Ch 6 from the other guy

Question 1

QUESTION 1 Which of the following is the most common method of laundering money through a legal money services business? A. Purchasing structured money instruments. B. Smuggling bulk-cash. C. Transferring funds through Payable Through Accounts (PTAs). D. Exchanging Colombian pesos on the black market.

Answer 1

A. Purchasing structured money instruments.

Question 2

QUESTION 2 In general, the three phases of money laundering are said to be: Placement: A. Structuring and manipulation. B. Layering and integration. C. Layering and smurfing. D. Integration and infiltration.

Answer 2

B. Layering and integration.

Question 3

QUESTION 3 Which statement is true? A. Bust-out schemes are popular in creating large bankruptcy frauds where businesses secure increasing loans in excess of the actual value of the company or property and then run with the money, leaving the lender to foreclose and take a substantial loss. B. Cuckoo smurfing is a significant money laundering technique identified by the Financial Action Task Force, where a form of structuring uses nested accounts with shell banks in secrecy havens. C. In its 40 Recommendations, the FATF issued a list of “designated categories of offense” that asserts crimes for a money laundering prosecution. D. E-cash is not attractive to the money launderer because it cannot be completely anonymous and does not allow for large amounts to be “transported” quickly and easily.

Answer 3

A. Bust-out schemes are popular in creating large bankruptcy frauds where businesses secure increasing loans in excess of the actual value of the company or property and then run with the money, leaving the lender to foreclose and take a substantial loss.

Question 4

QUESTION 4 Which three of the following is an indication of possible money laundering in an insurance industry scenario? A. Insurance products sold through intermediaries, agents or brokers. B. Single-premium insurance bonds, redeemed at a discount. C. Policyholders who are unconcerned about penalties for early cancellation. D. Policyholders who redeem the policy within the “free look” period

Answer 4

B. Single-premium insurance bonds, redeemed at a discount. C. Policyholders who are unconcerned about penalties for early cancellation. D. Policyholders who redeem the policy within the “free look” period.

Question 5

QUESTION 5 Which two activities are typically associated with the black market peso exchange (BMPE) money laundering system? A. Converting illicit drug proceeds from dollars or Euros to Colombian pesos. B. Converting illicit drug proceeds from Colombian pesos to dollars or Euros. C. Facilitating purchases by Colombian importers of goods manufactured in the United States or Europe through peso brokers. D. Facilitating purchases by European or U.S. importers of goods manufactured in Colombia through peso brokers.

Answer 5

A. Converting illicit drug proceeds from dollars or Euros to Colombian pesos. C. Facilitating purchases by Colombian importers of goods manufactured in the United States or Europe through peso brokers.

Question 6

QUESTION 6 What is the Right of Reciprocity in the field of international cooperation against money laundering? A. The legal principle that financial institutions that have referred customers to other financial institutions can share information about these customers with the other institutions. B. A rule of the Basel Committee allowing properly regulated financial institutes of another member state of the Basel Committee to do business without additional supervision to the degree that the other state grants the same right. C. The right of each FATF member country to delegate prosecution of a case of money laundering to another member that is already investigating the same case. D. A rule in the law of a country allowing its authorities to cooperate with authorities of other countries to the degree that their law allows them to do the same

Answer 6

D. A rule in the law of a country allowing its authorities to cooperate with authorities of other countries to the degree that their law allows them to do the same

Question 7

QUESTION 7 The greatest risk for money laundering is for casinos that A. Provide their customers with a wide array of gambling services. B. Operate in a non-Egmont member country. C. Allow customers with credit balances to withdraw funds by check in another jurisdiction. D. Only send suspicious transaction reports to the financial intelligence unit of the country it operates in.

Answer 7

C. Allow customers with credit balances to withdraw funds by check in another jurisdiction.

Question 8

QUESTION 8 Which statement is true regarding the risk of Politically Exposed Persons (PEPs)? A. PEPs provide access to third parties on whom the financial institution has not conducted sufficient due diligence. B. PEPs have significantly greater exposure to the politically corrupt funds, including accepting bribes or misappropriating government funds. C. PEPs are foreign customers who inherently present additional risk as they are engaged in crossborder transactions. D. PEPs generally do not pose enhanced risks to an institution due to their political standing; rather, PEPs increase the prestige of an institution.

Answer 8

B. PEPs have significantly greater exposure to the politically corrupt funds, including accepting bribes or misappropriating government funds.

