Practice Questions Flashcards by DING DING

An anti-money laundering specialist at a large institution is responsible for informing senior management about the status of the anti-money laundering program across the organization. Which report is the most useful?
A. The total credit exposure for non-cooperative countries and territories
B. Results of related audits and examinations
C. Details on inquiries received from law enforcement
D. Notification of management changes in the different major divisions

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What is most valuable when using the internet as an investigative source?
A. A team of AML investigators
B. A reference list of websites known to yield credible information
C. A combination of independent thinking and technical skills
D. A powerful search engine

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What are three risk factors a financial institution should examine with regard to a proposed new product?
A. The complexity of the product
B. The need to verify the identification of the customer
C. Whether the product is easily transferable
D. Whether other financial institutions are marketing the product

A,B and C

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Which three are principles found in the document “Principles of information Exchange between Financial Intelligence Units (FIUs)”?
A. The exchange of information between FIUs should take place as informally and as rapidly as possible and with no prerequisites, while guaranteeing protection of privacy and confidentiality of the shared data
B. Differences in the definition of offenses that fall under the competence of FIUs should be before free exchange of information takes place
C. The Egmont principle of free exchange of information at the FIU level should be possible on the basis of reciprocity, including spontaneous exchange
D. It should be possible for communication between FIUs to take place directly and without intermediaries

A,C and D

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A recent anti-money laundering audit revealed several regulatory reporting violations and lapses with the organization’s anti-money laundering policy. As a result, the compliance officer has created a follow-up matrix to document progress in correcting the identified deficiencies.
To whom should the compliance officer provide regular updates of corrective action to help ensure the appropriate oversight?

A. Human Resources
B. Audit management
C. Designated board committee
D. Business line managers

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A compliance officer at a small community bank has been asked to review existing customer onboarding policies and procedures to ensure they adequately address anti-money laundering risks.
How should customer due diligence be implemented?

A. With an annual compliance review and approval of customers
B. As applicable to customers that pose higher money laundering or terrorist financing risk
C. As an ongoing activity that may vary commensurate with the risk profile of the customer
D. With a one-time event conducted at initial customer onboarding

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Under the FATF Recommendations, when should a bank perform a risk assessment on issuing a new product to market?

A. 30 days from the official launch date
B. 90 days from the official launch date
C. During the product testing phase, but before final details on the product are defined
D. Prior to launching the product into the market to identify appropriate measures to mitigate identified risks.

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According to the Basel Committee, banks without due diligence requirements can be subject to the following:

A. Organizational risk
B. Transactional risk
C. Legal risk
D. Confiscation risk

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According to the Basel Committee, banks should perform the following customer due diligence measures?

Develop customer acceptance policies and procedures describing the customers background, country of origin, and business activities.
Establish policies and procedures to accommodate protecting the identity of private banking accounts.
Develop clear and concise description of who is an acceptable customer.
Establish continued monitoring of high-risk accounts for transactions of $100,000 or more.

A. 1 and 3
B. 2 and 3
C. 1 and 4
D. 3 and 4

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Under FATF’s assessment of a jurisdiction to identify Non-Cooperative Countries and Territories (NCCTs), which of the following were criteria used during the review?

Excessive secrecy provisions regarding financial institutions.
Lack of efficient suspicious transactions reporting.
Lack of resources in public and private sectors.
Absence of a financial intelligence unit.

A. 1, 2 and 3
B. 2, 3 and 4
C. None of the above
D. All of the above

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According to the Basel Committee, the three lines of defense in a bank’s AML efforts include?

A. Information technology, line of business and AML compliance
B. Line of business, information technology and audit
C. Audit, AML compliance and Board of Directors
D. AML compliance, line of business and audit

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According to the Basel Committee, A critical way to mitigate money laundering risk is by using the transaction monitoring system to?

A. Conduct ongoing monitoring of customer activity, build on information from enhanced due diligence and identify high-risk wire transfers.

B. Conduct ongoing monitoring of customer activity, build on information from risk assessments and customer profiles.

C. Conduct ongoing monitoring of customer activity, build on information from enhanced due diligence and customer profiles.

D. Conduct ongoing monitoring of customer activity, build on information from risk assessments and identify high-risk wire transfers.

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According to the Basel Committee on customer due diligence, what are the four necessary elements of a sound KYC program?

A. Customer acceptance policy, declaration of beneficial ownership, customer identification and risk management.
B. Customer acceptance policy, risk management, monitoring high-risk accounts and customer identification.
C. Declaration of beneficial ownership, customer identification, monitoring higher risk accounts and designation of PEPs as higher risk.
D. Customer retention policy, risk management, monitoring higher risk accounts and customer identification.

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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 (確定)the legal position for a client
C. Participating in financial or corporate transactions
D. Obtaining information associated with a judicial proceeding

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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

A,B and C

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According to the FATF40 Recommendations “designated non-financial businesses and professions” include:

A. Casinos, real estate agents and dealers in precious stones
B. MSBs , gatekeepers and issuers of electronic money
C. Dealers in precious metals, lawyers, commodity futures traders
D. Life insurance companies, real estate agents and notaries

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An AML compliance officer was reviewing customers at XYZ Bank and one of the customers attracted her attention. Through a period of several months cash deposits and withdrawals were transacted through his account with amounts ranging between US7500 and US 17000. In addition, Sam deposited two checks issued by a casino into his account for USD32000 each. When opening the account he 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
Bl 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

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A financial institution is looking to establish an online account opening service. The institution plans to offer this product to new and existing customers within the country. Which of the following would be the best plan of action for an AML specialist to recommend enabling the institution to verify the customer’s identity

A. do not offer the product, as it is too high risk as the customer cannot be seen to verify their identity.

B. Require all customers to send a copy of valid photo identification to the institution

C. Ensure that the institution has a reliable 3rd party source that will enable verification the customer

D. Allow customers to enter required information, but require all customers to come to the institution in person for verification

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An employee hears a colleague on the telephone with a customer giving advice on how to ensure that a suspicious transaction report will not be filed as a result of a future transaction.
What action should the employee take?

A. Report the conversation to the local police
B. Report the conversation to the compliance officer
C. Tell the colleague that it is against policy to give such advice
D. Ignore the situation because the colleague is the relationship manager for that customer

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A bank compliance officer has implemented enhanced monitoring rules that have identified some unusual activity that may be indicative of human trafficking.

Which Red flag should prompt additional transactional review?

