The primary objectives of the United Nations in developing sanctions regimes include: (Select Three.)
A bank located in Arizona is considering a loan application for a new client. The collateral for the loan is a
property in Florida.
The loan will be in the name of a limited company (LLC) whose ownership is not disclosed to the bank. The
LLC was established by a New York-based attorney.
The loan will be repaid by the LLC in monthly wire transfers of $9,000 which is more than the required monthly
payment.
Which aspect indicates potential for money laundering?
Which of the following activities is most likely associated with a lawyer participating in a money laundering scheme?
Customers of a telecommunications firm received an email explaining an issue with their last order. The customers were directed to the company website via a link in the email to provide personal information. Both the email and website were fake. What type of cybercrime has been committed?
Which is a goal of Financial Action Task Force Regional-Style Bodies?
An AML specialist at a financial institution is presented with a search warrant. Which actions should be taken to comply with the search? (Select Two.)
When performing an investigation, which key steps should be taken to maintain and secure supporting documentation used to perform an investigation of a suspicious activity?
A financial institution's monitoring system triggers an alert and an internal investigation has confirmed the activity as suspicious. Which of the following should an anti-money laundering specialist do before submitting the suspicious transaction report?
How can violations of anti-money laundering laws be a risk to individuals?
A precious metals dealer opens a new account with a bank. Which requires a referral to AML Investigations for further review?
Which scenario indicatespotential money laundering activity by a lawyer?
Which three methods are commonly used by an accountant to launder money? (Choose three.)
A businessman requests a European private bank to open a numbered or alternate name account. According to the Basel Committee on Banking Supervision principles, which of the following is the most important question the banker should ask?
A credit institution has been served with a preliminary findings report highlighting major deviations from AML obligations in its country and stating that it faces the possibility of withdrawal of its banking license.
Which authorities could have issued the report?
Which online gambling scheme involves placing bets with deposited funds and colluding with other players to obscure the money’s origin?
Which action does the Financial Action Task Force call on member countries to take in the most serious cases when countries have significant strategic AML deficiencies?
Which of the following activities conducted at a financial institution is the strongest example of avoiding reporting thresholds?
A high volume of incoming wire transfers generates an alert about a client. The funds are immediately debited by cash withdrawals and outgoing wire transfers. Which information should be reviewed first to investigate this alert/case?
Which of the following are included in the11 Immediate Outcomesoutlined in the Financial Action Task Force (FATF) methodology for assessing technical compliance with the FATF Recommendations and the effectiveness of AML/CFT/CPF systems during mutual evaluations? (Select Three.)
A high-volume dealer of precious metals and stones in a high-risk jurisdiction is approached by a new customer interested in selling gold worth $200,000. The customer was referred by a longtime family friend of the dealer and provides no indication ofbackground or business purpose for the sale. The dealer agrees to make the purchase based solely on the reference.
What is the money laundering red flag?
Which of the following is a common strategy employed by non-governmental organizations (NGOs) to combat money laundering?
A compliance officer for a casino may suspect money laundering if an individual:
Public-private partnerships (PPPs) that involve the sharing of information between law enforcement authorities, Financial Intelligence Units (FIUs), and the private sector are established to: (Select Two.)
Abank organized under foreign lawand located outside of the U.S. maintains acorrespondent banking relationshipwith aU.S.-based bankto handlefinancial transactions in U.S. dollarsfor its clients.
In compliance with theUSA PATRIOT Act of 2001, allU.S. banks and broker-dealers in securities must obtain a signed certificationfrom allnon-U.S. foreign bank clients conducting business with them.
What information does theUSA PATRIOT Act of 2001require theforeign bank to certify to the U.S. bank? (Select Three.)
Which three do the Office of Foreign Asset Control regulations cover? Choose 3 answers
Which scenario best justifies why a customer's account might be closed by a financial institution?
A well-developed anti-money laundering compliance program is unlikely to achieve institutional goals without
Which regulation permits financial institutions, upon providing notice to the US Department of the Treasury, to share information with one another in order to identify and report activities that may involve money laundering or terrorist activity to the federal government?
