20 - 25 minutes
Certificate Included
China
"This self-paced course takes approximately 20 to 30 minutes to complete and is designed for private bankers, relationship managers, business development professionals, front-office leaders, and compliance partners working in international private banking environments. The course examines how AML, CFT, and Counter-Proliferation Financing risks arise through client acquisition, onboarding, and ongoing relationship management. While grounded in international standards issued by the Financial Action Task Force (FATF), the content reflects how these expectations are implemented across major regulatory regimes, including the US, UK, EU, and other FATF-member jurisdictions. Learners will explore practical topics such as source of wealth assessment, complex ownership and control structures, ethical pressure and incentive risk, ongoing monitoring, effective escalation to compliance and the MLRO, and defensible documentation. The course emphasises judgement over box-ticking, explaining how compliance works in practice through realistic front-office scenarios. By the end of the course, participants will understand how their decisions directly affect institutional risk exposure and how to apply a risk-based, defensible approach that meets regulatory expectations while maintaining professional client relationships."
Module 1: The Front Office as a Control Function
You will learn why regulators view private banking business development as a critical first-line AML control, and how front-office decisions influence institutional exposure. The module explains regulatory expectations under FATF and supervisory guidance, focusing on accountability, judgement, and governance at the point of client entry.
Module 2: Client Acquisition Risk
This module explains how AML risk enters an institution during onboarding. You will learn how to assess higher-risk client profiles, distinguish source of wealth from source of funds, manage intermediary risk, and identify weak or unverifiable narratives in line with FATF Recommendations and customer due diligence standards.
Module 3: Incentives, Pressure, and Ethical Drift
You will explore how commercial incentives and organisational pressure can weaken controls over time. The module focuses on ethical drift, behavioural risk indicators, and the importance of maintaining a strong compliance culture consistent with regulatory expectations on conduct and individual accountability.
Module 4: Understanding Complex Ownership and Control
This module covers how trusts, foundations, holding companies, and family offices can obscure control. You will learn how to identify beneficial ownership and control in practice, applying FATF guidance on transparency and escalation when complexity undermines understanding.
Module 5: Ongoing Relationship Risk
You will learn why AML risk evolves throughout the client lifecycle and how to identify trigger events that require reassessment. The module explains ongoing monitoring, familiarity bias, and risk-based vigilance aligned with supervisory expectations for continuous due diligence.
Module 6: Interaction with Compliance and the MLRO
This module explains how to escalate concerns effectively, what compliance and the MLRO require from the front office, and how to avoid tipping off. It focuses on practical escalation, information sharing, and confidentiality obligations under AML and CFT frameworks.
Module 7: Documentation and Decision Ownership
You will learn how to document judgement and decisions in a defensible manner. The module explains what regulators expect to see during reviews, how documentation supports governance and accountability, and why undocumented decisions increase individual and institutional risk.
Module 8: Practical Scenarios and Behavioural Guidance
This final module applies course principles to realistic private banking scenarios, including client resistance, senior referrals, and intermediary pushback. You will practice choosing defensible outcomes under pressure, reinforcing a risk-based and regulator-aligned approach.”
