Financial crime risk analysis and advice in relation to high net worth (HNW) investors’ dividend distributions

Our client had a policy that it did not operate high volume corporate accounts. The distinction between transactional corporate accounts and dividend distribution accounts can become blurred when distributions involve FX and netting between group companies.

Analysis of the bank’s clients’ proposed transaction patterns was required in order to ensure the bank could remain within its own policy restriction and ensure adequate mitigation of any financial crime risk, before the bank was willing to agree to operate the required distribution accounts.

We worked with the bank’s relationship managers and second line of defence team to document and understand the proposed transaction scenario. This was supplemented by interviews with the bank’s client to further understand the client’s business logic for the proposals.

Following this analysis we documented all the proposed transaction flows together with their business justification, expected volumes and values, and associated parties.

Our analysis and documentation provided a sound basis for the bank to assess compliance against its account policy and to understand the financial crime due diligence requirements for all associated client parties (group companies and shareholders).