Question 9

QUESTION 9 In 2014 the Wolfsberg Group published their Anti-Money Laundering Principles for Correspondent Banking. Which three of the following elements are recommended to be included in the due diligence of a Correspondent Banking client? A. The geographic risk. B. The ownership and management structure C. The resume of the Compliance Officer D. The customer base.

Answer 9

A. The geographic risk. B. The ownership and management structure D. The customer base.

Question 10

QUESTION 10 A new customer approaches a bank to open a commercial account. The customer provides an address for the account located across the city from the branch. When asked by the account representative if the customer requires any additional banking services, the customer responds she is also interested in opening a personal investment account. The account representative refers the customer to their brokerdealer. The customer tells the firm representative she has never had a brokerage account before and has a few questions about how an investment account works. The customer asks how deposits can be made into her account, if there are any reporting requirements, and how to go about moving balances out of the account using wire transfers. No questions are asked about fees associated with these transactions. Which three items would be considered suspicious? A. The customer asks many questions about the brokerage account, but none of them are related to investing. B. The customer is opening a commercial account and at the same time a personal investment account. C. The address of the account holder and the branch where the customer came to open the account are not close to each other. D. That the customer appears unconcerned about the fees.

Answer 10

A. The customer asks many questions about the brokerage account, but none of them are related to investing. C. The address of the account holder and the branch where the customer came to open the account are not close to each other. D. That the customer appears unconcerned about the fees.

Question 11

QUESTION 11 Trade Based Money Laundering requires the ability to: A. Over- or under-invoice the goods. B. Sell the imported goods for as little as possible. C. Use goods that do not need to be declared. D. Avoid the use of high-value assets such as luxury cars or boats.

Answer 11

A. Over- or under-invoice the goods.

Question 12

QUESTION 12 Which of the following statements is true? Correspondent banking is MOST vulnerable to money laundering when the correspondent account is: A. Maintained for foreign financial institutions that are banks. B. Not used to provide services directly to third parties. C. Maintained for a foreign bank that does not have a physical presence in any country. D. Maintained for a foreign private bank that is publicly traded and is a qualified intermediary.

Answer 12

C. Maintained for a foreign bank that does not have a physical presence in any country.

Question 13

QUESTION 13 Which statement is true? Lawyers: A. In FATF member countries can generally not be used to serve as formation agents to set up trusts, front companies or shell companies. B. And similar professional “gatekeepers” are called money services businesses. C. Can generally not be used to act as a nominee shareholder for a beneficial owner. D. Can be abused by launderers by using the accounts they set up for them for the placement and layering of funds.

Answer 13

D. Can be abused by launderers by using the accounts they set up for them for the placement and layering of funds

Question 14

QUESTION 14 Which three of the following statements are true in respect of the Fourth EU Anti-Money Laundering Directive? A. Member countries can decide when and if the incorporate it into their own local laws. B. It repeals and replaces the Third EU Directive on Anti- Money Laundering. C. The beneficial owner is defined as having a minimum of 25% direct or indirect ownership of the company. D. The definition of a PEP is expanded to include domestic persons.

Answer 14

B. It repeals and replaces the Third EU Directive on Anti- Money Laundering. C. The beneficial owner is defined as having a minimum of 25% direct or indirect ownership of the company. D. The definition of a PEP is expanded to include domestic persons.

Question 15

QUESTION 15 According to the EU Directives an independent legal professional is obligated to report suspicion of money laundering in a client relationship when: A. Representing a client in a legal matter. B. Ascertaining the legal position for a client. C. Participating in financial or corporate transactions. D. Obtaining information associated with a judicial proceeding.

Answer 15

C. Participating in financial or corporate transactions.

Question 16

QUESTION 16 Which of the following is the most difficult regulatory challenge facing a foreign financial institution with a correspondent banking relationship in the U.S.? A. USA Patriot Act. B. Basel Due Diligence Principles for Banks. C. FATF Guidance on Terrorist Financing. D. UN Security Council Resolution on Correspondent Banking.

Answer 16

A. USA Patriot Act.

Question 17

QUESTION 17 Which were the Basel Committee’s two main motivations to encourage strong Know Your Customer programs in its paper “Customer Due Diligence for Banks”? A. Mirror FATF’s KYC Recommendations. B. Meet European Union guidelines. C. Protect the safety and soundness of banks. D. Protect the integrity of banking systems.