Which activities could be considered a potential spear phishing scam? (Select Three.)
Cybersecurity risk can result in identity theft by:
Red flags for potential money laundering in real estate include completing luxury real estate purchases. (Select Two.)
A national Financial Intelligence Unit, which is responsible for receiving, analyzing and disseminating disclosure of financial information, should consider becoming a member of what organization?
Which of the following should an anti-money laundering specialist consider the most serious deficiency when detected during a regulatory audit of the anti-money laundering program?
Whichkey metricwould provide themost valuable datatosenior managementabout theeffectiveness of its AML controls?
A bank receives a request for a subpoena (or a client who has been the subject of monitoring for several months. The bank wishes to close the account in order to mitigate any additional risk. However, the government requires that the account remain open. What document must be provided to the bank to keep the account open?
A financial institution (FI) is fined for failure to implement an effective AML program. Which consequences could the regulator impose on the bank's Chief AML Officer? (Select Three.)
A charity has unaudited accounts. Which of the following represents the highest risk factor for terrorist financing?
A country that does not have strong predicate offenses and is lax in prosecuting AML cases could suffer which social/economic consequence?
A U.K. real estate agent has three foreign clients interested in purchasing an apartment building, valued at £30
million, in the outskirts of London as an investment property. The clients are not willing to have their names
provided to the bank. The clients want to purchase to be made in the names of three private companies for
privacy reasons. The plan is to wire the funds into an account held in the name of another private company at
a bank in London.
Which red flag should stop the agent from discussing this potential purchase further?
Which of the following is considered a shell bank as defined by the USA PATRIOT Act?
According to the Basel Committee, customer acceptance, customer due diligence, and record-keeping policies and procedures should be changed as necessary to:
Which of the following is the best action to take regarding a particular account once suspicious activity is reported by the institution?
Financial Action Task Force (FATF)-style regional bodies are created and obliged to understand the inherent
money laundering and terrorist financing risks in the region of the world they serve.
What is one of the methods they use to understand these risks?
Which event occurs most frequently in money laundering in the insurance industry?
Which is often an indirect consequence of non-compliance with AML laws?
A comprehensive set of risk-based guidelines for maintaining business relationships is being developed.
Which situation indicates that the institution should terminate the relationship with a client?
How should law enforcement obtain documentation from an institution when suspicious activity was identified? (Choose two.)
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 wellknown philanthropist.
To whom should the investigator escalate these concerns?
Which risk factors are associated with acquiring and servicing the banking activities of customers considered higher risk for financial crime activities? (Select Three.)
Which of the following is among the Financial Action Task Force criteria defining non-cooperative countries and territories?
Which transaction monitoring processes would alert a bank for red flag activity?
AnAML analyst at a financial institutionis examining analert generated by the automated transaction monitoring systemto determine whether the alert should beescalated to the AML unit for further investigation or archived as a false positive.
Whichaction might be reasonable for the AML analyst to take?
Which action should financial institutions with cross border correspondent banking activity be required to perform according to the Financial Action Task Force 40 Recommendations?
A suspicious transaction report has been filed on an account owned by the wife of the bank’s ChiefExecutive Officer. Which of the following is the most important consideration when deciding whether to recommend closing the account?
The bank for International Settlements provides the secretariat for which organization?
According to the Financial Action Task Force, financial institutions should exit the relationship with a client in which case?
A compliance officer of a financial institution is reviewing a payment for sanctions compliance between two parties in Europe and Asia. The payment is in Euros and involves the provision of services to a company located in a jurisdiction subject to Office of Foreign Assets Control secondary sanctions. Which factor is most important in determining the compliance officer's response?
A compliance officer at a financial institution has completed an investigation into a high-risk customer's activities and determined that there are strong indications of money laundering. The compliance officer has documented their findings and is ready to recommend offboarding the customer. However, the relationship manager responsible for the customer is resistant to the idea, citing the customer’s significant revenue contribution to the institution.
What should the compliance officer do next to ensure the appropriate escalation and decision-making process is followed?
Whichred flag is most relevant to money laundering through capital markets?
