Please read through the following guidance notes before writing your assignment.
The paper needs to be done under Irish Jurisdiction.
“Footnote Style referencing” must be used.
Any amount of sources.
Submitting your assignment
- Please collate your assignment as a single document in a Microsoft Word format.
- Save the assignment as your candidate ID number, e.g. CON-000123456.
- All marking is anonymous, which means your name should not appear on your work.
- You must state the region/jurisdiction in which you are working in the header of each
- You must ensure that all your work is properly referenced.
- Penalties will be applied to those candidates who submit their assignment after the
- The total word count for this assignment should be between 3,000 and 3,500 words.
This includes all text references and appendices but excludes any footnotes, reference
page or contents page. N.B. Appendices should only be used in exceptional
circumstances and should consist of only brief extracts or tables.
- The number of words per part of the question should be in proportion to the number of
- Penalties will be applied for excessive overall word count.
ICA regards plagiarism and other forms of academic malpractice, such as collusion and
fabrication, as serious academic offences.
- When submitting your assignment to ICA you have responsibility for ensuring that:
a. it is entirely your own work, except where you have given fully documented
references to the work of others
b. the material contained in your assignment has not previously been submitted
for assessment in any formal course of study.
- All assignments are screened using Turnitin detection software that checks for passages
found elsewhere on the Internet, in books and journals or in work previously submitted.
- ICA has issued guidelines on academic malpractice to help clarify for you what will be
considered as constituting such offences and to indicate the nature of the penalties
that may be imposed where they occur.
Further advice on all aspects of assignment writing and submission is available in the
ICA Assessment Handbook.
All parts of the question can be answered in relation to a jurisdiction with which you
The name of the jurisdiction you have selected should be clearly stated in your
You are a newly appointed money laundering reporting officer (MLRO) at a medium-sized regulated financial services firm based in a jurisdiction of your choice.You have been asked by the board of directors to undertake a thorough review of the AML
policies, procedures and culture prevalent in the firm.
A recent regulatory visit to the firm highlighted inadequate AML systems and controls. The board
members are concerned that the firm may suffer regulatory penalties or negative publicity as a
Before your appointment, the AML role was fulfilled by the firm’s regulatory compliance officer.
You conduct initial investigations and discover the following facts.
• The firm is expanding into provision of complex investment and tax-avoidance services
for high-net-worth individuals (HNWIs).
• The board has a high risk appetite for business, particularly in jurisdictions that are
listed on the Transparency International Corruption Perceptions Index as those where
the levels of corruption are high.
• The chief executive officer (CEO) of the firm encourages sales techniques that may
not be in the best interests of the customers. The CEO was formerly the sales director.
He has introduced substantial staff bonus payments tied to new business targets. This
has resulted in a corporate culture where customer due diligence (CDD) is conducted
but there is a lack of enthusiasm for the process.
• The CEO has made it clear that while he appreciates that CDD must be conducted,
staff should not let this unduly inhibit sales, particularly for the new HNWI customers.
• The files you examine indicate that information about source of wealth and source of
funds is often basic and is rarely independently verified.
• Previously, the regulatory compliance officer (much to her annoyance) has had
responsibility for AML within the firm. When interviewed she stated that she had
‘neither the time, nor the training to properly fulfil this role’. She commented that ‘the
CEO is aggressive and everyone does what he says’. She further stated that had it not
been for the regulatory report, the firm would not have appointed a new MLRO.
• Where a new HNWI applies to become a customer, the internal procedure is that the
application has to be passed to the CEO for final sign-off. To date no HNWIs have
been refused, despite the fact that many originate from high-risk jurisdictions and often
have military or government connections.
In your review paper you need to cover:
• an assessment of the AML culture within the firm
• an analysis of the AML and CDD risks inherent in the way the firm is operated
• a schedule of recommendations to reduce AML and financial crime risk and better
protect the firm.
Total 100 marks