Role Simulation 1

The Complex Onboarding

Client onboarding with multiple red flags

Simulation Scenario

Situation: You are an insurance broker at an established firm. A prospect arrives, Mr. Joaquin Bermudez, a businessman in the construction sector, interested in acquiring an insurance package that includes:

  • Universal life policy with investment: DOP 25,000,000
  • Business liability insurance: DOP 50,000,000
  • Key executive life policy: DOP 15,000,000

Mr. Bermudez arrives accompanied by his accountant and a lawyer. During the initial meeting:

  • Mr. Bermudez wants to pay the first year's premiums in cash "to expedite things"
  • His company was established only 18 months ago but already bills DOP 200 million annually
  • The main contracts are with government entities
  • The lawyer frequently intervenes to answer questions directed at the client
  • There is urgency to close before the end of the month "for tax reasons"

Your boss, the brokerage manager, is excited about the account and is pressuring you to close quickly.

Simulation Instructions

  1. Each participant assumes one of the assigned roles
  2. The simulation takes place in a 30-minute meeting
  3. The broker must conduct the onboarding meeting
  4. Other participants act according to their roles and hidden objectives
  5. At the end, the group analyzes the decisions made

Simulation Roles

Insurance Broker (Protagonist)

Objective: Conduct proper onboarding complying with DD regulations

  • Must collect complete KYC information
  • Identify and document red flags
  • Balance commercial pressure with compliance
  • Decide whether to proceed, reject, or escalate
Mr. Joaquin Bermudez (Client)

Hidden objective: Obtain the policies quickly while avoiding too much scrutiny

  • Be friendly but evasive about details
  • Use time pressure as a tactic
  • Mention important connections
  • Delegate technical answers to the lawyer
Client's Lawyer

Hidden objective: Protect the client's confidentiality

  • Intervene when questions become too detailed
  • Cite "professional confidentiality"
  • Offer "comfort letters" as an alternative
  • Question the need for certain documentation
Client's Accountant

Hidden objective: Facilitate the operation, has interest in the commission

  • Validate the client's figures
  • Minimize concerns about the cash
  • Offer "summarized" documentation
  • Subtly pressure the broker
Brokerage Manager (Supervisor)

Objective: Close the account, meet monthly targets

  • May intervene by phone or message
  • Push for quick progress
  • Question "excessive paperwork"
  • Mention the competition
Compliance Officer (Consultation)

Objective: Advise on regulatory requirements

  • Available only if the broker consults
  • Provide guidance on required DD
  • Identify alerts in the information
  • Recommend escalation if necessary

Context Analysis

Analysis Activities
  1. Identify external and internal factors influencing this onboarding situation.
  2. Identify the causes of the red flags present.
  3. Identify the consequences of onboarding or not onboarding the client.
  4. Identify the constraints - regulatory, commercial, and practical.
  5. Identify the applicable legal framework: Law 155-17, Decree 408-17, UAF Guide 2026.
  6. Create a Concept Map connecting all identified elements.
  7. Create an Ishikawa Diagram for the causes of the red flags.

Factors to Consider

External Factors
  • Current AML/CFT regulatory framework
  • UAF and Superintendency oversight
  • Construction sector as high risk
  • Government contracts and corruption
Internal Factors
  • Commercial pressure from the manager
  • Pending sales targets
  • Internal DD policies
  • Organizational culture

Relevant Regulatory Framework

  • Law 155-17: Obligations of the obligated subject
  • Decree 408-17: Identification and verification requirements
  • UAF Guide 2026: Enhanced DD for high-risk clients
  • Reporting thresholds: Cash transactions > DOP 500,000

Stakeholder Analysis

Analysis Activities
  1. Identify direct and indirect stakeholders in the situation.
  2. Identify the roles of each stakeholder.
  3. Identify the relationships between stakeholders.
  4. Identify perspectives, interests, and priorities of each stakeholder.
  5. Create a Concept Map of stakeholders.
  6. Create a Relationship Map between stakeholders.

Stakeholder Matrix

Stakeholder Main Interest Power Position
Broker Compliance + Commission High (decision) Neutral
Mr. Bermudez Get policies quickly High (client) Pushing for speed
Lawyer Protect the client Medium (influence) Obstructs DD
Manager Close the sale High (hierarchical) Pushing for closure
Compliance Meet regulations High (veto) Requires complete DD

Practical Analysis

Analysis Activities
  1. Identify the components of the onboarding process.
  2. Identify relevant processes: KYC, verification, approval.
  3. Identify challenges, problems, opportunities, and threats.
  4. Create a Mind Map with the identified elements.
  5. Create a Priority/Impact Quadrant.

