d. Mr. Braccio an Italian citizen is a computer technician. He has an IT company in the Democratic Republic of the Congo . This company has contracts with the Congolese government. He lives in DRC. He pays taxes in this country. He is not a tax resident in Italy, but a tax resident in DRC. He has a non-resident account in an Italian bank. In his banking records "
Weekly purchases in Italy, paid with his personal debit card.
International transfers. His Italian bank account receives almost 30.000 euros every month from his bank in DRC
Is a bank obliged to keep a ten-year record of a client’s transactions? Besides this, are you obliged to perform a parallel investigation (for banking purposes), to verify if this client has suspicious activity in his banking records? Which due diligence measures would you perform? Do you think the activities of the client are risky? Should Mr. Braccio be considered a high-risk client?
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