ISO 27001:2022 – Information Security Management System Lead Auditor Quiz 09 24Mar25 - Practice Quiz

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Question 1 of 30

A portfolio manager, Anya Sharma, at a CIRO dealer member firm, receives a specific instruction from a high-net-worth client, Mr. Dubois, to invest a significant portion of his portfolio in a newly issued corporate bond from a company operating in a jurisdiction with weak anti-money laundering (AML) controls. Anya\'s internal compliance systems flag the investment as potentially problematic due to the heightened risk of illicit funds being involved. Mr. Dubois insists that the investment is crucial for his diversification strategy and threatens to move his assets to another firm if Anya refuses. Considering Anya\'s obligations under NI 31-103, CIRO regulations, and her fiduciary duty to Mr. Dubois, what is the MOST appropriate course of action for Anya to take?

Thoroughly document the potential AML risks, explain the concerns to Mr. Dubois, refuse to execute the trade as instructed, and explore alternative investment options that align with both his diversification goals and regulatory requirements.

Execute the trade as instructed by Mr. Dubois, ensuring that all internal documentation reflects his explicit direction, thereby shifting the responsibility for any potential AML violations to the client.

Immediately seek legal counsel to determine the firm's legal obligations and await their advice before taking any further action, thereby delaying the investment decision until a legal opinion is obtained.

Execute a small portion of the trade to appease Mr. Dubois while simultaneously reporting the suspicious activity to the firm's compliance department and the relevant regulatory authorities, thereby balancing client relations with regulatory obligations.

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