Anti-Money-Laundering and Professional Ethics
Core concepts
Anti-money-laundering rules require customer due diligence, identification of the beneficial owner, ongoing monitoring, and reporting of suspicious transactions. Know the risk-based approach, simplified and enhanced measures, and the record-keeping periods. Professional ethics covers independence, impartiality, confidentiality, conflict of interest, and the duty to refuse unlawful instructions.
Traps
Questions test when enhanced due diligence is mandatory (politically exposed persons, high-risk jurisdictions), what to do when identification is impossible, and the interaction between confidentiality and reporting. Watch the rule that a notary must not disclose a report to the client.
Rule of thumb
Identify, verify, assess risk, monitor, report. Example: A client insists on anonymity; the notary cannot complete identification, must decline the transaction, and should consider a suspicious transaction report without tipping off the client.