The Wolfsberg Group has issued a number of documents since its inception aiming to:
A financial institution (FI) has decided to revamp its compliance program to be more risk-based. Which option should the FI use as part of the new risk-based compliance program?
While gaming platforms are typically used for recreational purposes, they can potentially be used for terrorist financing through games in which players can:
A compliance officer is tasked with implementing an enterprise-wide anti-money laundering program for a bank, which operates in multiple countries. Not all the bank products and services are available in all countries.
Which three factors should be considered as part of the approach? (Choose three.)
What is the primary action a financial institution should take before formulating its anti-money laundering program?
Upon filing a suspicious transaction report, which of th€ following elements should be the highest anti-money laundering priority in making the decision to keep the account open?
A financial institution's US Branch receives a subpoena from law enforcement requesting detailed records of a customer's account activity. The customer is part of an ongoing investigation into a money laundering operation. At the same time, the institution has received a FinCEN 314(b) information-sharing request from another bank seeking details on transactions linked to the same customer. The compliance team is tasked with responding to both the subpoena and the FinCEN 314(b) request.
What should the compliance officer prioritize in responding to these requests while ensuring that all legal and regulatory obligations are met?
What should an effective anti-money laundering training program include?
Under requirements for correspondent accounts in the USA PATRIOT Act, the word "certification" refers to a written representation by a
When may Office of Foreign Assets Control (OFAC) sanctioned-related transactions be allowed that would otherwise be prohibited?
How can a ‘free-look provision’ as part of a life insurance policy help criminals to launder money?
What are three elements of a sound Customer Due Diligence Program?
Which of the following statementsbest describes the role of the Board of Directorsin overseeing an institution’sAML governance and compliance framework, according to theBasel Committee on Banking Supervision?
A client has retained a lawyer to create a financial holding company. The lawyer resides in Europe. The client provides all requested documentation to the lawyer. However, the lawyer becomes suspicious that the customer is engaged in criminal activity and intends to use the financial holding company for money laundering purposes. Which of the following should an anti-money laundering specialist recommend according to the European Union Money Laundering Directives?
When should new business products to evaluated for AML concerns?
Which of the following attributes would enhance an AML program's effectiveness?
A customer opens a corporate account with a broker-dealer on behalf of several beneficial owners, with a
stated long-term investment goal. The customer deposits $25.5 million into the account and three days later transfers $5 million to an overseas bank. Shortly thereafter, the customer begins making numerous purchases of pesos. The compliance officer receives a query regarding the movement of funds. Within a month of account opening, the customer depletes the account.
Which two red flags should prompt the firm’s compliance officer to take action? (Choose two.)
A compliance officer is reviewing the activity of the wire transfer department for the previous month and identifies an unusual wire transfer from a customer’s account.
Which information should be included in the review of the customer’s activity?
According to the Financial Action Task Force 40 Recommendations, Designated Non-Financial Businesses and Professionals include which entities?
Which situations would require a financial institution (FI) to update its ML/TF risk assessment? (Choose two.)
A government has instituted a new anti-money laundering laws which require all financial institutions to obtain certain information from its customers.
Which step should an institution located in this jurisdiction take to ensure compliance?
A compliance analyst is reviewing the account activity of a customer that they suspect may be indicative of money laundering activity. Which is difficult to determine solely from the customer's account activity and KYC file?
In relationship to life insurance business, the third European Directive states that Member States may allow the identity verification of the beneficiary under the policy after the business relationship has been established, but before which events?
A compliance officer at a large financial institution has been tasked by senior management to lead a team in an internal review and potential revision of the institution’s customer onboarding program following a regulatory enforcement action of another institution.
Which step should the compliance officer perform first?
Which ML/TF risks are associated with cryptoassets? (Select Three.)
In order to protect investigative materials from disclosure when conducting an internal Investigation of any employee of a financial institution, legal counsel of that financial should________?
A non-U.S. bank wants to open an account at Bank A, which is a U.S.-based bank.
Which information must Bank A obtain under the USA PATRIOT Act?
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?
