與代理銀行客戶的財務經理保持良好關係的客戶官員得知,執法部門已要求代理銀行提供許多記錄。為了與客戶保持良好的關係,客戶官員召開會議與客戶討論法律請求。客戶官員打算在會議期間討論與調查相關的要點。
反洗錢專家該推薦什麼?
Correct Answer: C
the account officer should avoid disclosing any details of the investigation to the customer, as this could compromise the integrity of the law enforcement inquiry, or even constitute tipping off, which is a criminal offense in many jurisdictions12. The account officer should only inform the customer that a legal request has been made, and that the bank is obliged to comply with it, without revealing the nature or scope of the request3. The account officer should also document the communication with the customer, and report it to the appropriate internal authority, such as the compliance officer or the legal department4.
Reference:
1: CAMS Study Guide, 6th Edition, Chapter 5: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), page 151-152. 2: Tipping Off: What It Is and How to Avoid It, ACAMS Today, March 2019. 3: How to Handle Law Enforcement Requests, ACAMS Webinar, June 2018. 4: Best Practices for Responding to Law Enforcement Inquiries, ACAMS White Paper, October 2017.