A. Wire Transfer activity from countries with significant migrant populations
B. Cash deposits that occur in cities where the customer resides and conducts business
C. Cash deposits that occur in cities where the customer does not resides or conduct business
D. Cash deposits that occur in cities where the customer does not reside or conduct business followed by same-day withdrawals

D
Please refer to P266

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The USA PATRIOT Act requires United States (U.S.) financial institutions to collect certain information from non-U.S. banks that hold a correspondent account.

Which two pieces of information must a non-U.S. bank provide to its U.S. correspondent to enable them to comply with this requirement? (Choose two.)

Answers
A. The name and address of all shell banks the bank maintains accounts for
B. The name and address of all beneficial owners who own 25% or more of the bank
C. Prompt notice of any suspicious activity it detects on any customer who uses the correspondent account
D. The name and address of a U.S. person who is authorized to receive service of legal process for the bank

B & D

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In developing an effective AML compliance program, which of the following elements is most critical in ensuring accountability (問責) and enforcement (執法) across all levels of an organization?
A. Automated transaction monitoring
B. Periodic employee training and education programs
C. A clear AML policy and a designated AML compliance officer
D. Regular audits and risk assessments

A: Automated transaction monitoring systems

While automated transaction monitoring systems are important for detecting suspicious activities, they do not ensure accountability and enforcement across all levels of an organization.

B: Periodic employee training and education programs

Training and education programs are crucial for raising awareness and ensuring staff are knowledgeable, but they alone do not ensure accountability and enforcement.

C: A clear AML policy and a designated AML compliance officer

A clear AML policy and a designated AML compliance officer are essential for providing clear guidelines and ensuring there is a responsible party for enforcement, which promotes accountability.

D: Regular audits and risk assessments

Regular audits and risk assessments are important for periodically evaluating the effectiveness of the AML compliance program, but they do not alone ensure accountability and enforcement across all levels.

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What is an example of the integration stage of money laundering involving a bank or another deposit-taking institution?

A. Depositing illicit funds into an account set up for a front company
B. Directing third parties to exchange illicit cash for negotiable instruments
C. Wiring illicit funds from an account at one bank to an account at another bank
D. Using illicit funds that had previously been deposited to purchase a luxury vehicle

The integration stage of money laundering involves placing illicit funds into the legitimate financial system to give them the appearance of legitimacy. This is the final stage of the money laundering process and involves using the funds for seemingly legitimate purposes, such as making investments, purchasing real estate or luxury goods, or paying for services.

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The compliance officer at a crowdfunding website is in charge of monitoring new crowdfunding projects. Recently, the number of crowdfunding projects has significantly increased.

Which red flag indicates the highest anti-money laundering risk?

A. Those with the largest number of donors
B. Projects that get funding within days of their start
C. Projects with the highest monetary success threshold
D. Projects that start and close and are fully funded within a very short period

All of the options listed can potentially be red flags for anti-money laundering (AML) risks, but one stands out as the highest risk.

A. Those with the largest number of donors: While a large number of donors can be a positive sign of a popular project, it can also be a red flag if the donors are from high-risk jurisdictions or if the donors are individuals or entities with known criminal connections. However, large numbers of donors alone are not necessarily indicative of money laundering.

B. Projects that get funding within days of their start: While fast funding can be a positive sign of a popular project, it can also be a red flag if it is done through anonymous or suspicious payment methods, or if the project appears to have little value or potential for success. However, fast funding alone is not necessarily indicative of money laundering.

C. Projects with the highest monetary success threshold: This could be a red flag if the amount is extremely high and appears to be disproportionate to the project’s value or if the funding is coming from high-risk jurisdictions or individuals with criminal connections. However, a high monetary threshold alone is not necessarily indicative of money laundering.

D. Projects that start and close and are fully funded within a very short period: This option presents the highest AML risk. Projects that are fully funded within a short period, particularly if they are in high-risk sectors such as real estate or luxury goods, can be indicative of money laundering. Criminals may use crowdfunding as a way to launder money by quickly funding a project with illicit funds and then receiving the “clean” money from the project’s success. Therefore, this option presents the highest AML risk.

In summary, all of the options presented can potentially be red flags for AML risks, but option D presents the highest risk due to the potential for money laundering through quick and fully funded projects in high-risk sectors.

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Which two statements in the Wolfsberg Group's 'Suppression of the Financing of Terrorism' define the role financial institutions should play in the fight against terrorism? (Choose two.) A. Financial institutions need to assist competent authorities in fighting terrorist financing through prevention, detection and information sharing. B. Financial institutions need to continuously analyze the types of activity related to terrorist financing and develop models that in the long term will drive down terrorism. C. Financial institutions should have financial intelligence units dedicated to the investigation of activity that would lead to the detection of terrorist financing as a means to decrease global terrorism. D. Financial institutions should apply extra due diligence whenever they see suspicious or irregular activities, especially when customers are engaged in sectors or activities that have been identified by competent authorities as being used for the financing of terrorism.

AD Please refer to page 172

What is a key risk associated with Correspondent Accounts according to the Basel Customer Due Diligence paper? A. The volume and value of transactions passing through the account may not be in line with the original correspondent agreement. B. The respondent bank's customer acceptance and know your customer policies are ineffective. C. The service fees are insufficient to cover the cost of managing the account. D. It is not used on a daily basis.

What is the appropriate compliance control for identifying politically exposed persons (PEPs) according to the Basel Committee's paper on Customer Due Diligence for Banks? A. Reviewing relationships at account opening and on a periodic basis B. Reviewing when a relationship is established C. Determining that a local figure is a PEP D. Requiring that the customer discloses that they are a PEP or an associate of a PEP

An organization uses an automated surveillance system that generates a very large volume of anti-money laundering alerts. The monthly volume of alerts has increased over the last year causing the compliance staff to fall significantly behind reviewing the alerts. As a result, the system settings are under review to determine if they are appropriate. Which action should be included in the evaluation of system settings? A. Compare settings to organizations within its peer group B. Flag filters with no history of generating an alert for removal C. Review parameter settings based on the latest risk assessment D. Calibrate parameters based on staffing capabilities to clear alerts

An institution has made the decision to exit a client relationship due to anti-money laundering concerns. Prior to starting the close out process, the institution receives a written request from a law enforcement agency to keep the account open. The client is the subject of an ongoing investigation and law enforcement wants the institution to continue to monitor the account and report any suspicious activity. What is primary consideration the institution should keep in mind when deciding whether to agree to this request? A. The anticipated cost of complying with the law enforcement request B. The number of suspicious transaction reports previously filed on the client C. The fact that the institution has a solid record in complying with law enforcement requests D. Whether the institution can continue to meet its regulatory obligations with the accounts open

