As a member of the AML, CDD checks need to be performed for the potential client, GMT due to the nature of the business activity as a dealer in dealing with precious metals.

An effective CDD process involves identifying and identifying the identity of clients as well as understanding the purpose and nature of the business relationships.

Thus, prior to updating to Board, the CDD process is fundamental to:

Prevent reporting intuitions from creating anonymous and fictitious accounts1 and
Access the extent of money laundering (ML)

Based on the nature of the client’s business, it is clearly classified under Inherent Risk which is defined as the possibility of inaccurate information appearing in a financial statement due to error or omission, not a failure of internal controls. It is most likely to occur when transactions are complex and use of difficult –to-access financial instruments.

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