An AML compliance officer receives notice of government update including the names of the latest terrorists sanctioned by the United Nations Security Council. Which would be the most appropriate step to take?
A high-profile, successful entrepreneur has been a client of a Swiss private bank for more than a decade. Recently, the entrepreneur launched a political career, with rather extremist
political views. On which grounds can the bank terminate the client's bank relationship? (Select Two.)
Interactions between the compliance department and other functions or departments within an organization contribute to making the anti-financial crime (AFC) compliance program more robust by addressing specific risk areas.
Which departments play a crucial role in enhancing the AFC compliance program of an organization? (Select Two.)
How canawareness be raisedwithincountries that do not have sanctions regulatory regimes? (Select Two.)
Which of the following represents the first Financial Action Task Force initiative?
A close relative of a privately-owned bank's senior manager requests to open an account. Because of this relationship, the staff expedites the opening of the account without following established account-opening procedures. Applying the Basel Committee on Banking Supervision principles, which of the following poses the highest operational risk?
What is an example of a legal risk a financial institution (FI) could face if it is sanctioned for failure to report suspected fraud activity?
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.)
Whichmeasures help limit the collection and use of personal datawhen performing AML-related controls?
At a small community bank, the compliance officer identifies unusual activity on a customer, who with his personal and company accounts, is the bank’s largest depositor. The customer’s companies have significant balances on their outstanding loans. The compliance officer notices that there is a lot of unusual movements of money between the customer’s individual and business accounts. After filing a suspicious transaction report (STR), the compliance officer gets a call from law enforcement indicating that they want the bank to keep the account open while they conduct an investigation into the customer.
How should the compliance officer escalate this information to the board of directors?
Which is the first valid step in the Mutual Legal Assistance Treaties (MLAT) international cooperation process?
AnAML analyst at a bankis investigating cases triggered bytransaction monitoring alerts.
Whichcircumstances might cause the analyst to suspect a case involves terrorist financing? (Select Two.)
A new AML Officer for a US-based money service business (MSB) is drafting procedures around types of activity that require further review. Which should be included? (Choose two.)
What action does the USA PATRIOT Act allow the US government to take regarding financial institutions (FIs) that are based outside of the US?
Suspicious activity triggered a suspicious transaction report filing on a company that holds an account at a large commercial bank. Investigations revealed that a member of the bank's Board of Directors is the major shareholder of the company. Further review revealed the bank had no reasonable explanation for the activity, but could not confirm if criminal activity occurred. Which of the following is the next best course of action for the compliance officer?
A foreign politically exposed person (PEP) requests to add a beneficiary to a file insurance policy.
How should the request be processed to mitigate risk?
Whichpersons must always comply with all Office of Foreign Assets Control (OFAC) regulations? (Select Three.)
Which of the following laws or regulations can impact the application of AML/CFT programs and require financial institutions (r" Is) to balance multiple compliance requirements?
According to the Financial Action Task Force Special Recommendations on Terrorist Financing, which of the following should an anti-money laundering specialist do if the specialist has reasonable grounds to suspect funds are linked or related to terrorist acts?
What is a major economic consequence of money laundering through the use of front companies?
A banker in the credit department wants to assess the risk of all customers, and contacts the compliance officer to request a list of customers with suspicious transaction report filings.
What should be done to protect suspicious transaction report information?
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?
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 bank has joined a public-private partnership (PPP) to work with law enforcement and regulators on combating financial crime. However, the bank's data protection officer is concerned about sharing sensitive customer data, and the compliance officer is worried about potential delays in receiving useful information from the government.
Which of the following best describes a benefit of PPPs in fighting financial crime?
Which statement about a multinational institution’s ability to fully investigate unusual activity in all its foreign operations is correct?
According to the Financial Action Task Force, which action must a financial institution take to fulfill customer due diligence obligations?
What is true regarding disclosure to a law enforcement agency by a financial institution of the supporting
documentation for a suspicious transaction report?
What should senior management do in order to promote a culture of anti-money laundering compliance?
To understand if the customer operates in line with the firm's risk appetite for a specific industry segment, a financial institution must:
In many jurisdictions, financial institutions are prohibited from hiring a person who has been convicted of what type of offense?
