The following updates have been made to the workbook edition.
The end of chapter questions of chapters 1-5 have been amended as follows:
Chapter 1- End of Chapter Questions
2. State the main differences between rules-based and principles-based approaches to regulation.
Answer reference: Sections 1.3
6. State the key policy goals of MiFID II.
Answer reference: Section 1.5.2
7. List how the Market Abuse Regulation (MAR) applies to financial instruments to increase market integrity and investor protection.
Answer reference: Section 1.5.2
8. What does Section 404 of the Sarbanes-Oxley (SOX) Act require publicly registered US companies to do?
Answer reference: Section 1.5.2
9. What is the definition of payment services?
Answer reference: Section 1.5.2
10. What is the punishment for defrauding securities investors?
Answer reference: Section 1.5.2
11. How is AMLD best described?
Answer reference: Section 1.5.2
3. What is counterparty risk?
Answer reference: Section 1.7.2
14. How do regulators approach Fintech?
Answer reference: Section 1.8.1
Additionally, the question numbering has been changed from Question 10-24.
Chapter 2- End of Chapter Questions
2. Who is responsible for establishing a written compliance policy containing the basic principles followed by management and staff?
Answer reference: Section 1.1.2
3. What is the purpose of the compliance manual?
Answer reference: Section 1.2.1
4. What are the three key stages involved in a risk-based approach to a monitoring programme?
Answer reference: Section 1.4
Additionally, the question numbering has been changed from Question 3-10.
Chapter 3- End of Chapter Questions
2. What is the purpose of the Financial Action Task Force (FATF)?
Answer reference: Section 1.3.3
3. Give two examples of predicate offences in financial crime.
Answer reference: Section 1.3.4
4. How does a Ponzi scheme work?
Answer reference: Section 1.3.5
5. What are typical cybercrime activities?
Answer reference: Section 1.3.5
6. Describe how a material misstatement of financial statements may arise.
Answer reference: Section 1.3.6
7. What is the difference between tax avoidance and tax evasion?
Answer reference: Section 1.3.7
8. Explain the concept of dual criminality.
Answer reference: Section 1.3.8
17. In applying a risk-based approach to identifying money laundering, what factors should a firm consider?
Answer reference: Section 2.5
Additionally, the question numbering has been changed from Question 9-20.
Chapter 4- End of Chapter Questions
2. Name three Chartered Institute for Securities & Investment (CISI) Code of Conduct Principles.
Answer reference: Section 1.3.2
5. What are the components to create an ethical culture?
Answer reference: Section 1.5.7
Chapter 5- End of Chapter Questions
11. Name three of the Bank for International Settlements (BIS) principles for enhancing corporate governance.
Answer reference: Section 1.9
20. How do you calculate a risk score?
Answer reference: Section 2.5.1
Additionally, the question numbering has been changed from Question 11-31.
A new section, 2.4.6 on ‘whistleblowing’ has been added after section 2.4.5 of the workbook. (Page 150-151)
The following update has been made to the workbook edition.
Page numbering of chapter 5, Appendices, Glossary, MCQs and the SLM of contents page No.V has been changed and now reads as:
Governance, Risk Management and Compliance 169
Appendices 205
Glossary 227
Multiple Choice Questions 235
Syllabus Learning Map 269
Chapter 1
‘client’ has been marked as a glossary term under section 1.4
The paragraph started with ‘OTFs’ in between the table of section 1.6.3 and section 1.7 is removed.
End of Chapter Questions 2, 11,13 and 14, answer references have been amended and now read as follows:
2. State the main differences between rules-based and principles-based approaches to regulation.
Answer reference: Sections 1.3, 2.3.2, 2.3.3
11. How is AMLD best described?
Answer reference: Section 1.5.3
13. What is counterparty risk?
Answer reference: Section 1.7
14. How do regulators approach Fintech?
Answer reference: Section 1.8
Chapter 2
The LO 2.1.2 under section 1.2 is amended and now reads as follows:
2.1.2 understand Principle 6 of the BCBS Principles on Compliance and the compliance Function in Banks
The LO 2.2.4 under section 2.1.3 is amended and now reads as follows:
2.2.4 Understand Principle 5 of the BCBS Principles on Compliance and the compliance Function in Banks
End of Chapter Question No.3 is changed to read as:
3. What does Principle 5 of the BCBS Principles on Compliance and the compliance Function in Banks require of a firm’s compliance function?
Answer reference: Section 1.3.1
The answer references of End of Chapter Questions No.2, 3 and 4 are changed to read as:
2. Who is responsible for establishing a written compliance policy containing the basic principles followed by management and staff? Answer reference: Section 1.1.3
3. What does Principle 5 of the BCBS Principles on Compliance and the compliance Function in Banks require of a firm’s compliance function?
Answer reference: Section 1.3.1
4. What are the three key stages involved in a risk-based approach to a monitoring programme? Answer reference: Section 1.5
Chapter 3
The section number in ‘see section’ in the following paragraph under ‘Offshore Trusts’ is revised to read as follow:
Although offshore trusts may be used by people for legitimate tax planning, ie, minimising an individual’s or family’s tax liability within the tax regulations relating to their country of residence and the offshore centre, such trusts may also be used for tax evasion. While tax avoidance is legal, tax evasion is a crime and any suspicion is reportable as with any financial crime. See section 1.7 on tax evasion and tax avoidance.
