1.) Set out a Risk Based Approach to categorize each of the FFC, Van Diesel, Smokey and ETG using the RBA approach.
2.) Write up any STR, UTR or AUTR present in the above fact scenario.
Include the following in your answer:
• Screening for and identifying suspicious transactions; this is part of YUB’s account opening and ongoing monitoring obligation
• Assessing the facts and context surrounding the suspicious transaction, if any, noted in the fact scenario above.
• Linking money laundering (ML)/terrorist financing (TF) indicators to the assessment of the facts and context in the fact scenario.
• Explaining YUB’s grounds for suspicion in filing an STR, if any, for Van Diesel, ERD and ETG.
FINTRAC expects MUB to articulate how the facts, context and ML/TF indicators allowed the CAMLO to reach his or her conclusion and specifically to note why the transaction(s) or attempted transaction(s) are related to.
Sample Solution