CompCo-Report Writing - Law Assignment Help

Assignment Task

All parts of the question can be answered in relation to a jurisdiction with which you are familiar.

The name of the jurisdiction you have selected should be clearly stated in your answer.

Answer all parts of the question.

Question

a) Sanctions compliance is an ever-present requirement and sanctions screening is an important activity for firms. They are required to ensure that they are not conducting prohibited business activity and that they are not doing business with individuals, entities, vessels, or jurisdictions that are subject to applicable sanctions.

In the context of international sanctions, evaluate the key risks and issues related to the sanctions screening that is undertaken by regulated firms.

b) Roberta is a compliance analyst at CompCo, a large, regulated financial services firm, whose Head Office is based in a jurisdiction of your choice. CompCo has several subsidiaries globally.

During a recent customer review, Roberta has become concerned about several notes she has found, in customer files, about potential risk indicators flagged by relationship managers (RMs) that have never been followed up. These include:

• several customers with links to Russia whose sources of wealth and sources of funds were noted as never having been fully established
• many RMs recorded concerns about different account activity but at client meetings, where more information about the activity was sought, clients were recorded as becoming aggressive, threatening to take their business elsewhere
• in cases where clients had businesses that involved different entities, the RMs seem to have investigated beneficial ownership to some extent, but there were several notes in the files stating ‘investigations came to a halt owing to lack of information’
• as a general point and due to the review of the files, Roberta also makes the observation that there appears to be a very small number of internal ML suspicion reports, commensurate with the size of the firm and number of accounts operated. Consider each of the bullet points above and discuss the implications of the facts contained within them.

Evaluate whether Unusual Activity Reports (UARs or Internal Suspicious Reports) or Suspicious Activity Reports/Suspicious Transaction Reports (SARs/STRs) should have been submitted and, in cases where they should have been submitted, what the risk implications were for the firm.

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