International Advanced Certificate in Anti Money Laundering
Assignment Two
Submission due date: 9th January 2023
Please read through the following guidance notes before writing your assignment. Submitting your assignment
1. Please collate your assignment as a single document in a Microsoft 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 not appear on your work.
4. You must state which region/jurisdiction in which you are working from in the header of each page.
5. You must ensure that all your work is properly referenced.
6. Penalties will be applied to those candidates who submit their assignment after the due date.
Word count
7. The total word count for this assignment should be between 2,000 and 2,500 words. This includes all in 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.
8. The number of words per part of the question should be in proportion to the number of marks allocated.
9. Penalties will be applied for excessive overall word count.
Academic malpractice
The ICA regards plagiarism and other forms of academic malpractice, such as collusion and fabrication, as serious academic offences.
10. 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.
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12. The 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.
Your assignment questions are on the next page
International Advanced Certificate AML – Assignment 2 – 9 January 2023
All parts of the questions 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 questions.
Question
Joseph is employed in a relationship management role in a large financial services firm in a jurisdiction of your choice.
One of the major accounts that he has managed for the last few years is that of Massimo Coltella (MC), an international art dealer, based in Switzerland. MC is an Italian national with strong ties to Sicily and he has worked extensively across the world. MC’s father is rumoured to have strong connections to organised crime in Sicily.
Joseph has noticed that recently, significant amounts of money have been transferred in and out of MC’s accounts in Sicily, and funds have then been transferred to other parts of Europe and Africa. These transfers are not typical of the preceding account activity in respect of MC’s accounts.
Joseph is concerned about the account activity from a money laundering perspective and at a client meeting with MC he asks for more information about the transfers. MC tells Joseph that his business as an art dealer has really taken off and that the transfers relate to payments for pieces of art that rarely come to market but which he has had the opportunity of buying. Many of the payments have been made to corporate structures that have been set up to avoid paying tax.
Joseph tries to get more information but MC becomes quite aggressive and tells Joseph that if he has any problems with the movement of funds, then he will move his accounts elsewhere.
Joseph does not want to lose the business, but is still concerned given that a number of the transfers are from MC’s father and do not appear to link directly to MC’s business activities.
i. Advise Joseph as to what action he should take in this scenario.
ii. If Joseph takes no action and it transpires that MC has used these accounts for money laundering purposes, define what criminal offences have been committed by Joseph and the organisation and analyse the nature of these offences.
iii. Analyse the risk issues raised by the scenario.
Total 100 marks
2 ICAA626