What are two sources for maintaining up-to-date sanctions information? (Choose two.) Answers A. U.S. Federal Bureau of Investigation's National Security Letters B. U.S. Department of the Treasury Office of Foreign Assets Control C. U.S. Department of the Treasury ג€" Section 311 ג€" Special Measures D. Financial Action Task Force's list of High Risk and Non-Cooperative Jurisdictions

B & C

A politically exposed person (PEP) maintains an account at a bank. Last month a money laundering analyst filed a suspicious transaction report about unusual wire deposits originated by unknown individuals in the home country of the official. Recently a negative news search revealed political corruption in the home country of the official. To whom should this situation be escalated? A. The board of directors B. The line of business executive C. The bank's anti-money laundering officer D. The Financial Action Task Force's PEP Hotline

The answer to this question is option C, the bank's anti-money laundering officer. This is because the AML officer is responsible for overseeing the bank's AML compliance program and ensuring that it is effective in detecting and preventing money laundering and terrorist financing. Therefore, the AML officer is the appropriate person to escalate the situation to. The AML officer can assess the risk of the situation and determine whether it is necessary to file a suspicious activity report (SAR) with the appropriate regulatory authorities. If a SAR is filed, the AML officer will work with law enforcement and regulatory authorities to investigate the matter further and take appropriate action to mitigate the risk. The board of directors (option A) and the line of business executive (option B) may not have the expertise or knowledge necessary to make informed decisions about AML matters. They may also be removed from the day-to-day operations of the bank's AML compliance program. Therefore, the AML officer is the appropriate person to handle this situation. Option D, the Financial Action Task Force's PEP Hotline, is an external resource that can be used to report PEP-related concerns to the appropriate authorities. However, it is not the first point of escalation in this situation. The bank's AML officer should be notified first, and they can then determine whether it is necessary to report the matter to the appropriate authorities, including the FATF's PEP Hotline.

Which two individuals are ordinarily beneficial owners of a private banking account according to the Wolfsberg Anti-Money Laundering Principles for Private Banking? (Choose two.) A. Those who are authorized signers on the account B. Those who have legal title to a controlling share interest in the customer C. Those who generally have ultimate control through ownership or other means over the funds in the account D. Those who are the ultimate source of funds for the account and whose source of wealth should be subject to due diligence

What are two requirements for monitoring and reporting suspicious activity for correspondent banking according to the Wolfsberg Principles? (Choose two.) A. Incorporate suspicious activity monitoring into periodic reviews B. Incorporate due diligence results such as customer risk ratings C. Utilize downstream correspondents to investigate and report suspicious activity D. Investigate and report suspicious activity only for the correspondent bank's clients

AB The Wolfsberg Principles are a set of global anti-money laundering (AML) guidelines developed by an association of international banks to promote effective AML measures and risk management in the financial industry. When it comes to monitoring and reporting suspicious activity for correspondent banking, two requirements outlined in the Wolfsberg Principles are: A. Incorporate suspicious activity monitoring into periodic reviews: According to the Wolfsberg Principles, correspondent banks should incorporate suspicious activity monitoring as part of their periodic reviews. Periodic reviews refer to the ongoing assessment and evaluation of correspondent banking relationships to ensure compliance with AML and other regulatory requirements. By integrating suspicious activity monitoring into these reviews, correspondent banks can actively identify and assess any potential suspicious transactions or patterns. This requirement emphasizes the importance of continuously monitoring transactions and customer behavior to detect and prevent money laundering and other illicit activities. B. Incorporate due diligence results such as customer risk ratings: Another requirement for monitoring and reporting suspicious activity in correspondent banking, as per the Wolfsberg Principles, is the incorporation of due diligence results, including customer risk ratings. Due diligence is the process of collecting and verifying information about customers, their business activities, and associated risks. Correspondent banks are expected to perform thorough due diligence on their customers and assign risk ratings based on the level of risk they pose. These risk ratings help in assessing the likelihood of suspicious activity and aid in prioritizing monitoring efforts. By incorporating customer risk ratings into their monitoring processes, correspondent banks can focus their resources on high-risk customers and transactions. To summarize, the two requirements for monitoring and reporting suspicious activity for correspondent banking, as outlined by the Wolfsberg Principles, are: A. Incorporating suspicious activity monitoring into periodic reviews to actively identify and assess potential suspicious transactions or patterns. B. Incorporating due diligence results, including customer risk ratings, to prioritize monitoring efforts and focus resources on high-risk customers and transactions.

When should the anti-money laundering risk assessment be updated? A. Every two years B. After a merger or acquisition C. When the board of directors changes D. When instructed to by the Financial Action Task Force

A customer brings $15,000 worth of chips into a casino and plays various games. The customer redeems all the remaining chips and requests a wire transfer of the proceeds to an unrelated third party. What are two red flags that indicate money laundering? (Choose two.) A. Customer redeeming all remaining chips B. Playing various games before cashing out C. Bringing $15,000 worth of chips into the casino D. Requesting a wire transfer to an unrelated third party

CD Requesting a wire transfer to an unrelated third party (Option D) When a customer requests a wire transfer to an unrelated third party, it could be an indication of layering, which is the process of separating the illegal funds from their source by creating layers of transactions to make it difficult to trace the funds. This is a common technique used in money laundering, where the ultimate goal is to disguise the proceeds of illegal activities as legitimate. Therefore, requesting a wire transfer to an unrelated third party is a red flag for potential money laundering. Bringing $15,000 worth of chips into the casino (Option C) Casinos are required to report any transactions over a certain threshold to the Financial Crimes Enforcement Network (FinCEN) under the Bank Secrecy Act (BSA). In this case, the customer bringing $15,000 worth of chips into the casino may trigger a Currency Transaction Report (CTR) filing by the casino. Money launderers may try to avoid detection by breaking up large transactions into smaller ones to avoid reporting requirements. Therefore, bringing a large amount of chips into the casino could be a red flag for potential money laundering.