Abank received a subpoenaregarding one of its clients. TheFinancial Intelligence Unit (FIU) of the bankshould review the subpoena and:
Which two statements are true regarding the European Union Money Laundering Directives? (Choose two.)
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?
Bank A is located in Country A. A wire transfer from Bank B located in Country B is processes by Bank A, where the funds are being moved to a customer at Bank C located in Country C. The wire transfer is deemed suspicious by Bank A.
Who should Bank A file a suspicious transaction report on?
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.)
An example of an external factor that will affect an organization's AML risk is:
What is a key objective of the Egmont Group?
According to the Financial Action Task Force methodology, which situations would require a financial institution (FI) to consider filing a suspicious activity report?
How can a financial institution verify the nature and purpose of a business and its legitimacy?
According to the Egmont Group, which benefits do public-private partnerships (PPPs) provide to Financial Intelligence Units (FIUs)? (Select Three.)
What is thepurpose of a Risk Appetite Statement (RAS)and its linkages while implementingorganizational controls? (Select Two.)
A financial institution recently purchased anti-money laundering software. The software routinely generates more alerts than the anti-money laundering staff can properly analyze as a result of limited staffing. These alerts are generated by default software rules. Which of the following should the individual responsible for setting the anti-money laundering software parameters recommend?
Which red flags should be considered prior to establishing a relationship with a third party? (Select Two.)
Which collective body of Financial Intelligence Units (FlUs) was formed with an objective to improve Information exchange and sharing mechanisms among member FlUs as well as to support its members by enhancing their capabilities'?
The United Nations Security Council (UNSC) is empowered to impose sanctions regimes against countries and terrorist organizations.
Which statements are true regarding sanctions imposed by the UNSC? (Select Two.)
An institution is about to release a new peer to peer (P2P) funds transfer product to provide much needed remittance services to an under-banked population segment in the country.
The service allows customers to transfer funds through a mobile banking application to individuals worldwide entering only a name and mobile number. The new service charges less than comparable market solutions and offers real time transfer of funds. The customer onboarding process is conducted at branch locations with
identity verification.
Which three present the highest anti-money laundering or sanctions risk and will require controls prior to launch? (Choose three.)
A commission rogatory would be used in which gateway to obtain information from another country?
Which three circumstances are indicators for defining a customer as required additional diligence according to the Wolfsberg Principles on Private Banking? Choose 3 answers
The compliance officer at a crowd funding website is in charge of monitoring new crowd funding projects.
Recently, the number of crowd funding projects has significantly increased.
Which red flag indicates the highest anti-money laundering risk?
Which transaction should result in a suspicious activity report filing?
A customer comes into the bank and appears to be ill-at-ease waiting in the teller line. When the customer gets to the teller, he become exceedingly nervous and asks for a large cashier’s check to be cashed and disbursed to him in $100 bills.
What should the teller do after completing the transaction?
The ultimate goal of economic sanctions is to:
When implementing a risk-based approach related to casinos, which risks are related to the customer as an individual? (Choose two.)
A real estate buyer purchases multiple high-value properties in cash through a series of transactions in a short period of time and without any clear economic justification.
Which of the following is the most likely money laundering risk associated with this behavior in the real estate sector?
What national agency is responsible for analyzing and assessing the information it receives to substantiate possible existence of money laundering or terrorist financing activities?
The new KYC lead at a bank is particularly focused on enhancing the risk management component of its KYC program and refers to the Basel Committee's customer due diligence (CDD) principles.
Which of the following describe key improvements to a KYC program established in the Basel Committee's CDD principles? (Select Two.)
In May 2002, the Wolfsberg Principles on Private Banking were revised and included a section that prohibits the use of internal non-client accounts in a manner that would prevent officials from appropriate monitoring movements of funds or keep clients from being linked to the movement of funds on their behalf.
What is another name for these internal, non-client accounts?
Who bears the ultimate responsibility for approving a financial institution's relationship with a politically exposed person?
