In the Goldman Sachs SAR case (2024), an RM identified a beneficial owner as a senior PEP from a sanctioned jurisdiction during quarter-end onboarding. What was the FCA-compliant first action?
SYSC 4.1 §3.2
A · Approve subject to standard CDD given quarter-end pressure
B ✓Escalate to the MLRO and pause onboarding pending Enhanced Due Diligence
C · Defer the relationship to the next quarter
Edit
Regenerate again
✓ Approve