Identified Red Flags

Critical Alerts
  • Large cash payment
  • Very new company with high billing
  • Government contracts (corruption risk)
  • Evasion of direct questions
Moderate Alerts
  • Unjustified urgency
  • Excessive lawyer intervention
  • Vague tax reason
  • Internal manager pressure

Priority and Impact Quadrant

High Priority / High Impact
  • Document source of funds
  • Verify public contracts
  • Apply Enhanced DD
High Priority / Low Impact
  • Verify basic identity
  • Confirm company data
Low Priority / High Impact
  • Investigate the lawyer
  • Verify accountant
Low Priority / Low Impact
  • Confirm addresses
  • Verify phone numbers

Critical Analysis and Prioritization

Critical Analysis Questions
  1. Which problem is most critical to address first? Justify your answer.
  2. How would you prioritize the identified problems?
  3. What are the implications of not resolving the incomplete DD issue?
  4. What criteria would you use to evaluate priorities?

Prioritization Criteria

  • Regulatory risk: Sanctions for DD non-compliance
  • Reputational risk: Association with problematic client
  • Operational risk: Personal liability of the broker
  • Commercial impact: Loss of client vs loss of license

Implications of Not Acting

Consequences of Incomplete DD
  • Violation of Law 155-17: fines up to DOP 25,000,000
  • Possible complicity in money laundering
  • Suspension of broker license
  • Personal criminal liability
  • Reputational damage to the brokerage

Decision Making

Decision Making Questions
  1. What has been tried before with success in similar situations?
  2. What decision and action options can you consider?
  3. Evaluate the advantages and disadvantages of each option.
  4. Identify constraints and implications of each option.

Decision Options

Option Advantages Disadvantages
A) Proceed with Enhanced DD Meets regulations, protects the broker May lose the client, tension with manager
B) Reject the client Completely eliminates risk Certain loss of business
C) Escalate to Compliance Shares responsibility, gets guidance Takes more time, possible rejection
D) Accept with minimal DD Closes sale quickly High regulatory and personal risk

Define Your Decisions

Exercise: Decision Definition
  1. Suggest at least two alternative decisions to make.
  2. Explain your reasoning for each decision.
  3. Describe the constraints and resources needed.
  4. Describe the implications and expected results.
  5. Describe how you would communicate each decision to the team.
  6. Describe how you would communicate each decision to the client.

Execution and Planning

Planning Activities
  1. Design an action plan with phases and deadlines for onboarding.
  2. What resources would you need to implement your plan?
  3. Identify possible obstacles and how you would address them.

Suggested Action Plan

Phase Actions Deadline
1. Communication Inform the client about DD requirements Immediate
2. Collection Request complete documentation 5 days
3. Verification Validate information, check lists 3 days
4. Escalation Present to Compliance for approval 2 days
5. Decision Communicate result to client 1 day

Required Resources

  • Access to verification databases (restrictive lists, PEPs)
  • Enhanced DD forms
  • Support from the Compliance area
  • Time for investigation (without immediate closure pressure)

Results Evaluation

Evaluation Questions
  1. How would you measure the success of the decisions made?
  2. What metrics would you use to evaluate the results?
  3. What metrics would you use to evaluate the impact?
  4. If the decisions don't work, what alternatives would you consider?

Success Metrics

Outcome Indicators
  • DD completed 100% according to regulations
  • Complete documentation in the file
  • Compliance approval obtained
  • Client onboarded or rejected with grounds
Impact Indicators
  • Zero observations in audits
  • Protection of professional license
  • Broker's reputation intact
  • Trust relationship with Compliance

Dynamics Between Stakeholders

Dynamics Questions
  1. What communication skills are essential in this situation?
  2. What conflicts exist between stakeholder interests?
  3. How would you address these conflicts?

Identified Conflicts of Interest

  • Broker vs Manager: Compliance vs sales targets
  • Broker vs Client: Complete DD vs speed
  • Manager vs Compliance: Closure vs approval
  • Client vs Regulator: Privacy vs transparency

Key Communication Skills

  • Assertiveness: Maintain position under pressure
  • Diplomacy: Communicate requirements without offending
  • Active listening: Identify signals in responses
  • Negotiation: Find solutions that satisfy everyone

Creativity and Innovative Solutions

Creative Exercise
  1. Propose an innovative approach to the onboarding process.
  2. What technology or disruptive approach would you apply?
  3. How would you involve stakeholders in this new approach?

