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Jack-Alexander is president and CEO of Royal Assets Investment Group, an investment adviser that is a wholly owned subsidiary of Royal Assets Bank. Royal Assets
Jack-Alexander is president and CEO of Royal Assets Investment Group, an investment adviser that is a wholly owned subsidiary of Royal Assets Bank. Royal Assets Investment Group uses the 25 branch offices of the bank for its business locations. One client of Royal Assets Investment Group, a long-time bank customer and personally known by Jack-Alexander and the board members of the bank, opened an investment account at Royal Assets Investment Group with the stated investment objective of income. Although the client did make a few investments over the course of a year, the client engaged in almost exclusively banking activity in the account that involved hundreds of transactions and consisted of $115 million in deposits and $105 million in withdrawals. The transactions included electronic transfers to and from individuals and entities located in bank secrecy havens or countries identified by the government as presenting a money laundering risk. In addition, Jack-Alexander understood the client to be engaged in a type of international business activity that presented an increased risk of transactions being tainted by corruption or bribery. But because of the client's longstanding relationship with the bank, Jack-Alexander presumed that the transactions had a legitimate business purpose. JackAlexander accepted vague descriptions of the transactions as "for services provided," "consulting fees," or "commissions," and he approved the daily Anti-Money Laundering (AML) reports (required by law when transactions trigger red flags of potentially suspicious activity) without further investigation. Jack-Alexander's actions are (Choose the best answer.) (No answer given) appropriate because he is protecting the confidentiality of client information. inappropriate as it violates standard I(C). inappropriate as it violates standard I(A)
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