Advise Adam as to what action he should take in this scenario

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Can the below be included in the questions
A)give an example of what a high net worth individual is and explain the
risks. Also the risks of dealing in Art and some red flags for money
laundering – What are the AML red flags in the scenario
B) mention failure to report offence and Money laundering is defined as
an act which constitutes an offence under S.327, 328 and 329 or a
conspiracy or attempt to commit such an offence under POCA 2002. Make
reference to Griffiths v Pattison about failing to report a transaction
C) Give actions against bank and Adam such as fine, trading bans, what
the authorities impose(don’t restrict to the UK which is my
jurisdictions. On the uploaded file i have included the maximum word
count for each question. My jurisdiction is UK so please use UK rules
and laws (other than question C where it can be expanded. Thanks so much
and any questions please contact me. I chose you again as i was very
impressed with the previous questions you did for me. The attached file
has the scenario and the questions

Advise Adam as to what action he should take in this scenario

Assignment 2 Question
Adam is a member of the relationship management team at Onyx bank and specialises in looking
after the accounts of high-net-worth customers. One of his major accounts is that of Sergio Malakov,
a Russian art dealer based in London. Sergio is a Ukrainian national, but his art business, which is
based around the trade in Russian art and cultural artefacts is rumoured to have connections to the
Russian Mafia. Adam is aware of these rumours but has never seen any factual evidence to
substantiate them. Sergio Malakov is regarded as an important customer by Adam’s line
management and is highly valued by the bank.

Recently, Adam has noticed that a significant change has occurred in relation to the size, frequency,
destination and origin of funds flowing into and from the accounts of Sergio Malakov. Previously
funds flowed predominantly back and forward between London and Moscow, whereas recently
transactions have been global, with unusual transactions of funds being sent to Dubai, Iraq, Ukraine
and Saudi Arabia.

Advise Adam as to what action he should take in this scenario

Adam is concerned about the account activity from a money laundering perspective and at a client
meeting with Malakov he asks for more information about the transfers. The interview reveals that
Malakov has a strong interest in politics and wants to become a politician in the Ukraine in the future.
To fund his political aims, he has expanded his art business to become more global, hence the sale
and purchase of more artefacts to a range of locations

Malakov seemed reluctant to give more details and asked for confidentiality because of the
sensitivities of his political goals. When asked about a transfer of funds to an organisation that
allegedly had connections to the Russian Mafia, he became aggressive and strongly disputed any
negative implications linked to his activities

Adam does not want to lose the client but is still concerned about the nature and destination of many of the transactions that do not appear to link directly to his business.

A)    Advise Adam as to what action he should take in this scenario (625 words 25 marks)

B)    If Adam takes no action and it transpires that Sergio Malakov has used his accounts for money laundering purposes, identify what criminal offences may have been committed by Adam and the bank. (625 words 25 marks)

C)    Analyse the risk issues raised by the scenario (1250 words 50 marks)

Advise Adam as to what action he should take in this scenario