During an internal investigation in a financial institution, what is the most critical first step that should be taken when suspicious activity is identified? A. Notify senior management immediately B. Preserve all relevant records and evidence C. Interview the customer involved in the suspicious activity D. Prepare a Suspicious Activity Report (SAR)

B Preserve all relevant records and evidence is crucial to ensure information is not lost or tempered with, and it allows for a thorough investigation. Preparing a SAR is essential but it comes after initial facts and evidence are gathered and preserved

Which emerging technology poses the greatest challenge for Anti-Money Laundering (AML) professionals in identifying and preventing illicit financial activities? A. Cryptocurrencies and Blockchain B. Artificial Intelligence and Machine Learning C. Decentralized Finance (DeFi) D. Big Data Analysis

C Decentralized Finance (DeFi) represents a novel and rapidly growing sector of the financial market that relies on public blockchain technology to conduct financial transactions. Unlike traditional systems, DeFi eliminates intermediaries, facilitates peer-to-peer transactions and increases transaction anonymity, posing a significant challenge for AML professionals to enforce regulations and track illicit financial activities. Cryptocurrencies and Blockchain technology provide anonymity and decentralization, making it difficult for AML professionals to trace and monitor transactions effectively

Which key element ensures the effectiveness of an Anti-Money Laundering (AML) compliance program within a financial institution? A. A formal risk assessment process B. Comprehensive training for all employees C. Periodic Independent testing and audits D. Imprementation of automated transaction monitoring systems

C While all of these elements are important in an AML compliance program, independent testing and audits are crucial because they provide an objective evaluation of the program‘s effectiveness, ensure it is properly implemented and functioning as intended and help identify any gaps or weaknesses A formal irsk assessment helps to identify and prioritize the area of greatest risk, ensuring that the resources are allocated effectively While training is essential, it alone does not ensure overall effectiveness of the AML compliance program Automated transaction monitoring systems are important, but they need to be part of a broader, well-rounded compliance program

Which of the following techniques has been identified as the key method used by terrorist organizations to transfer funds across borders? A. Trade-based money laundering B. Hawala Network C. Smurfing D. Digital currency

B Hawala is an informal method of transferring money without physical movement. it is heavily used in terrorism financing due to its anonymity and lack of regulation Digital currencies, such as cryptocurrencies, hae gained popularity for money laundering and terrorism financing due to their anonymity and lack of regulation, though their usage is still evolving and not as widespread as traditional methods

A United States (U.S.) bank was recently alerted by law enforcement of an increase in sale of large denomination U.S. bank notes to casas de cambio. They suspect that a Mexican syndicate is operating a money laundering scheme in the bank's jurisdiction. Which two steps should be taken to trace funds through the bank to assist law enforcement in their investigation? (Choose two.) 一家美國銀行最近接到執法部門的警報，表示向 casas de cambio 出售的大面額美國紙幣有所增加。他們懷疑墨西哥犯罪集團正在該銀行管轄範圍內實施洗錢計畫。應採取哪兩個步驟透過銀行追蹤資金以協助執法部門進行調查？（選兩個。 A. Identify the money laundering scheme and submit a suspicious transaction report B. Identify if there is a decrease in the sale of large denomination U.S. bank notes to casas de cambio by the bank C. Identify deposits by casas de cambio that include third-party items including sequentially numbered monetary instruments D. Identify multiple wire transfers initiated by casas de cambio to jurisdictions outside of Mexico that bear no apparent business relationship with that casa de cambio

Upon a routine account review a money laundering investigator identified a number of large round dollar wire transfer deposits into a business account owned by a local auto repair shop. The wire transfers all originated from a country that is a known financial secrecy haven with poor anti-money laundering controls. The investigator concludes there appears to be no legitimate business purpose for the wire transfers and files a suspicious transaction report. The owner of the auto repair shop is popular in the community and is a well-known philanthropist. To whom should the investigator escalate these concerns? A. Audit committee B. Chairman of the Board C. The owner of the auto repair shop D. The bank anti-money laundering officer

A compliance officer learns from an Information Technology (IT) source of a potential new financial service being discussed by the new product approval committee. What is the correct next course of action? A. Request that the new product approval committee include the compliance officer. B. Go to the board of directors and try to shut the new service down immediately because the committee did not communicate with the compliance officer. C. Get as much information as possible from the source so that potential risks can be researched and a report prepared and presented to the head of marketing. D. Start initial research into potential risks but wait until notified that the service has been approved by the committee before initiating extensive research.

What is the goal of the Egmont Group in providing a forum for Financial Intelligence Units (FIUs) around the world? A. To improve international laws to combat money laundering and the financing of terrorism and foster the implementation of domestic programs. B. To provide a forum for FIUs to improve cooperation in the fight against money laundering and the financing of terrorism and to foster the implementation of domestic programs in this field. C. To improve communication with law enforcement in the fight against money laundering and the financing of terrorism and to foster the implementation of domestic programs in this field. D. To improve cooperation with state and federal governments in the fight against money laundering and the financing of terrorism and to foster the implementation of domestic programs in this field.

B Please refer to P168

The branch manager notices that a number of customers come in weekly and always use the same teller to process their deposits. The manager notices that the customers and the teller, who are from the same ethnic group, are speaking in a foreign language and every once in a while the customers from local ethnic restaurants will bring the teller lunch. The commercial customers that visit the teller generally deposit the same amount of cash each time they come in. How should the branch manager respond to this activity? A. Transfer the teller to another branch B. Conduct further investigation before taking any other action C. Encourage the teller to bring in more business from the ethnic community D. Suggest to the teller to send the customers to other tellers to avoid the opportunity for collusion

Which insurance product is particularly vulnerable to money laundering? A. Annuity 年金 B. Casualty 意外保險 C. Collateral 抵押 D. Regulated pension 退休計劃

A Please refer to P44

What is an essential element of Know Your Customer (KYC) standards according to the Basel Committee's Customer Due Diligence for Banks paper? A. Annual staff training B. A customer acceptance policy C. The same KYC requirements must be applied in all cases D. All completed KYC documents must be reviewed by a senior manager not involved in the account opening process

B Please refer to P140 The 4 essential elements for KYC 1. Customer identification 2. Customer Acceptance Policy 3. Risk Management 4. Monitoring

A foreign bank operating under an offshore license wants to open a correspondent account with a United States (U.S.) bank. The foreign bank plans to provide payable through account services to some of its customers. What must the foreign bank provide to the U.S. bank under the USA PATRIOT Act? A. A list of politically exposed persons who are owners of the correspondent bank B. A list of account holders at the financial institution who will use the payable through account C. The person in the United States who can receive service of legal process for the correspondent bank D. A list of anti-money laundering training records for the financial institution employees monitoring payable through account transactions

C According to 319(b): Bank Records Related to Anti-Money Laundering Programs To facilitate the government's ability to seize illicit funds of individuals and entities located in foreign countries by authorizing the Attorney General or the Secretary of the Treasury to issue a summons or subpoena to any foreign bank that maintains a correspondent account in the U.S. for records related to such accounts, including records outside the U.S. relating to the deposit of funds into the foreign bank. This Section also requires U.S. banks to maintain records identifying an agent for service of legal process for its correspondent accounts.