Innovative Ideas

Technology
  • Automated digital document verification
  • Real-time restrictive list checks
  • Automatic risk scoring
  • Blockchain for document traceability
Process
  • Digital pre-screening before in-person meeting
  • Interactive DD checklist
  • Automatic escalation by alerts
  • Real-time tracking dashboard

Ethical and Social Impact

Ethical Questions
  1. What ethical implications do the proposed decisions have?
  2. What ethical implications does NOT making decisions have?
  3. What considerations ensure that decisions are ethical and fair?

Ethical Dimensions

  • Integrity: Not yielding to improper commercial pressure
  • Responsibility: Protecting the financial system
  • Justice: Applying the same standards to all clients
  • Transparency: Clearly communicating requirements

Alternative Scenario

Change of conditions: Imagine that Mr. Bermudez turns out to be the nephew of a high-ranking current government official, making him a PEP by association.

  • How does this change impact the case?
  • What additional considerations would you take?
  • What additional decisions and actions would you implement?

Metacognition and Personal Reflection

Reflection Questions
  1. What knowledge, skills, and competencies did you put into practice?
  2. What did you learn in this simulation?
  3. How are your responses different from what you would have given before this program?
  4. How will you apply what you learned in your professional life?

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Role Simulation 2

The Manager's Dilemma

When commercial targets clash with regulatory compliance

Simulation Scenario

You are the Manager of a medium-sized insurance brokerage. It's the last day of the quarter and you're DOP 3,000,000 short of meeting the target.

Your best broker, Luis Martinez, has a client ready to close a life insurance policy with investment for DOP 10,000,000. However, the Compliance department has put the transaction "under review" for the following reasons:

  • The client owns a chain of currency exchange houses
  • Wants to pay the premium with a transfer from an account in Panama
  • Source of funds verification is incomplete
  • The client has a relative who was a PEP 2 years ago

The CEO calls you to ask about the target. Luis is pressuring you to "talk to Compliance." The Compliance Officer stands firm on their objections.

You have a meeting in 30 minutes where you must decide the course of action.

Simulation Roles

Brokerage Manager (Protagonist)

Objective: Make a decision that balances business and compliance

  • Accountable to management for targets
  • Accountable to the regulator for compliance
  • Must manage everyone's expectations
Luis Martinez (Broker)

Objective: Close the sale, get his commission

  • Argues that the client is legitimate
  • Pushes for an exception or fast approval
  • Subtly threatens to move to another brokerage
Compliance Officer

Objective: Protect the company from regulatory risks

  • Stands firm on requirements
  • Cites regulations and precedents
  • Offers alternatives within the framework
CEO

Objective: Quarterly financial results

  • Asks for solutions, not problems
  • Reminds of shareholder commitments
  • May moderate position if risks are explained

Complete Analysis

Context Analysis Activities

  1. Identify the external and internal factors creating this dilemma.
  2. Identify the causes of tension between areas.
  3. Identify the consequences of prioritizing one position or the other.
  4. Create an Ishikawa Diagram for the causes of the conflict.

Stakeholder Analysis Activities

  1. Map the interests of each involved stakeholder.
  2. Identify where there is alignment and where there is conflict.
  3. Which perspective should prevail and why?

Practical Analysis Activities

  1. Which problem is most critical to address first?
  2. What are the implications of yielding to commercial pressure?
  3. What are the implications of missing the quarterly target?

Decision Quadrant

High Risk / High Benefit
  • Approve without complete DD
  • Meets target, high regulatory risk
High Risk / Low Benefit
  • Partial approval
  • Doesn't meet target, risk present
Low Risk / High Benefit
  • Accelerated but complete DD
  • If possible in time
Low Risk / Low Benefit
  • Reject operation
  • Lose target, protect company

Decision Making

Decision Exercise
  1. Define at least two alternative courses of action.
  2. Evaluate advantages and disadvantages of each.
  3. How would you communicate your decision to the CEO?
  4. How would you communicate your decision to Luis?
  5. How would you communicate your decision to Compliance?

Decision Options

Option Commercial Implication Regulatory Implication
Support Compliance Lose target, potentially lose broker Protect license, no observations
Seek intermediate solution Possible closure with delay Depends on DD quality
Push for exception Meet target immediately High risk, possible future sanction

Execution Plan

  1. Design an action plan for the next 30 minutes.
  2. What resources do you need?
  3. What obstacles do you anticipate?

