How would you design a global CDD framework that remains consistent while accommodating local regulatory requirements?I would establish a global minimum-control standard covering identity verification, beneficial ownership, screening, customer risk rating, enhanced due diligence, and ongoing review. I would then maintain jurisdictional addenda approved with local MLROs to document stricter or distinct local requirements. Governance should include clear ownership, change controls, testing, metrics, and periodic reviews to ensure the framework remains operationally effective.
Describe your approach to implementing a customer risk-scoring framework for retail and corporate customers.I would begin with a documented risk assessment and define explainable risk factors such as geography, customer type, ownership structure, product usage, transaction behavior, sanctions exposure, and adverse media. The scoring model should have calibrated thresholds, defined EDD triggers, and a documented override process with quality assurance. I would validate outcomes through back-testing, periodic tuning, and monitoring of false positives, escalation volumes, and risk-segment trends.
How would you handle an escalation from a banking partner regarding potentially inadequate KYC controls?I would acknowledge the issue promptly, gather the relevant customer, control, and audit evidence, and assess the concern against policy and regulatory obligations. I would coordinate the appropriate remediation with compliance operations, product, legal, and the local MLRO where needed, while providing the banking partner with transparent status updates. After resolution, I would perform root-cause analysis and track preventive actions to completion.
What metrics would you report to leadership for global CDD projects and control effectiveness?I would report project milestones, delivery risks, dependency status, jurisdictional rollout progress, and remediation aging. For control effectiveness, I would include onboarding turnaround time, QA error rates, EDD volumes, escalation trends, periodic-review completion, screening alert outcomes, audit findings, and overdue corrective actions. Metrics should distinguish operational workload from actual risk indicators so leadership can make informed prioritization decisions.
How do AML/CFT and sanctions risks differ for a crypto business compared with traditional financial services?Crypto businesses can face rapid, cross-border movement of value, pseudonymous counterparties, exposure to wallets and decentralized services, and elevated typology changes. A strong program combines conventional CDD and beneficial-ownership controls with blockchain analytics, wallet screening, transaction monitoring, source-of-funds reviews, and clear escalation procedures. I would ensure controls are risk-based, documented, and aligned with the licensing and reporting obligations in each operating jurisdiction.