An immigrant residing in the United States opens a bank account that includes a debit card. Several months later, the transactional monitoring system identifies small deposits into the account followed by corresponding ATM withdrawals from a country bordering a conflict zone. How should the bank respond? A. Block any further activity B. File a suspicious transaction report C. Initiate an investigation into the activity D. Contact the customer if the transaction activity continues

A retail bank has just acquired a credit card business. The bank's anti-money laundering policy requires that new employees are trained within 30 days of their hire date and refresher training is delivered to all employees on an annual basis. Is the bank's existing anti-money laundering training adequate to be delivered to employees of the newly acquired credit card business? A. Yes, the existing training covers the bank's policies, procedures, and processes. B. No, anti-money laundering training needs to be delivered face-to-face for credit card businesses. C. No, anti-money laundering training needs to be tailored and focused on the risks specific to the business. D. Yes, the existing training covers the anti-money laundering regulations that the bank is required to follow.

C Please refer P221 While it is true that the bank's anti-money laundering policy requires new employees to be trained within 30 days of their hire date and refresher training is delivered on an annual basis, this policy alone does not guarantee that the training is sufficient for the newly acquired credit card business. Anti-money laundering training should be tailored to the specific risks of the business in question. Credit card businesses, in particular, have unique money laundering risks that may not be adequately addressed in a generic training program. For example, credit card businesses may be vulnerable to schemes involving fraudulent credit card applications, account takeovers, and money laundering through the purchase and resale of goods and services. Furthermore, the acquisition of a new business often results in changes to the bank's risk profile and overall risk management strategy. These changes may necessitate updates to the bank's anti-money laundering policies and procedures, which would need to be reflected in the training provided to employees of the newly acquired credit card business. Therefore, the bank should ensure that its anti-money laundering training for the newly acquired credit card business is tailored to address the specific risks of that business and that it reflects any changes to the bank's overall risk management strategy resulting from the acquisition.

Which method do terrorist financiers use to move funds without leaving an audit trail? A. Extortion 勒索 B. Cash couriers C. Casa de cambio （現金交易所） D. Virtual currency

B Cash couriers are individuals who physically transport cash or negotiable instruments on behalf of others, often across borders. They use various techniques to avoid detection, such as concealing the cash in clothing, luggage, or other items, or splitting it into smaller amounts to avoid currency reporting requirements. Cash couriers can move funds quickly and efficiently, making it a preferred method for terrorist financiers who want to avoid the scrutiny of financial institutions or law enforcement agencies. It is difficult to trace the source of funds or determine the intended recipient when cash is physically transported.

In reviewing recent activity, a compliance officer for a money transmitter that several customers are each remitting the same amount of money but much more frequently. How should the institution respond? A. File a suspicious transaction report B. Instruct the tellers not to process remittances for these customers in the future C. Conduct further investigation to determine whether this is truly suspicious activity D. Immediately contact the customers and ask them why they are remitting money more often

In the summer, an institution identifies anti-money laundering concerns regarding a customer's account activity. The customer, an ice cream parlor (雪糕店), has deposited a lot of checks drawn on banks in foreign countries, sent large number of high dollar international wires to different countries, made cash deposits of a few hundred dollars every few days and written multiple checks for a few hundred dollars to the same dozen payees every two weeks. Which two transaction types warrant investigation? (Choose two.) A. Regular cash deposits B. The wires to foreign countries C. Repeated checks to the same payees D. Checks drawn on banks in foreign countries

A law enforcement agency is reviewing a suspicious transaction report (STR) filed by a financial institution for suspicious activity on a client's account. Subsequently, the agency requests further information. Which supporting documentation might the law enforcement agency request from the institution to facilitate its investigation? A. Previously filed STRs on the same customer B. Account opening documents and account statements C. Copies of promotional materials sent to the customer D. A copy of the institution's STR policy and procedures

A new compliance officer is reviewing the bank's anti-money laundering program and notices that the risk assessment was completed six months ago. Since that time, the bank acquired another financial institution, re-named the internal records group, and streamlined cash handling procedures. Which factor causes the compliance officer to update the bank's risk assessment? A. The bank acquired another institution B. The internal records group has been re-named C. The cash handling procedures were streamlined D. The risk assessment was completed six months ago

A The acquisition of another financial institution may result in changes to the bank's customer base, products and services offered, and geographic footprint. These changes could increase the bank's exposure to new risks, such as those associated with the new customer base or new geographic regions. As a result, it is essential to conduct a new risk assessment to ensure that the bank's AML program is effective in addressing these new risks.

The Wolfsberg Anti-Money Laundering Principles for Private Banking require new clients to be approved by whom? A. The board of directors B. Only the private banker C. The private banker's supervisor D. At least one person other than the private banker

D Please refer to P170

In which two ways does a government Financial Intelligence Unit interact with public and private sectors? (Choose two.) A. It governs the methods of investigation used by competent authorities B. It mediates disputes between financial institutions and investigative authorities C. It receives and analyzes disclosures filed by financial and non-bank institutions D. It disseminates information and the results of its analysis to competent authorities

CD Please refer to p300 of the study guide and Slide 80 of the ppt

What do Financial Action Task Force (FATF)-style regional bodies do for their members to help combat money laundering and terrorist financing? A. They provide technical assistance to members in implementing FATF recommendations B. They assist member countries in penalizing entities that violate FATF standards and recommendations C. They work with members on areas of concern outside of anti-money laundering and terrorist financing D. They supervise member country financial institutions relating to anti-money laundering and terrorist financing

A Please refer to P157

What are two requirements with respect to supporting documentation that is used to identify potentially suspicious activity, according to Financial Action Task Force? (Choose two.) A. It must be retained for at least five years B. It must be retained for at least seven years C. It must be kept in a manner so that it can be provided promptly D. It must only be released to the government through a subpoena process

AC Option A: Please refer to FATF Recommendation 11 - RecordKeeping (P125, Slide P67)

What are two reasons physical certificates present a money laundering risk to broker-dealers? (Choose two.) A. The trade information on a physical certificate can be easily altered B. Physical certificates do not expire and may be held by the owner for perpetuity (永續性) C. There is little information readily available to the broker confirming the source of the funds D. Physical certificates may be provided to nominees for deposit or settled in off-market transactions (場外交易)

