International Diploma in Governance, Risk & Compliance
Assignment Three
Submission due date: 3 December 2018
Please read through the following guidance notes before writing your assignment.
Submitting your assignment
1. Please collate your assignment as a single document in a Microsoft Word format
2. Save the assignment as your candidate ID number, e.g. CON-000123456.
3. All marking is anonymous, which means your name should not appear on your work
4. You must state which region/jurisdiction you are from in the header of each page
5. You must ensure that all of your work is properly referenced. ICA accepts either footnote or Harvard style referencing.
6. Penalties will be applied to those candidates who submit their assignment after the due date Word count.
7. The total word limit for this assignment is 3,500 words. This includes all footnotes, in text references and appendices but excludes any bibliography, reference page or contents page. N.B. Appendices should only be used in exceptional circumstances and should consist of only brief extracts or tables.
8. The amount of words per question should reflect the number of marks allocated.
9. Penalties will be applied for excessive overall word count Academic malpractice
The ICA regards plagiarism and other forms of academic malpractice, such as collusion and fabrication, as serious academic offences,
10. When submitting your assignment to ICA you have responsibility for ensuring that:
a. it is entirely your own work, except where you have given fully-documented
references to the work of others.
b. the material contained in your assignment has not previously been submitted for
assessment in any formal course of study. 11. All assignments are screened using Turnitin detection software that checks for passages found elsewhere on the internet, in books and journals or in work previously submitted.
12. The ICA has issued guidelines on academic malpractice to help clarify for you what will be
considered as constituting these offences and to indicate the nature of the penalties that
may be imposed where they occur.
Further advice on all aspects of assignment writing and submission is available in the
ICA Assessment Handbook
Your assignment question is on the next page
International Diploma in Governance, Risk and Compliance – Assignment Three – 3 December 2018
2 ICAA262
All questions can be answered in relation to a jurisdiction with which you are familiar.
Answer all questions.
Question 1
You are the head of compliance for a firm in a jurisdiction and sector of your choice. Rather
than a single central office in which all areas of the business are based, the firm operates from
multiple sites throughout the jurisdiction and, consequently, there is little day-to-day interaction
amongst the firm’s staff working in different areas of the business. With the aim of encouraging
interaction, regular training and development days are scheduled, during which members of
different departments present short sessions on their own area of business, providing insight
into their activities and how these relate to the overall aims of the firm. You have been invited
to present a session at an upcoming training event. Due to the continuing fast-paced
development of the regulatory environment within which the firm operates, you have identified
that it will be useful for attendees at the session to more fully understand the current regulatory
environment and also the importance of regulatory compliance, both for the firm and the
industry, as a consequence of that environment.
With the above in mind, produce a plan that clearly sets out the topics that you will cover during
the training session and the materials that you will use in support of this. You should state the
objectives of the session, what will be covered and why, how you will deliver the session and
how you will ensure this is effective in meeting its brief. However, the detailed content of the
training is not required.
(25 marks)
Question 2
You are a senior member of the risk management team in a regulated firm in a sector and
jurisdiction of your choice. As part of your role you regularly carry out training with staff from
across the business to ensure understanding of how your firm’s risk management process
operates and how it is used within different business functions. A new member of staff has
recently been recruited into the compliance team and you have been asked to spend some
time with them to ensure they too understand the basics of the risk management process.
a) Explain to the new member of compliance staff who has no previous knowledge or
experience of risk management practices:
• what the above diagram represents
• what its purpose is within the risk management regime, and
• why it is of relevance within a regulated firm.
International Diploma in Governance, Risk and Compliance – Assignment Three – 3 December 2018
3 ICAA262
(6 marks)
b) Select two products or services offered by your chosen firm. Using these products or
services as the basis, explain to the new member of compliance staff the risk
assessment process in place within your firm to help them understand this process. In
doing so:
• compare and contrast the two products or services from a risk perspective, and
• briefly explain each stage of the risk assessment process.
(19 marks)
(Total 25 marks)
Question 3
Worldwide is a firm newly regulated in a jurisdiction and sector of your choice. The recently
appointed head of compliance has been given a mandate by the executive board to design,
implement and manage the compliance function and is due to attend the next board meeting
to provide an overview of these plans. The compliance function is part of the risk division within
the firm and in their new role the head of compliance reports to the director of risk.
Prepare a report for the executive board to accompany the presentation by the head of
compliance at that meeting, taking the board through the key steps required in this process,
identifying the critical success factors along the way. The report should also make clear what
the main challenges to the successful completion of this programme are and explain why these
are the main challenges, as well as providing a clear indication of how these can be managed.
(25 marks)
International Diploma in Governance, Risk and Compliance – Assignment Three – 3 December 2018
4 ICAA262
Question 4
An experienced compliance manager, you have recently joined a bank regulated in a
jurisdiction of your choice. Due to a management reshuffle, there is temporarily an absence of
a specifically designated Money Laundering Reporting Officer (MLRO). The firm’s board has
now asked you to ‘fill in’ for the MLRO role in the short term, stating that recruitment is well
under way, so it should only be for ‘a matter of weeks’. Having been informed of your interim
responsibility, Mr Jones, one of the back-office support staff for the customer relationship
managers (CRMs), has requested a meeting with you.
At the meeting, Mr Jones spells out his concerns about Mr Smith, who is the top performing
CRM and deals with a number of very wealthy, internationally mobile, customers. Mr Smith
does not allow any of the other CRMs to work with ‘his’ clients; even when he is on annual
leave he remains available for clients to contact.
Mr Jones mentions a Mr Adams in particular and reports that the documentation held by the
Bank about Mr Adams contains ‘very little detail’. Mr Adams is apparently a well-known figure
in his home country, where a petro-chemical firm to which he has links maintains a number of
government contracts; these are facilitated through his brother who is a high-ranking army
general. He commonly uses your Bank to transfer money across jurisdictional boundaries.
In terms of customer documentation, Mr Jones informs you that the Bank actually holds very
little. Despite Mr Jones’s numerous reminders, Mr Smith seems to keep ignoring or misplacing
even the most basic customer due diligence (CDD) information that has been requested of
him. When pressed on this, Mr Smith told Mr Jones to ‘back off’ stating that the customer is ‘a
wealthy businessman, bringing a lot of money through the Bank, which is keeping everyone
happy’.
The balance of Mr Adams’s accounts currently exceeds $20 million.
a) Identify three of the principal areas of concern in the scenario above and the main risks
that these represent to the firm, explaining why these issues are of concern.
(15 marks)
b) Recommend to Mr Jones, and your firm, the next actions to take, and explain why
these should be taken.
(10 marks)
(Total 25 marks)
Total 100 marks
