What should a Financial Institution do to enable its employees to make the determinations described in response to the prior question?
The Financial Institution should address the principles noted in response to Questions 1 and 2 above in its policies and procedures. In addition, the Financial Institution should provide training to appropriate employees to enable them to make the relevant determinations and to escalate matters when appropriate. Such training could include pertinent case studies. Managers should supervise the activities of their employees to assure that such employees are making these determinations appropriately and escalating in accordance with the Financial Institution’s procedures. Part C: Loan Syndications, Participations and Trading Loan syndications and loan trading are not generally associated with money laundering activity. Questions do arise, however, as to the AML responsibilities of Financial Institutions in this context.
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