CD off- market transaction: 指的是不在證券交易所交易，而是在買賣雙方之間直接進行證券交易。

An automotive parts company in South America sends multiple $500,000 wire transfers per week to ABC Holdings Ltd. in Asia referencing payment for silk flower shipments. Research reveals Sunrise Holdings, Ltd is registered in the British Virgin Islands with no available ownership information. What are two red flags that indicate how trade-based money laundering could be occurring in this instance? (Choose two.) A. The transaction involves the use of front (or shell) companies B. The packaging is inconsistent with the commodity or shipping method 包裝與商品或運送方式不符 C. Significant discrepancies appear between the description of the commodity on the bill of lading and the invoice 提單上的商品描述與發票上的商品描述有重大差異 D. The type of commodity being shipped appears inconsistent with the exporter or importer's regular business activities 所運送的商品類型與出口商或進口商的日常業務活動不一致

AC Please refer to P265 for TBML Red Flags The fact that Sunrise Holdings, Ltd is registered in the British Virgin Islands with no available ownership information is a red flag that suggests this entity may be a front (or shell) company used to facilitate illicit transactions. Specifically, the fact that they are referencing payment for silk flower shipments when the company is an automotive parts company suggests that the nature of the transactions may not be accurately represented, and may be a way to move illicit funds through trade channels.

The branch manager calls the compliance officer and informs her that a law enforcement officer has just left the branch and was asking a lot of questions and left a business card. What should the compliance officer do? A. File a suspicious transaction report B. Follow up to verify that the officer received all necessary information C. Verify that the reported officer was an actual authorized representative D. Require the branch manager to write a detailed memo about the request

C Given the potential risks associated with impersonation and fraud, it is crucial for the compliance officer to verify the authenticity of the law enforcement officer. This verification can be done by contacting the law enforcement agency directly or using established procedures for verifying the identity of authorized representatives. Confirming the officer's credentials helps ensure that the institution is cooperating with legitimate law enforcement agencies and protects against potential scams or unauthorized access to sensitive information. Once the officer's identity has been verified, the compliance officer can proceed with the necessary actions, such as following up with the officer to provide any required information and requesting the branch manager to write a detailed memo about the request.

What is a major economic consequence of money laundering through the use of front companies? A. Placing more emphasis on manufacturing B. Weakening of the legitimate private sector C. Creating a more competitive pricing environment 創造更具競爭力的定價環境 D. Aligning management principles between criminal enterprises and legitimate businesses 協調犯罪企業和合法企業之間的管理原則

B Please refer to P7, Slide 10 - The economic and social consequences of money laundering

Which directive under the European Union's Anti-Money Laundering (AML) framework mandates the establishment of beneficial ownership registers accessible to authorities and affected parties? A. 4th Directive B. 3rd Directive C. 5th Directive D. 2nd Directive

C Please refer to P

A bank account is established for a new business customer. The business was established five years ago with an address in another state. The business website contains few details other than stating it is a real estate business. One principal has an international telephone number and appears to be living in another country. The other principal works out of a recreational vehicle. What warrants enhanced due diligence in this scenario? A. Shell company B. Human trafficker C. Politically exposed person D. Money laundering through real estate

What are the two purposes of the USA Patriot Act? (Choose 2) A. To strengthen United States' measures to prevent, detect, and prosecute international money laundering and financing of terrorism B. To subject to special scrutiny foreign jurisdictions, foreign financial institutions, and classes of international transactions or types of accounts that are susceptible to criminal abuse C. To administer and enforce economic and trade sanctions based on United States foreign policy and national security goals against targeted foreign countries and regimes, terrorists, and international narcotics traffickers D. To set standards and promote effective implementation of legal, regulatory, and operational measures for combating money laundering, terrorist financing and other related threats to the integrity of the international financial system

AB https://www.fincen.gov/resources/statutes-regulations/usa-patriot-act

An AML training program should include which requirement? A. New tellers should receive training after their first year on the identification of suspicious or unusual activity. B. New lending staff should receive annual training on the preparation of currency transaction reporting. C. New staff should receive training during employee orientation or shortly thereafter on bank procedures. D. New operational staff should receive training shortly after hire on currency transaction reporting exemptions.

A Money Laundering Reporting Officer (MLRO) was aware that a strategically important client of the bank was sending money to human traffickers. However, the MLRO did not report the activity to law enforcement or move to exit the relationship. What is the legal term for the activity the MLRO engaged in? A. Avoidance B. Circumvention C. Negligent conduct D. Willful blindness

Which statement best describes a key aspect of the AML Directive of the EU regarding business relationships and transactions with high-risk third countries? A. Obliged entities should voluntarily consider the implementation of increased external audit requirements for branches and subsidiaries located in high-risk countries. B. Obliged entities, in accordance with the member state regulations, should determine at a national level the measures that can be used for enhanced due diligence. C. Obliged entities should implement additional mitigating measures complementary to the enhanced customer due diligence procedures, in accordance with a risk based approach. D. Obliged entities should not take into account specific circumstances when performing enhanced due diligence measures.

C Please refer to 5th EU Directive (Notes 152-153)

Which action by a prospective customer during the account opening process requires further investigation? A. Listing a long-distance phone number B. Questioning reporting requirements C. Expressing knowledge of the financial industry D. Providing driver's license

B Please refer to red flag signal (Notes P254-255)

Enhanced due diligence (EDD) may be bypassed for which situation? A. On-boarding a branch or majority-owned subsidiary of an EU or US FI located in a high-risk third country that fully complies with group-wide policies and procedures. B. On-boarding a subsidiary in a high-risk country with a complex ownership structure of a long-standing and reputable customer based in the EU or US. C. On-boarding a casino headquartered in the EU or US that is part of an international hotel chain, provides less than 50% of overall revenue and that fully complies with group-wide policies and procedures. D. On-boarding a reputable Politically Exposed Person (PEP) from the EU onto the wealth management arm of a US financial institution (FI).

Under the Egmont Group Principles, information exchange among Financial Intelligence Units (FIUs) is conducted: A. without the expectation of reciprocity on how the information will be used. B. freely, spontaneously, and upon request, on the basis of reciprocity. C. only if the status of the foreign FIU is related to law enforcement. D. with set limits on the amount of financial and administrative information provided.

B Refer to Notes p302 and https://egmontgroup.org/wp-content/uploads/2022/07/2.-Principles-Information-Exchange-With-Glossary_April2023.pdf

What core objective does the Egmont Group suggest would lead to an effective national Financial Intelligence Unit (FIU)? A. The FIU must operate from physically separated premises from other law enforcement agencies and government offices. B. The FIU meets the Egmont Group assessment criteria. C. The FIU must have absolute trust amongst national and international stakeholders before sensitive information will be exchanged with confidence. D. The FIU must be able to promote the value of the government's commitment to embed a corruption free society within the country.