Answer 17

C. Protect the safety and soundness of banks. D. Protect the integrity of banking systems.

Question 18

QUESTION 18 What is the definition of a predicate offense? A. Lawful or unlawful activity that involves willful blindness, and if there is an international element to the crime, can lead to a suspicious activity report. B. Unlawful activity whose proceeds, if involved in the transaction, can give rise to prosecution for the crime of money laundering. C. An interface which is the underlying segment of a suspicious transaction monitoring system. D. A specified unlawful activity that is committed through concentration accounts deceiving customers that are not directly related to the account.

Answer 18

B. Unlawful activity whose proceeds, if involved in the transaction, can give rise to prosecution for the crime of money laundering.

Question 19

QUESTION 19 What is considered a beneficial owner of an account? A person or entity: A. That has direct signatory authority over an account, and whose name appears on the account. B. That is ultimately entitled to the funds in the account, even though his name may not appear on the account. C. That is the originator and the destination of most (but not all) transactions conducted within the account, but who does not ultimately control such funds. D. That is a gatekeeper, has the legal title to the account, and typically transfers the funds to a trust.

Answer 19

B. That is ultimately entitled to the funds in the account, even though his name may not appear on the account.

Question 20

QUESTION 20 The FinCen “Advisory to US Financial Institutions on Promoting a Culture of Compliance”, published in 2014, listed six areas of emphasis. Which three areas below are included in that list: A. Leadership Should Be Engaged. B. Information Should Be Shared Throughout the Organization. C. Leadership and Staff Should Understand How Their BSA Reports are Used. D. The Organization must have an Appropriately Qualified Compliance Officer.

Answer 20

A. Leadership Should Be Engaged. B. Information Should Be Shared Throughout the Organization. C. Leadership and Staff Should Understand How Their BSA Reports are Used.

Question 21

QUESTION 21 Which of the following should a national legislature consider when criminalizing money laundering in line with the CFATF 19 Recommendations (choose three)? A. Do not limit the number of specific predicate offenses for money laundering. B. Criminalize conspiracy or association to engage in money laundering. C. Indicate whether it is relevant that a predicate offense may have been committed outside the local jurisdiction. D. Require money laundering offenses to prove that the offender has actual knowledge of a criminal connection to the funds.

Answer 21

A. Do not limit the number of specific predicate offenses for money laundering. B. Criminalize conspiracy or association to engage in money laundering. C. Indicate whether it is relevant that a predicate offense may have been committed outside the local jurisdiction.

Question 22

QUESTION 22 Which three statements are true about the 4th EU Directive on Money Laundering? It: A. Updates European Community legislation to be further in line with the Financial Action Task Force (FATF) 40 Recommendations. B. Repeats the definition of a politically exposed person in previous Directives. C. Repeats the customer due diligence requirements of the previous Directives, but adds more detail to the requirements by, for example, including a specific requirement to identify the beneficial owner and includes ongoing monitoring requirements. D. Requires firms to apply the customer due diligence requirements to existing customers at appropriate times on a risk sensitive basis.

Answer 22

A. Updates European Community legislation to be further in line with the Financial Action Task Force (FATF) 40 Recommendations. C. Repeats the customer due diligence requirements of the previous Directives, but adds more detail to the requirements by, for example, including a specific requirement to identify the beneficial owner and includes ongoing monitoring requirements. D. Requires firms to apply the customer due diligence requirements to existing customers at appropriate times on a risk sensitive basis.

Question 23

QUESTION 23 Which one of the following statements is correct in respect of the FATF 40 Recommendations which state that countries should: A. Not allow bearer shares and legal persons that are able to issue bearer shares. B. Gather statistics on STRs; prosecutions and convictions; on property frozen, seized and confiscated; and on mutual legal assistance, but not necessarily on other international requests for co- operation. C. Consider the feasibility of a system where banks and other financial institutions and intermediaries would report currency transactions without indicating a minimum fixed amount. D. Not approve the establishment or accept the continued operation of shell banks

Answer 23

D. Not approve the establishment or accept the continued operation of shell banks.

Question 24

QUESTION 24 Among the Principles for Information Exchange Between Financial Intelligence Units for Money Laundering Cases, issued by the Egmont Group on June 13, 2001, we find which of the following? A. Information-sharing agreements must follow the model issued by the Egmont Group. B. Information which is shared under these agreements will be exempt from the local privacy laws of the countries involved. C. Information exchanged between FIUs may be used only for the specific purpose for which the information was sought or provided. D. The requesting FIU may make use of the information shared by a disclosing FIU for administrative purposes without the prior consent of the disclosing FIU

Answer 24

C. Information exchanged between FIUs may be used only for the specific purpose for which the information was sought or provided.