Which three procedures should a compliance officer looking to revise an institution’s CTF efforts include in accordance with the Wolfsberg Group’s Statement on the Suppression of the Financing of Terrorism?
Bank A is a non-United States (U.S.) bank that has $5 million in a correspondent account at a bank in New York City. The Worldwide Terrorist Syndicate (WTS) has $1 million in its account at a non-US branch of Bank A. The U.S. government has initiated forfeiture action against the WTS.
Which potential action can the U.S. take under the USA PATRIOT ACT pursuant to the issuance seizure warrant?
A local law enforcement officer, who is conducting a criminal investigation, requests information about a customer.
Which two actions should the bank take? (Choose two.)
Transfers of money over the last 6 months to a corporation in a jurisdiction with strict secrecy laws triggered an alert. Which of the following should cause the most suspicion of money laundering?
Which statement identifies one of the duties of a government Financial Intelligence Unit?
A bank has maintained an account for a European charity for several years. The charity provides clothing to persons in need in various countries with active terrorists’ cells.
Which action by the charity indicates possible terrorist financing?
Which key aspect of the Office of Foreign Assets Control's extraterritorial reach specifically relates to prohibited transactions?
Which three statements are true about on-line banking offering a significant money laundering risk to a financial institution?
What three attributes do havens for money laundering and terrorist financing typically have? Choose 3 answers
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.
To whom should this situation be escalated?
Which o! the following are considered best practices regarding senior management involvement in a financial crime compliance program? (Select Two.)
A customer has held an account at a local credit institution for 10 years. The account has received deposits twice weekly for the same amount and has never shown signs of suspect behavior. Monitoring software indicated that in the past few months the account has received several large deposits that were not in line with the account history.
When asked, the customer states she recently sold a piece of property, which is supported with a proof of sale.
Which of the following should the compliance officer do next?
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 QUESTION NO:s and left a business card.
What should the compliance officer do?
Under the USA PATRIOT Act, in which scenario would the US not have jurisdiction?
A compliance officer at a financial institution (FI) received an investigation request for a customer from a local law enforcement agency. Which action should be taken by the FI?
An accounting firm opened an account at a bank that is intended to be used as the operational account for the business. After a few months, a comprehensive review of the account was triggered due to unusual activity on the account. Which most likely triggered the review?
What are four key elements that a KYC program should contain according to the Basel Committee requirements?
Which action does the Financial Action Task Force (FATF) recommend be taken against jurisdictions that
have strategic deficiencies?
AML training programs should extend beyond basic concepts to deliver targeted training by:
Which money laundering risks are posed by the misuse of trust and asset management services? (Select Three.)
OFAC-issued regulations apply to which entities? (Choose two.)
A bank sells reloadable open-loop prepaid cards to both customers and non-customers.
What is a red flag associated with these cards that may indicate money laundering?
The findings of an internal audit discover that a large group of employees do not know how to handle Politically Exposed Persons (PEPs). Which is the next course of action that should be taken?
According to Basel Committee guidelines, which level of the organization should determine whether or not to enter business relationships with higher risk customers?
A European Union (EU) bank has a correspondent banking relationship with a U.S. bank. Under USA PATRIOT Act Section 311, the U.S. government has enacted special measures against a designated entity that has a payable-through account with the EU bank. Which of the following actions might the U.S. bank be required to take regarding the EU bank's services for the designated entity?
Which factor should a bank consider before sharing information about a customer with its broker-dealer
affiliate in the case of an investigation?
An anti-money laundering specialist has just developed and implemented an anti-money laundering program. Which of the following is the best resource to evaluate the effectiveness of the program?
Country A’s anti-corruption authorityhas been investigating themovement of potential proceeds of bribery and corruption to Country Band is now preparing to take the case to a local court.
Which method of obtaining the requiredevidence to prosecute the casewould bemost effective?
Which unusual or suspicious activity by a financial institution's (FI's) employee requires additional investigation and scrutiny?
Which are primary purposes of Financial Action Task Force {FATF)-Style Regional Bodies? (Select Two.)
To ensure that an institution’s anti-money laundering program is current, which step should be taken?