C Please refer to the aims of Egmont group

An employee of a financial institution (FI) receives an email from a client directing the employee to transfer funds from the client's account to another account overseas. The bank employee complies, but later, the Fi discovers the email did not come from the client. Which type of cyber-enabled crime occurred? A. Phishing B. Spear phishing C. Spoofing D. Ransomware

B Please refer to notes P270 for definitions

One example of an external factor that will affect an organization's AML risk includes: A. acceptance of new customer types. B. introduction of mobile banking for all clients. C. political system changes in a specific jurisdiction. D. introduction of a new product which will be offered to wide range of clients.

To understand if the customer operates in line with the firm's risk appetite for a specific industry segment, a financial institution (FI) must: A. obtain the name and address, country identification number and date of birth of a non-customer who purchases a monetary instrument. B. obtain identifying information for beneficial owners through a completed certification form from the individual opening the account on behalf of the legal entity customer. C. obtain sufficient customer information to understand the nature and purpose of customer relationships for the purpose of developing a customer risk profile. D. obtain the name, date of birth for an individual, address and identification number from each customer before opening the account.

When a financial institution (FI) receives a court production order from law enforcement, it should: A. be responsive and provide pseudonymized customer information to make sure it's compliant with data privacy regulations. B. be responsive, provide customer information and be able to provide information from branches and subsidiaries if necessary. C. raise this matter with the Data Protection Officer to ask for data exchange approval prior to sharing the customer's personal data with the law enforcement. D. raise this matter with the Board to ask for data exchange approval and include corporate lawyers to make sure there is a legal basis for such exchange.

B When a financial institution (FI) receives a court production order from law enforcement, it should be responsive and provide customer information as per the requirements of the order. The FI should also be able to provide information from branches and subsidiaries if necessary. Answer option A, which suggests providing pseudonymized customer information, is not necessarily sufficient in response to a court production order. The order typically requires the FI to provide specific customer information, which may include personally identifiable information. Providing pseudonymized data may not meet the requirements of the order and may not be considered compliant with data privacy regulations. Answer option C, which suggests raising the matter with the Data Protection Officer to ask for data exchange approval prior to sharing the customer's personal data with law enforcement, is also not a recommended approach. A court production order is a legally binding request, and the FI is required to comply with it. Consulting with the Data Protection Officer to seek approval to share customer data would not be an appropriate response to such an order. Answer option D, which suggests raising the matter with the Board to ask for data exchange approval and including corporate lawyers to make sure there is a legal basis for such exchange, is also not the best approach. The FI is legally obligated to comply with the court production order, and seeking approval from the Board and involving corporate lawyers may cause delays and impede timely compliance with the order. In summary, the correct answer is option B, which suggests being responsive and providing customer information and being able to provide information from branches and subsidiaries if necessary. The FI should also ensure that the information provided is accurate and complete, as failing to comply with the order may result in legal and regulatory consequences.

In the follow-up process of the fourth round of Mutual Evaluations of the FATF, what happens when a country is placed on enhanced follow-up? A. If the country submits its implementation plan, it is freed from other enhanced measures that may be applied until the next evaluation by FATF. B. The country is required to remain on enhanced follow-up status until the next FATF mutual evaluation. C. The country undergoes a follow-up FATF assessment five years after the initial enhanced follow-up placement. D. The country has to report back its implementation plan at the first FATF general meeting after the adoption of the evaluation report by FATF.

C Please refer to notes p122

When should a financial institution (FI) exit a relationship? (Choose two.) A. The reputational risk to the FI posed by closing the account B. The request from law enforcement to close the account C. The FI's requirements for opening an account D. The suspicious conduct of the account holder E. The FI's stated policies and procedures for closing an account

BE Please refer to P290

Question 245 Which statements regarding the USA PATRIOT ACT best describe key aspects that have extraterritorial reach? (Choose three.) A. It allows for the US Attorney General to subpoena records from a foreign bank with US correspondent accounts, including those that are located outside the US. B. It allows foreign banks to voluntarily designate a registered agent in the US to accept service of subpoenas. C. It allows the Secretary of the Treasury to order a US financial institution (FI) to close a correspondent account when a subpoena has not been responded by a foreign bank in a timely manner. D. It obliges the government to trace the origin of the funds when a seizure of assets occurs in a correspondent account that has been opened and maintained for a foreign bank in the US. E. It excludes as foreign FIs businesses that would be considered broker-dealers, money transmitters, and currency exchangers. F. It allows federal banking supervisors to require records of the identity of the owners of a foreign bank from a FI operating in the US.

ACF

Which unusual or suspicious activity by a financial institution's (FI's) employee requires additional investigation and scrutiny? A. The employee avoids taking periodic vacations despite having accrued vacation time. 員工規避定期休假 B. The employee assists with transactions of a disclosed ultimate beneficiary. C. The employee lives a lavish lifestyle within their means. D. The employee is involved in a minimal number of unresolved exceptions.

A Please refer to P261

Which is a key reason why a financial institution (FI) conducts an enterprise-wide AML risk assessment? A. The need to assess money laundering and terrorist financing risks and ensure there are adequate controls to mitigate those risks. B. The identification of specific risk categories (i.e., export, inactivity, layman, and false locations) unique to the bank. C. The need to understand its overall budget needs for each department and for internal audit. D. The board of directors and senior management are required to have an AML risk assessment for the bank.

A foreign bank maintains a correspondent account in the US. According to an investigation carried out by US authorities, the specific correspondent account seems to have facilitated a transaction involving tainted funds. Which allows the US authorities to seize the funds of the foreign bank held with the US bank? A. The FinCEN CDD Final Rule B. The 6th EU AML Directive C. Regulations of the OFAC, US Department of Treasury D. The USA PATRIOT Act

One key aspect of promoting an enterprise-wide compliance culture within a financial institution (FI) is that the: A. first line of defense should establish its own policies independently. B. revenue generating business sectors should have precedence over compliance. C. relevant information should be shared throughout the organization. D. cost of compliance should increase proportionately to revenues.

A bank teller receives a written request from a police officer to review a previous customer's account on a pre-populated form with the officer's official letter head. The officer suspects the previous customer is engaging in smurfing. Which action should the bank teller perform? A. Provide the police officer the customer's account information. B. Reject the police officer's request for the customer's account information and escalate to the compliance officer. C. Provide the police officer the customer's account information after management approval. D. Escalate the police officer's request for the customer's account information to the compliance officer.

