Description:

Involves an intermediary, agent, or representative who performs services on behalf of the firm or is authorized to represent the firm through other 3rd parties.

Appears in:

• Acquisition Leveraged Finance
• Certificate of Deposit (Broker Acting on Behalf of Client)
• Certificate of Deposit (Direct Interaction with Clients)
• Constant Proportion Portfolio Insurance (CPPI)
• Credit Linked Deposit
• Credit Linked Note
• Deposit
• Deposit (Direct with Client)
• Deposit (via Broker)
• Dual Currency Deposit (DCD)
• Equity Linked Note
• Exchange Traded Funds (ETFs) (Counterparty to Counterparty)
• Exchange Traded Funds (ETFs) (Exchange Traded)
• FX Prime Brokerage (Continuous Linked Settlement)
• FX Prime Brokerage (Non-Continuous Linked Settlement)
• FX Spot
• International Services
• Structured Deposit
• Trade Receivable Securitization
• Traditional Hawala

Addressed by:

• Approval to Make 3rd Party Payment: Compliance approval is required for 3rd party payment and monitoring.
• Bank to Bank Transfers (Low Risk Jurisdictions): Payment can only be made via bank-to-bank transfers from countries with strong AML controls (typically low-risk jurisdictions).
• Gifts and Entertainment: Monitoring of inducements or gifts, and entertainment.
• Low Risk Multi-Banked Customer: The customer must establish more than one relationship with a firm or another official body (e.g., a regulator) in a low-risk jurisdiction.
• SWIFT Confirmation: Requires confirmation via SWIFT that payment will be used solely for agreed purposes pre-release and post-payment
• Transactional Due Diligence (TDD): Conducts a detailed examination of specific transactions identified as being higher risk.