A bank iscompleting a periodic KYC profile reviewfor asmall digital marketing companybased inNew York City.
Which of the following would be ared flag?
What is therelationship between the EU Anti-Money Laundering Directives (AMLDs) and local AML regulationsin European Union (EU) member states? (Select Two.)
Abank is preparing for a regulatory examafter a previousregulatory exam identified weaknesses in its AML program. Since the last exam, the bank has:
Improved its written AML program
Hired an experienced AML compliance officer
Demonstrated a stronger culture of compliance
Focused on clearing its transaction monitoring case backlog and enhancing its sanctions screening program
Which of the followingare correct? (Select Two.)
Which of the following describes a role of the Financial Action Task Force (FATF)?
A financial institution's transaction monitoring system flags an unusually high volume of international wire transfers originating from a small business account. The transfers are being sent to multiple jurisdictions known for limited regulatory oversight. Additionally, an employee reports suspicious behavior from the account holder during an in-person visit, where they requested a large cash withdrawal without providing a clear business justification. As part of the investigation, the compliance team must assess whether this activity is suspicious and determine the appropriate next steps.
Which of the following steps should be taken first in the investigation process to properly gather information and assess whether the transactions are suspicious?
A potential client calls a broker-dealer wishing to purchase securities. The client does not appear to be concerned with any fees associated with the account or price of the securities. Further information provided by the potential client indicates the individual may have relatives working for a company in which the potential client wants to invest. Which type of activity is the potential client attempting to commit?
When investigating an AML event, which techniques would be used to investigate suspected mule accounts? (Select Three.)
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?
Who has the ultimate responsibility within a bank for ensuring that the bank has a comprehensive and
effective Bank Secrecy Act / anti-money laundering (BSA/AML) program and oversight framework that is
reasonably designed to ensure compliance with applicable regulations?
In which situation can money laundering adversely affect a country’s currencies and interest rates due to launderers investing dirty funds?
What is a tool governments and multi-national bodies can use to prevent the proliferation of weapons of mass destruction?
An existing customer has changed its business scope and jurisdictions it deals with. Which are the steps the bank needs to take to manage sanctions compliance risk for this customer?
An agent of a wealthy individual residing in Country A, which is on the EU list of high-risk third jurisdictions, approaches a notary in Country B, which is in the EU. The agent wants to complete a disposal of assets recently acquired at auction by the wealthy individual through an offshore company. The agent also has a power of attorney to act on behalf of the offshore company issued by a respectable law firm from Country C, which is also in the EU. The agent asks the notary to proceed with the disposal as quickly as possible without paying any specific attention to related costs or taxes to be paid as a result of this transaction. The notary notices the intended transfer price is significantly lower than the one recorded at auction, but the agent does not want to discuss this matter and claims that it is not covered by the power of attorney.
Which red flags should the notary consider? (Select Two)
An offshore company is owned by four equal partners that reside in separate jurisdictions. One partner presents an authenticated power of attorney apparentlyexecuted by the remaining three partners in his favor and requests that a bank account be opened on behalf of all partners. He needs this done quickly because there is a large deposit pending. The account-opening officer contacts the bank's anti-money laundering officer for advice. Which of the following should the anti-money laundering officer advise as an initial step?
What is a key objective of the Egmont Group?
What is acore function of a Financial Intelligence Unit (FIU)as described inFATF Recommendation 29?
What kind of person should perform the independent testing of an institution’s anti-money laundering program?
Which of the following are important AML controls for a compliance manager of a regulated asset management company in the European Union to implement? (Select Two.)
What describes the Black Market Peso Exchange money laundering method?
When using virtual assets such as Bitcoin to finance terrorism, which tactic may be used to ensure that the virtual assets are not easily seized by law enforcement?
During a law enforcement investigative interview regarding potential money laundering, the suspect starts
making assertions and statements that the investigator believes are false.
How should the investigator respond?
In order to demonstrate commitment to AML compliance within a bank, the Board of Directors should:
Which of the following facilitates law enforcement agents obtaining evidence from authorities in a foreign country relating to criminal activity?