Question 25

QUESTION 25 In which stage of money laundering would you classify depositing small amounts of cash into several related accounts? A. Integration. B. Structuring. C. Placement. D. Construction.

Answer 25

C. Placement.

Question 26

QUESTION 26 In which stage of money laundering would you classify the use of laundered funds to purchase high value assets and luxury items? A. Integration. B. Structuring. C. Placement. D. Construction.

Answer 26

A. Integration

Question 27

QUESTION 27 In most laws criminalizing money laundering, it is stated that: A. Financial institutions are not responsible for money laundering or suspicious transactions taking place within their accounts until the government places the customer on a watch list. B. Informing customers that their accounts and/or transactions are the subject of an AML investigation is not punishable. C. The dirty money undergoing money laundering will not be confiscated because of privacy laws. D. It is required that the institution identifies the beneficial owner(s) of the account.

Answer 27

D. It is required that the institution identifies the beneficial owner(s) of the account.

Question 28

QUESTION 28 The tactic in which individuals make multiple deposits in small quantities to avoid detection is called: A. Paralleling. B. Integration. C. Investing. D. Structuring.

Answer 28

D. Structuring.

Question 29

QUESTION 29 In which case might a Suspicious Transaction Report NOT be necessary? A. A customer who deposits money of suspicious origins and refuses to answer questions from the financial institution’s staff. B. A customer who tries to move money that is suspected of being derived from criminal activity. C. A customer who owns a large supermarket and deposits large amounts of cash several times a day. D. A customer whose account is showing transaction activities which are beyond his known financial capability.

Answer 29

C. A customer who owns a large supermarket and deposits large amounts of cash several times a day.

Question 30

QUESTION 30 As part of their role in fighting money laundering, financial institutions should: A. Designate a compliance officer. B. Depend solely on The State’s staff for combating money laundering. C. Refuse small cash deposits under the reporting threshold. D. Not open accounts for people from high risk jurisdictions.

Answer 30

A. Designate a compliance officer

Question 31

QUESTION 31 A junior compliance analyst learns over lunch with a friend in the computer operations department that during the previous week there was a problem related to the data being transmitted to the transaction monitoring application. The friend states that since it was purely a technical computer system issue he was quietly proud that he was able to rectify it quickly himself during the early hours of the morning. What action should the analyst take? A. Congratulate his friend on his prompt action. B. Congratulate his friend and, as soon as possible, ensure that the Compliance Officer is aware of the situation. C. Nothing because the appropriate controls are in place for such events. D. Immediately report the situation to the regulators.

Answer 31

B. Congratulate his friend and, as soon as possible, ensure that the Compliance Officer is aware of the situation.

Question 32

QUESTION 32 What is willful blindness defined as? A. Failing to file a Suspicious Transaction Report for dealing with companies or financial institutions from offshore tax havens. B. Not following customer identification procedures as set out in the institution’s procedures. C. Deliberate avoidance of knowledge of the facts or ignoring obvious money laundering red flags. D. Deliberate avoidance of a customer based on the assumption that his or her behavior suggested a potential threat as money launderer and/or terrorist.

Answer 32

C. Deliberate avoidance of knowledge of the facts or ignoring obvious money laundering red flags.

Question 33

QUESTION 33 In anti-money laundering terminology a “red flag” is: A. A warning sign indicating potentially suspicious, risky transactions or activities. B. A general banking term used once the balance is negative / overdue. C. The standard flag of countries not cooperative in fighting money laundering and terrorist financing. D. An indicator that a customer is listed on an economic sanctions list.

Answer 33

A. A warning sign indicating potentially suspicious, risky transactions or activities.

Question 34

QUESTION 34 The AML Reporting Officer of a financial institution should: A. Report everything that comes his way from anyone in the organization. B. Report everything that comes his way from senior management or Board of Directors. C. Review all available information and file a Suspicious Transaction Report in respect of any unusual or potentially suspicious activity. D. Report only what the Reporting Officer’s superior agrees should be reported.

Answer 34

C. Review all available information and file a Suspicious Transaction Report in respect of any unusual or potentially suspicious activity.