A non-Us bank is implementing a sanction compliance program. Which extraterritorial reach of OFAC regulations would matter the most to the foreign bank? A. OFAC sanctions programs prohibit transactions and require the blocking of assets of foreign individuals that appear in negative media sources. B. OFAC administers sanctions based on criminal investigations against targeted foreign individuals. C. OFAC acts only under presidential wartime emergency powers, against countries and foreign individuals considered enemies of the US. D. OFAC has the power to impose significant penalties on foreign individuals who are found to be in violation of the blocking orders.

D, Please refer to Slide 125

A typical red flag regarding potential money laundering in connection with an art purchase occurs when a customer: A. pays more at an auction for a painting than the estimated maximum price. B. asks to pay a large amount in cash without a comprehensible reason. C. buys a painting as an anonymous bidder and provides the source of wealth. D. asks to pay in installments and pays from two differently named accounts.

Which are the requirements of the Fifth AML Directive of the European Union (EU)? (Choose two.) A. Promoting the record keeping obligations of banks to the maximum amount of data necessary for the purposes of AML/CFT investigations. B. Extending AML/CFT rules to entities that provide virtual currency services. C. Broadening the criteria for assessing high-risk third countries. D. Developing a variant approach in the strategy for the treatment of organized crime and terrorism threats. E. Providing information access to Financial Intelligence Units (FIUs) according to the differences in the nature of their functions, competences and powers.

Which approach ensures the successful implementation of a transaction monitoring system? A. Ensuring all checks of a transaction monitoring system's rules and parameters use actual live data after the system is operational B. Implementing third-party transaction monitoring software, taking great care not to adjust pre-programmed rules and alerting thresholds C. Taking great care to minimize changes to transaction monitoring system rules and parameters once these have been certified as accurate D. Performing systems integration testing at key steps of development and user acceptance testing prior to going live with the transaction monitoring system

One of the main purposes of FATF-Style Regional Bodies is to: A. focus on global fraud typologies. B. help jurisdictions implement AML and terrorism financing standards. C. determine global watchlist standards and ensure that those lists are maintained accordingly. D. set up and maintain a global Politically Exposed Persons (PEPs) database.

B, please refer to P157

When considering sharing information across the institution or within the same jurisdiction, what is the key legal issue that poses challenges to sharing customer-related information? A. Data protection and privacy laws B. Technological inconsistencies and challenges C. Consumer protection laws D. Conflicting AML/CFT regulations

A compliance officer at a financial institution (FI) received an investigation request for a customer from a local law enforcement agency. The compliance officer informs the senior management team. Which action should be taken by the FI? A. Obtain approval from the Financial Intelligence Unit (FIU) before submitting the customer's information. B. Omit some responses to meet the regulatory deadline. C. Assign employees responsible for the customer to the investigation team. D. Consider retaining (聘請) qualified, experienced legal counsel.

D Please refer to notes P292

A country that does not have strong predicate offenses and is lax in prosecuting AML cases could suffer which social/economic consequence? Answers A. Loss of tax revenue B. Increased organized crime and corruption C. US sanctions D. Reputation risk for the port

The compliance officer for a private bank has been tasked with writing a policy on how the bank will deal with intermediaries. Which two aspects should be included in the policy in respect of intermediaries to align it with the Wolfsberg Anti-Money Laundering Principles for Private Banking? (Choose two.) A. When an intermediary introduces clients to the bank, it is not necessary for the bank to perform due diligence on the intermediary's clients. B. Where an intermediary introduces clients to the bank, the bank must obtain the same type of information with respect to an introduced client that would otherwise be obtained by the bank, absent the involvement of the intermediary. C. Where an intermediary manages assets on behalf of a number of clients and is the account holder with the bank, but that intermediary does not conduct the same level of due diligence as the bank, it is necessary for the bank to undertake due diligence on the intermediary's clients. D. Where an intermediary manages assets on behalf of a number of clients and arranges for the opening of accounts for its clients with the bank, and that intermediary is a financial institution subject to similar regulations, it is necessary for the bank to perform due diligence on the intermediary's clients.

B & C

C From ACAMS Mock Exam

An institution has made the decision to exit a client relationship due to anti-money laundering concerns. Prior to starting the close out process, the institution receives a written request from a law enforcement agency to keep the account open. The client is the subject of an ongoing investigation and law enforcement wants the institution to continue to monitor the account and report any suspicious activity. What is a primary consideration the institution should keep in mind when deciding whether to agree to this request? A. The anticipated cost of complying with the law enforcement request B. The number of suspicious transaction reports previously filed on the client C. The fact that the institution has a solid record in complying with law enforcement requests D. Whether the institution can continue to meet its regulatory obligations with the accounts open

In the summer, an institution identifies anti-money laundering concerns regarding a customer's account activity. The customer, an ice cream parlor, has deposited a lot of checks drawn on banks in foreign countries, sent large number of high dollar international wires to different countries, made cash deposits of a few hundred dollars every few days and written multiple checks for a few hundred dollars to the same dozen payees every two weeks. Which two transaction types warrant investigation? (Choose two.) A. Regular cash deposits 規律的現金存款 B. The wires to foreign countries 匯錢到外國 C. Repeated checks to the same payees 重複向同一批受款人開支票 D. Checks drawn on banks in foreign countries 從國外銀行提領的支票

BD From ACAMS Mock Exam

Which two factors should increase the risk of a correspondent bank customer and require additional due diligence according to the Wolfsberg Anti-Money Laundering Principles for Correspondent Banking? (Choose two.) A. The customer is located in a Financial Action Task Force member country and provides services primarily to a local individual customer. B. The customer is located in a Financial Action Task Force member country and the bank's head of information security is a politically exposed person. C. The customer is located in a Financial Action Task Force member country and provides services to other correspondent banks in neighboring countries. D. The customer is located in a non-Financial Action Task Force member country and services mostly commercial customers who engage in international trade.

As a result of an audit, a policy exception was identified that had been approved by the compliance officer. The auditor determined that the policy exception is a violation of a regulatory requirement. What should the auditor do? A. Advise the compliance officer on how to appropriately respond to policy exceptions. B. Include the regulatory violation in the audit report and report it to the board of directors. C. Consult with legal counsel to determine if the approval of the policy exception was acceptable. D. Include the regulatory violation in the audit report and recommend the compliance officer be subject to disciplinary action by the board of directors.

A foreign politically exposed person (PEP) requests to add a beneficiary to a life insurance policy. How should the request be processed to mitigate risk? A. Perform due diligence on the beneficiary B. Determine the source of wealth and source of funds C. Decline the request if the beneficiary is a foreign PEP D. Decline the request to add a beneficiary due to increased risk