Reflection and Learning

Alternative Scenario

Change: Imagine the policy is for DOP 50,000,000 and would represent 50% of the brokerage's annual target.

  • Does your analysis change?
  • Does your decision change?
  • Should it change?
Personal Reflection
  1. What did you learn about the balance between business and compliance?
  2. How would you handle pressure from a superior?
  3. What skills do you need to develop for these situations?

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Role Simulation 3

Extraordinary Compliance Committee

Collective evaluation of a complex Enhanced DD case

Simulation Scenario

An Extraordinary Compliance Committee has been convened to evaluate the onboarding of a high-profile client:

Eastern Business Group SAS wants to contract a comprehensive insurance program for DOP 200,000,000 that includes executive life insurance, business liability, and property insurance.

DD Findings:

  • The group's president is the son of a former Senator (PEP by association)
  • The company has operations in free trade zones with multiple countries
  • 30% of revenue comes from government contracts
  • There is a journalistic investigation linking a minor partner to tax havens
  • Financial statements show 500% growth in 3 years
  • Declared source of funds is "profit reinvestment"

The committee must decide: approve, reject, or approve with conditions.

Committee Roles

Committee Chair

Moderates discussion, seeks consensus, has casting vote

Compliance Officer

Presents the case, identifies risks, recommends additional DD

Commercial Director

Defends the business opportunity, proposes mitigants

Legal Advisor

Evaluates legal risks, opines on exposure

Risk Director

Evaluates comprehensive risk, proposes controls

Audit Representative

Observes the process, verifies policy compliance

Simulation Dynamics

  1. The Compliance Officer presents the case (10 min)
  2. Each member expresses their initial position (15 min)
  3. Open debate on the decision (20 min)
  4. Voting and documentation of the decision (10 min)

Case Analysis

Pre-Committee Activities
  1. Identify all the red flags in the case.
  2. Classify alerts by risk level.
  3. Identify what additional DD is required.
  4. Prepare arguments for your position according to your role.

Risk Matrix

Critical Risks
  • PEP status of the president
  • Pending journalistic investigation
  • Atypical growth (500%)
Moderate Risks
  • Government contracts
  • International operations
  • Generic source of funds

Key Questions for the Committee

  • Does the reputational risk outweigh the commercial benefit?
  • Is it possible to mitigate risks with additional controls?
  • What precedent does this decision establish?
  • How would the regulator react if they reviewed this case?

Collective Decision Making

Decision Options

Option Conditions Implications
Approve Current DD is sufficient Assumed risk, commercial benefit
Approve with conditions Additional DD, enhanced monitoring, limits Risk-benefit balance
Defer Complete DD before deciding Delay, possible account loss
Reject Unacceptable risk Loss of business, total protection
Voting Exercise
  1. Each role presents their vote and justification.
  2. The decision is documented with grounds.
  3. Conditions are established if applicable.
  4. Those responsible for follow-up are assigned.

Post-Committee Reflection

Dynamics Analysis
  1. What communication skills were critical?
  2. How were conflicts of interest managed?
  3. Was the decision by consensus or by vote?
  4. What would you improve in the process?

Alternative Scenario

Change: After the meeting, a newspaper publishes that the investigation into the partner revealed links to drug trafficking.

  • How does this impact the decision made?
  • What immediate actions would the committee take?

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Role Simulation 4

Regulator Visit

UAF inspection of Due Diligence processes

Simulation Scenario

The UAF has notified a routine inspection of your insurance brokerage. During the visit, inspectors request:

  • Files of the last 20 onboarded clients
  • DD policies and procedures
  • Evidence of staff training
  • Record of SARs filed (if any)
  • Compliance committee minutes

When reviewing the files, inspectors identify findings:

  • 3 files have incomplete DD
  • 1 PEP client was not identified as such
  • 2 cash transactions >DOP 500,000 without CTR
  • The DD manual is not updated to the 2026 Guide

The lead inspector requests a meeting with management to discuss the findings.

Simulation Roles

UAF Lead Inspector

Conducts the inspection, identifies findings, may recommend sanctions

Assistant Inspector

Reviews documents, takes notes, asks technical questions

Brokerage General Manager

Responds for the organization, seeks to minimize impact

Compliance Officer

Explains processes, presents evidence, proposes remediation

Legal Advisor

Protects legal interests, negotiates deadlines

Situation Analysis

Preparation for the Meeting
  1. Classify findings by severity.
  2. Identify the causes of each finding.
  3. Prepare explanations (not excuses) for each one.
  4. Design a credible remediation plan.

