Very important:

 You copy shall not exceed 2 pages (font ‘’Arial’’ 10 or equivalent)


Further to brilliant studies performed at UPEC University you have been appointed to work in the trade finance team of ITFB, International Trade Finance Bank1. Your knowledge in the field of Compliance is highly appreciated in order to mitigate growing risks that all corporates and banks are facing henceforward.

Luckily, you have been appointed to work in the ITFB branch headquartered in New-York, in order to mitigate compliance risks, protect the bank in this very sensitive area and fight against AML-TF2 breaches.

Compliance Officer, you are reporting now to Mrs. Collins, Head of Compliance for ITFB US. Everyone in the branch is aware that Mrs. Collins appreciates efficiency, clear flowcharts and concise explanations, and always asks her staff to go right to the point. Her agenda is quite busy…


Question 1 (3 pts): Referring to the L/C terms (cf. Appendix) that are received from your colleagues of

the L/C3 Department of ITFB New-York.

– What is the full diagram / flowchart of such deal?

You shall detail all stakeholders, steps / flows, from the signature of the contract until

the payment to the beneficiary

1 – ITFB is one of the largest banks in USA, Investment grade ranked AA1 / AA+ (Moody’s, Fitch, Standard & Poor’s). 2 – Anti Money Laundering & Terrorism Financing 3 – Letter of Credit


Question 2 (12 pts). Very much concerned about this draft, Mrs. Collins requests all your comments

regarding this Letter of Credit.

– From a compliance standpoint what are, in details, all due diligences to perform in such type of


– As a Compliance Officer in charge of scrutinizing this deal specifically, what are the various

issues that comes out from this MT700 message?

– Would you approve such deal? In case you would not, what are the amendments to perform in

order to allow the L/C department to proceed?

Question 3 (5 pts). A growing way for money launderers to transfer large amounts of money across

borders relies on ‘’over invoicing’’ and / or ‘’under invoicing’’ technics.

– Using diagrams / flowcharts including the buyer, the seller, and both banks, detail the

different steps describing each one of these two technics used by money launderers.

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