The answer references of questions 2,3,4,5,6,7 and 8 and the Question No.2 of End of chapter questions in Chapter 3 have been amended as follows:
2. What is the purpose of the Financial Action Task Force (FATF)?
Answer reference: Section 1.3.4
3. Give two examples of predicate offences in financial crime.
Answer reference: Section 1.4
4. How does a Ponzi scheme work?
Answer reference: Section 1.5
5. What are typical cybercrime activities?
Answer reference: Section 1.5
6. Describe how a material misstatement of financial statements may arise.
Answer reference: Section 1.6
7. What is the difference between tax avoidance and tax evasion?
Answer reference: Section 1.7
8. Explain the concept of dual criminality.
Answer reference: Section 1.8
Chapter 4
Additional content has been added to section 3.1 to read as follows:
The following are the expected outcomes set out by the UK’s Financial Conduct Authority (FCA) for customers in the retail area from a fair treatment approach:
Outcome 1 – Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture.
Outcome 2 – Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly.
Outcome 3 – Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.
Outcome 4 – Where consumers receive advice, the advice is suitable and takes account of their circumstances.
Outcome 5 – Consumers are provided with products that perform as firms have led them to expect, and the associated service is of an acceptable standard and as they have been led to expect.
Outcome 6 – Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.
Firms are expected to be able to demonstrate that they are consistently treating their customers fairly and delivering fair outcomes relevant to their business. A firm needs to be able to:
demonstrate that senior management have instilled a culture whereby they understand:
• what the fair treatment of customers means
• where they expect their staff to achieve this at all times, and
• where (a relatively small number of) errors are promptly found, put right and learnt from
End of Chapter Questions
The answer reference of Question No.2 is amended to:
2. Name three Chartered Institute for Securities & Investment (CISI) Code of Conduct Principles.
Answer reference: Section 1.3.1
Section 4 has amended from Fair Dealing to Client Outcomes
The following content in 4.8.4 has amended to read as follows:
National rules will confirm how such segregation is achieved – in particular, the actions required when a firm receives client money. For example, a firm that operates the ‘normal approach’ to segregation must promptly place client money received into one or more accounts opened with any of the following (as permitted by the regulations):
• a central bank
• an institution authorised to hold client money
• a bank authorised in a third country
• a qualifying money market fund.
Glossary
The glossary term’ European Economic Area (EEA)’ is now removed as a glossary term.
MCQ
The following changes have been made to the MCQ questions and answers
Answers
5. C Chapter 1, Section 1.4 and 2.2.3
19. C Chapter 1, Section 1.5.3
Under the Foreign Account Tax Compliance Act (FATCA) and the US-UK intergovernmental agreement, a UK foreign financial institution must report to His Majesty’s Revenue and Customs (HMRC) on its account holders who are US persons or foreign entities with substantial US ownership.
26. B Chapter 5, Section 1.2
It is the responsibility of the board of directors to set out the governance structure for the organisation, to make sure it is implemented as intended, and to provide effective supervision over senior management. Members of the board need to act with honesty and integrity and need to be independent. Members of the board of directors and senior managers of financial institutions performing key roles need to be approved by the regulator to execute their function.
54. D Chapter 1, Section 1.6.3
60. D Chapter 5, Section 2.2.6
The key to managing stakeholder risk is to:
• build relationships at senior levels
• understand their agenda and how it may differ from the firm’s own agenda, and
• manage expectations with any new developments.
64. A Chapter 1, Section 1.3
72. D Chapter 2, Section 2.1.3
The concept of independence involves four related elements:
• Compliance should have a formal status within the firm.
• There should be a group compliance officer or head of compliance.
• Their responsibilities within the firm should not lead to conflicts of interest.
• They should have access to information and personnel.
74. C Chapter 3, Section 1.4
79. A Chapter 3, Section 1.7
83. D Chapter 3, Section 1.5
89. B Chapter 3, Section 1.6
19. In respect of the Foreign Account Tax Compliance Act (FATCA) under the UK-US intergovernmental agreement, which of the following are UK foreign financial institutions required to do?
A. Report monthly to the Internal Revenue Service (IRS) on account holders who are US persons or foreign entities
B. Report annually to the IRS on account holders who are UK domiciled
C. Report to His Majesty’s Revenue and Customs (HMRC) on account holders who are US persons or foreign entities
D. Report monthly to HMRC on account holders who are UK domiciled
26. Which of the following is responsible for setting out the governance structure of an organisation?
A. Head of Compliance
B. Board of Directors
C. Senior Management
D. SMCR Regime
SLM
The following changes have been done to the Syllabus Learning Map
Syllabus Unit/Element 3.1.5- Chapter/Section has revised to 1.4
Syllabus Unit/Element 3.1.6- Chapter/Section has revised to 1.5
Syllabus Unit/Element 3.1.7- Chapter/Section has revised to 1.6
Syllabus Unit/Element 3.1.8- Chapter/Section has revised to 1.7
Syllabus Unit/Element 3.1.9- Chapter/Section has revised to 1.8
Syllabus Unit/Element 3.2.8 - Chapter/Section has revised to 2.7
Syllabus Unit/Element 4.5.2 - Chapter/Section has revised to 5.1
Syllabus Unit/Element 5.2.6 - Chapter/Section has revised to 2.5.6