Question 35

QUESTION 35 Which of the following statements is true? A. Credit cards are not likely to be used in the layering phase of money laundering because of restrictions in cash payments. B. Credit cards are effective instruments for laundering money because the transactions do not create an audit trail. C. A launderer can launder money by prepaying his credit card using funds that are already in the banking system, creating a credit balance on his account, and requesting a credit refund. D. A launderer can use illicit funds that are already in the banking system to pay his credit card bill for goods purchased, which is an example of placement

Answer 35

C. A launderer can launder money by prepaying his credit card using funds that are already in the banking system, creating a credit balance on his account, and requesting a credit refund.

Question 36

QUESTION 36 Why is a Payable Through Account vulnerable to money laundering? A. It can be very difficult to conduct due diligence on the foreign institution customers who are ultimately using these accounts. B. These are concentration accounts located in a domestic branch of a foreign bank. C. These are nested correspondent accounts at a foreign shell bank with customers with whom the domestic bank did not exercise due diligence. D. These are master escrow accounts on which a domestic bank generally does not conduct periodic verification.

Answer 36

A. It can be very difficult to conduct due diligence on the foreign institution customers who are ultimately using these accounts.

Question 37

QUESTION 37 What is the reasoning behind implementing a “risk-based anti-money laundering approach”? A. It will keep the regulators focused on money laundering controls in sectors beyond banks. B. Institutions can best use their limited resources to focus on matters where the money laundering risks are highest. C. A quantitative approach will generate better results than a qualitative approach. D. It allows the institution to focus on selling products that have a better return on investment.

Answer 37

B. Institutions can best use their limited resources to focus on matters where the money laundering risks are highest.

Question 38

QUESTION 38 According to the FATF 40 Recommendations, “designated non-financial businesses and professions” include: A. Casinos, real estate agents and dealers in precious stones. B. Money service businesses, gatekeepers, and issuers of electronic money. C. Dealers in precious metals, lawyers, commodity futures traders. D. Life insurance companies, real estate agents and notaries.

Answer 38

A. Casinos, real estate agents and dealers in precious stones.

Question 39

QUESTION 39 According to the FATF 40 Recommendations, the threshold for identifying occasional customers at financial institutions is: A. EURO/US$ 5,000. B. EURO/US$ 10,000. C. EURO/US$ 15,000. D. EURO/US$ 20,000.

Answer 39

C. EURO/US$ 15,000.

Question 40

QUESTION 40 Tom works as a compliance officer at ABC Bank. He is looking at the transactions of one of the bank’s customers, Mr. Brown, the owner of a check cashing company. Over the last six months, Mr. Brown has not made withdrawals of cash against check deposits. He also deposited two checks for US$2,000 each that were issued by a casino. When checking the KYC file, Tom sees that, when opening the account, Mr. Brown had requested detailed information about fees and commission that are charged by the bank. What should arouse Tom’s suspicion the most? Mr. Brown: A. Deposited checks from casinos. B. Did not make withdrawals of cash against check deposits. C. Showed uncommon curiosity about commissions and fees charged. D. Does not have an escrow account.

Answer 40

B. Did not make withdrawals of cash against check deposits.

Question 41

QUESTION 41 A small broker-dealer has an AML compliance program that addresses procedures for filing Suspicious Transaction Reports and includes policies, procedures and internal controls for customer identification, monitoring accounts and identifying money laundering red flags. Every employee of the broker dealer is trained via the Internet in January and in July on AML issues. The board does not take the Internet training. Instead, the compliance officer organizes a luncheon for them where an outsider comes in and trains them. The program provides for the appointment of a compliance officer, and once a year the compliance officer conducts an audit to test the program. In what respect does the program need improvement? A. The AML program should be tested by an independent person, not the compliance officer. B. The AML program should be tested more than once per year. C. The board should receive the same training provided to the employees. D. Employees should not be trained via the Internet, because classroom training is better.

Answer 41

A. The AML program should be tested by an independent person, not the compliance officer.

Question 42

QUESTION 42 Susan works as a senior Money Laundering Reporting Officer at XYZ Bank. She is taking a closer look at the activity of several customers. What would arouse her suspicion the MOST? A. A customer who owns several check cashing companies in town and rents safe deposit boxes at different branches. B. A customer who avoids taking vacations. C. A small business that provides financial statements which are not prepared by an accountant. D. A customer involved in investment management who guarantees a very high rate of return, well above what other competitors can offer.

