Submitting your assignment  

1. Please collate your assignment as a single document in aMicrosoft Word format.

2. Save the assignment as your candidate ID number, e.g.CON-000123456.

3. All marking is anonymous, which means your name should notappear on your work.

4. You must state which region/jurisdiction you are from in theheader of each page.

5. You must ensure that all your work is properlyreferenced.

6. Penalties will be applied to those candidates who submittheir assignment after the due date.

Word count

7. The total word count for this assignment should be between2,000 and 2,500 words. This includes all in text references andappendices but excludes any footnotes, reference page or contentspage. N.B. Appendices should only be used in exceptionalcircumstances and should consist of only brief extracts ortables.

8. The number of words per question should reflect the number ofmarks allocated.

9. Penalties will be applied for excessive overall wordcount.

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

Where a specific jurisdiction has been selected, this should beclearly stated in your answer.

Answer all parts of the question.

Question

Olivia is a director and money laundering reporting officer(MLRO) of NRO Bank, a small local bank based in a jurisdiction ofyour choice. She is responsible for a number of areas of the Bank'soperations, including the Human Resources division and New BusinessAcquisition, as well as bearing the AML responsibilities.

Olivia has a strong personality and is trusted by the Bank'sboard, who rely on her to get things done. She is rarely challengedby other members of the board or other staff members.

The Bank has recently been the subject of a regulatory visit andthe report that followed has been highly critical of both the boardand the MLRO. Key criticisms included the following failings.

• • A failure on the part of the MLRO to process internalsuspicious activity reports (SARs)/suspicious transaction reports(STRs) and externalise them to the Financial Intelligence Unit(FIU) (26 in total, with some as old as 18 months).

• • The MLRO deliberately misled the board into believing thatmoney laundering was not a significant issue within the Bank. Shedeliberately failed to notify the board that internal SARs had beenmade.

• • The board of the Bank failed to meet regularly and did notmonitor the internal AML reporting system and processes.

• • The MLRO was an extremely powerful individual and deemedunapproachable by members of staff.

• • The Bank prioritised business development overcompliance.

• • From a corporate governance perspective, it wasinappropriate for Olivia to control so many other areas of theBank's operations while also carrying out the MLRO role.

Q)What remedial action do you believe the Bank should take inorder to remedy the issues highlighted?

The country/jurisdiction to be selected is DUBAI