Findings Classification

Serious Findings
  • Unidentified PEP - Law 155-17 violation
  • CTRs not sent - Reporting non-compliance
Moderate Findings
  • Incomplete DD - Process deficiency
  • Outdated manual - Control weakness

Possible Sanctions

  • Observations: Deadline to correct
  • Warning: Record in file
  • Fines: Up to DOP 25,000,000 depending on severity
  • Suspension: Of activities in extreme cases

Response Strategy

Response Exercise
  1. How would you explain each finding without justifying?
  2. What remediation plan would you present?
  3. What deadlines would you propose for each action?
  4. How would you demonstrate commitment to compliance?

Suggested Remediation Plan

Finding Corrective Action Deadline
Unidentified PEP Immediate review, reclassification, Enhanced DD 15 days
Pending CTRs Immediate submission of delayed CTRs 48 hours
Incomplete DD Complete files, training 30 days
Outdated manual Update to UAF 2026 Guide 60 days

Reflection and Learning

Reflection Questions
  1. What errors led to these findings?
  2. How could they have been prevented?
  3. What structural changes would you implement?
  4. How would you prepare your team for future inspections?

Alternative Scenario

Change: The inspector mentions that they have information from a SAR from another institution involving one of your current clients.

  • How would you react?
  • What information could you share?
  • What immediate actions would you take with that client?

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Role Simulation 5

Reputational Crisis

Managing a public scandal related to a client

Simulation Scenario

It's Monday morning. A national newspaper publishes on the front page:

"BUSINESSMAN ARRESTED FOR MONEY LAUNDERING - Had multi-million dollar policies with local insurers"

The article mentions that your brokerage intermediated a DOP 40,000,000 policy for the arrested businessman, Mr. Rafael Medina, 2 years ago.

Current situation:

  • The UAF calls requesting urgent information
  • A journalist requests statements
  • Other clients call concerned
  • The team is nervous and confused
  • The insurer asks about their exposure

You have 2 hours to organize a response before the authorities' press conference.

Simulation Roles

General Manager

Coordinates the response, makes executive decisions, spokesperson

Compliance Officer

Reviews client file, prepares information for UAF

Legal Advisor

Evaluates legal exposure, prepares communications

Commercial Director

Manages client communication, protects relationships

Communications

Prepares press release, handles media, monitors social media

Crisis Analysis

Immediate Actions (First Hour)
  1. Locate and review the client's file.
  2. Verify what DD was done at the time.
  3. Identify if there were unaddressed red flags.
  4. Prepare a timeline of the business relationship.

Critical Questions

  • Was the DD conducted adequate according to regulations in effect at that time?
  • Were there red flags that should have been escalated?
  • Was any SAR sent related to this client?
  • What is the brokerage's legal exposure?

Stakeholders to Manage

Immediate Priority
  • UAF - Mandatory response
  • Insurer - Coordination
High Priority
  • Media - Narrative control
  • Clients - Reassure
Medium Priority
  • Employees - Internal communication
  • Suppliers - Basic information

Response Plan

Planning Exercise
  1. Design a press release (3 paragraphs max).
  2. Prepare key points to respond to the UAF.
  3. Draft a message for concerned clients.
  4. Prepare talking points for employees.

Press Release Elements

  • Acknowledgment: We are aware of the situation
  • Cooperation: We are collaborating with authorities
  • Process: We have robust DD processes
  • Confidentiality: We cannot comment on specific clients
  • Commitment: We maintain our commitment to prevention

What NOT to Say

Mistakes to Avoid
  • Don't blame the client before there is a conviction
  • Don't reveal confidential DD information
  • Don't admit failures without legal advice
  • Don't speculate about other clients
  • Don't minimize the situation

Reflection and Learning

Post-Crisis Evaluation
  1. What worked well in the response?
  2. What could have been done better?
  3. What additional controls would you implement?
  4. How would you prepare the organization for future crises?

Alternative Scenario

Change: Upon reviewing the file, you discover that the broker who served Mr. Medina failed to document several red flags and did not escalate to Compliance.

  • How does this impact your response strategy?
  • What internal actions would you take?
  • How would you communicate this to the authorities?
Personal Reflection
  1. What competencies are critical for managing crises?
  2. How would you prepare a preventive crisis plan?
  3. What role would you like to play in a real crisis?

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