Cis & Caucasus

Indications of involvement in corrupt practices created cause for concern. CRW undertook a systematic analysis and enquiries with an extensive network of sources in the country and the broader region. The work uncovered that the bank had improved its governance in recent timets, but confirmed the existence of past episodes of involvement in money laundering and fraud, links to sanctioned subjects and opaque relations with PEPs.

Based on our risk assessment the client was able to take a risk-based decision and mitigate the risks identified.

Analysis and enquiries identified multiple violations of anti-money laundering legislation and it was established that the bank’s beneficial ownership was not transparent and the source of wealth of the alleged UBO was a cause for concern. In addition, there was reason to believe that the UBO and, therefore, indirectly the bank, had an elevated sanctions risk exposure.

Based on the results of the investigation, the client decided not to pursue a business relationship with the bank.