Q: 1
A client with many personal and business deposits with the financial institution (Fl) seeks a business
loan. The client wants to guarantee the loan with a trust for which they are the beneficiary.
An investigator examines the trust. The trust has many layers, including shell companies in known tax
havens. The client's ultimate beneficial ownership claim cannot be validated, and the loan is denied.
Two months later, the Fl receives a law enforcement (LE) request on one of the client's business
accounts. While reviewing the business account, the Fl receives another LE request on the same
account from another agency. The requested information is shared.
Three months later, a branch manager receives a request to open a business deposit account related
to a complex trust. The manager forwarded the request because of the complexity. The trust was the
same as the previously examined trust, but the request came from a different client. The second
client also has many accounts with the Fl. Further inspection finds links between the second client
and the Paradise Papers. The Papers state the client led illegal activities and committed tax evasion.
What steps should the investigator take to review the accounts held by the second client who is
listed in the Paradise Papers? (Select Two.)
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