Warming to my theme of due diligence, I am privileged in my work with MLROs to share their disbelief at some of the replies they receive from clients – and even their own staff – as they battle manfully to fulfill their basic obligation to find out who their clients are and where their money is from. Here’s my current favourite (suitably anonymised to protect the despairing):
“We were opening a bank account with a UK bank for a long-standing trust. The UK bank asked for details of the original settlor. We told them the settlor was dead. ‘In that case,’ came back the answer, ‘please give us details of the new settlor.'”
If you have any of your own due diligence howlers, please add them as comments – anonymous is fine. I’ll draw the world’s attention to the best/worst.