A KYC specialist from the first line of defense at a bank initiates an internal...

A KYC specialist from the first line of defense at a bank initiates an internal escalation based on a letter of credit received by the bank.

MEMO

To: Jane Doe. Compliance Manager, Bank B From: Jack Brown, KYC Specialist, Bank B RE: Concerning letter of credit

A letter of credit (LC) was received from a correspondent bank. Bank A. in Country A. in Asia with strict capital controls, providing guarantee of payment to Bank B's client for the export of 10 luxury cars located in Country B. located in Europe. Bank A's customer is a general in the army where Bank A is headquartered.

The information contained in the LC is as follows:

• Advising amount per unit 30.000.00 EU •10 units of BMW

• Model IX3

• Year of registration: 2020

Upon checks on Bank B's client, the exporter mentioned that the transactions were particularly important, and a fast process would be much appreciated in order to avoid reputational damage to the firm and the banks involved in the trade finance process. The exporter has a longstanding relationship with Bank B and was clearly a good income generator. The exporter indicated that, as a general, the importer was trustworthy.

The relationship manager

Feedback from the RM:

The RM contacted the exporter for a client courtesy visit, but it was rearranged four times as the exporter kept cancelling the appointments. When the exporter was finally pinned down for an interview, employees were reluctant to provide clear answers about the basis of the transaction. The employees were evasive when asked about the wider business and trade activity in the country.

Findings from the investigation from various internal and external sources of information:

• There were no negative news or sanctions hits on the exporter company, directors, and shareholders.

• The registered address of the exporting business was a residential address.

• The price of the cats was checked and confirmed to be significantly below the market price of approximately 70,000 EU, based on manufacturer's new price guide.

• The key controllers behind the exporting company, that is the directors and

During the investigation, the investigator determines that a nephew of the general (Bank A's customer) is a customer at Bank B. Which step should the investigator take next?