Answer 42

D. A customer involved in investment management who guarantees a very high rate of return, well above what other competitors can offer.

Question 43

QUESTION 43 Which of the following best describes the “alternative remittance system”? A. The transfer of values between countries, outside of the legitimate banking system. B. A non-electronic data remittance system used in several foreign countries to report suspicious activities. C. Old-fashioned reporting requirements commonly used in non-cooperative countries and territories. D. The transfer of funds between two or more financial institutions using concentration accounts.

Answer 43

A. The transfer of values between countries, outside of the legitimate banking system.

Question 44

QUESTION 44 An AML compliance officer was reviewing customers at XYZ Bank and one of the customers (Mr. Sam Tropicana) attracted her attention. Through a period of several months, cash deposits and withdrawals were transacted through his account with amounts ranging between US $7,500 and US $17,000. In addition, Sam deposited two checks, issued by a casino into his account for US $32,000 each. When opening the account, Sam stated that he operated an import/export company. Which of the following additional items should arouse the suspicion of an anti-money laundering compliance officer the most? A. Sam maintained a personal account as well as the business account. B. Sam’s home telephone number was disconnected last month. C. Sam asked for a letter of credit to finance some imports from a new supplier. D. Sam conducted large cash transactions for his import/ export business.

Answer 44

D. Sam conducted large cash transactions for his import/ export business.

Question 45

QUESTION 45 Which three of the following statements are true? A. Online gambling provides an excellent method of laundering because transactions are conducted primarily through credit or debit cards and the sites are typically unregulated offshore firms. B. An institution can know when a credit card is used for online gambling transactions because the cards rely on codes that illustrate the type of transactions. C Online gambling provides an excellent method of laundering because it lends itself to any type of cash movement and there is no face-to-face contact with the customer. D. Some banks no longer allow the use of credit cards for online gambling transactions.

Answer 45

A. Online gambling provides an excellent method of laundering because transactions are conducted primarily through credit or debit cards and the sites are typically unregulated offshore firms. B. An institution can know when a credit card is used for online gambling transactions because the cards rely on codes that illustrate the type of transactions. D. Some banks no longer allow the use of credit cards for online gambling transactions.

Question 46

QUESTION 46 Which one of the following statements is true? A. The Egmont Group membership comprises national FIUs. B. The Wolfsberg Group membership comprises central bank governors of the G10. C. The European Union recommends legistation to be passed in the member countries. D. The Basel Committee levies fines on the member countries for non-compliance with AML laws

Answer 46

A. The Egmont Group membership comprises national FIUs.

Question 47

QUESTION 47 Which three of the following statements are included in Section 313 of the PATRIOT Act definition of “Physical Presence” in respect of Shell Banks? A. A fixed address. B. Employ at least one full time employee. C. The majority of the board of directors must be local residents. D. Keep banking records at the fixed address.

Answer 47

A. A fixed address. B. Employ at least one full time employee. D. Keep banking records at the fixed address.

Question 48

QUESTION 48 The FATF has consistently noted the use of casinos in money laundering schemes in its annual typologies reports. One laundering technique involving casinos is: A. Asking for winners’ checks to be made out in the name of third persons or without a payee. B. Abusing casinos by circumventing its gatekeepers. C. Prepaying a casino token or chip by using funds that are already in the casino system, creating a debit balance. D. Extensive gambling via multiple games throughout the casino.

Answer 48

A. Asking for winners’ checks to be made out in the name of third persons or without a payee.

Question 49

QUESTION 49 Which of the following should an anti-money laundering specialist include on an internal investigation log? A. A government order on a customer that garnishes his wages for failure to pay child support. B. Supporting documentation and materials for denying service to a client with a bad credit rating. C. Notes pertaining to activity that is unusual, but for which a Suspicious Transaction Report has not been filed. D. Reference to a memorandum to the company’s corporate management relating to budgetary and similar concerns.

Answer 49

C. Notes pertaining to activity that is unusual, but for which a Suspicious Transaction Report has not been filed.

Question 50

QUESTION 50 What are the three key criteria in AML risk rating? A. Customer type, geographic location, products and services used. B. Geographic location, customer type, employment status. C. Products and services used, customer type and prior banking relations. D. Employment status, customer type, products and services used.

Answer 50

A. Customer type, geographic location, products and services used.