When deficiencies are identified in the Financial Action Task Force (FATF) mutual evaluation report, the assessed country needs to:
A financial institution in a jurisdiction with currency reporting thresholds is undergoing a branch office compliance review. A large number of currency transactions in amounts exceeding a reporting threshold were discovered without a currency transaction report (CTR) being filed. The transactions were handled by the same teller (cashier). This teller (cashier) was recently hired and had not received anti-money laundering training yet. The branch manager received daily exception reports of all large currency transactions as well as a report of all CTR filings. Which of the following should the compliance officer recommend as the initial action?
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?
During an ongoing investigation into a client's activities by a competent authority, a compliance officer should
An internal investigation log is primarily intended to:
Which is an indicator that there is an attempt to conceal a company's true beneficial ownership?
Outgoing foreign transactions of similar amounts trigger a monitoring alert for a customer's accounts. During the evaluation of the accounts, the bank discovers the wire transfers were very small amounts and occurred within the last 3 months following a long period of inactivity. The wire transfers appear to originate from legal sources. To assess the potential of terrorist financing, the institution must ensure the
A bank’s transaction surveillance system triggers an alert for a deposit of 250.000 USO into a client's account. According to the bank's KYC information, the client works for afinancial advisory firm, and earns approximately 100,000 USD per year. Which actions should be taken? (Select Three.)
File the suspicious transaction immediately to the financial intelligence unit.
According to the Financial Action Task Force (FATF) Recommendation 22. when involved in customer transactions that include the buying and selling of real estate, real estate professionals are required to apply which customer due diligence (CDD) measures? (Select Two.)
Themanager of a bank’s KYC teamdiscovers that ahigh-risk customer’s activity was not reviewed last quarteras required by the bank’s internal compliance schedule.
What should the KYC team manager do?
Whichsection of the USA PATRIOT Actrelates toforfeiture of funds and allows for extraterritorial reach?
An organization’s automated surveillance system identifies large fluctuations in customer activity. As a result of
an audit, the compliance officer is informed that the system is not generating alerts when activity is
consistently abnormal over a long period of time. Currently the organization is evaluating new alert scenarios
in an attempt to address this problem.
Which type of scenario is helpful in mitigating this weakness?
A new customer has just been onboarded in a securities firm. After a few weeks, there are unusual trading patterns that are being flagged. Which pattern is most concerning to the compliance officer?
What are two requirements for monitoring and reporting suspicious activity for correspondent banking
according to the Wolfsberg Principles? (Choose two.)
Aninternational bankis investigating apayment requested by a correspondent banking partner. The payment originated from acorporation located in Hong Kong, and the final beneficiary is anindividual in New York. The transaction triggered an alert in the bank’sautomated transaction monitoring system.
Which steps should the bank take first to address the alert? (Select Three.)
Which regulation regarding data privacy has to be considered while carrying out a financial crime investigation?
Which two methods have terrorist groups used to diversify their revenue stream and to fund their operations?
(Choose two.)
To what extent should senior management and the Board of Directors be involved in the filing of any STR?
Which statement about U.S. Specified Unlawful Activities (SUA) is true?
Which financial crime risks are inherent to e-commerce platforms? (Select Four.)
A customer comes into a financial institution and deposits a large amount of cash. He has never done that before. When asked about the deposit, he indicates he recently sold a used car and received cash.
He does not trust forms of payment and is wary of counterfeit money orders. What should the bank do?
Which of the options below is an indicator of potential insider activity that may warrant escalation For further investigation?
Which test should be included in a bank's Office of Foreign Assets Control sanctions screening audit program?
Which is a red flag for funds transfers?
Which should a financial institution implement in order to identify and investigate money laundering activity from their clients? (Select Two.)
In which of the following situations would it be most crucial for the designated AML compliance officer of a company to perform a complete review of the company's AML program, including identifying the risks and commensurate controls?
Which of the following is a key consideration for a global organization when managing AFC and sanctions compliance across multiple jurisdictions?
Which two factors assist a money laundering investigation that involves multiple countries? (Choose two.)
Which two actions should Financial Intelligence Units (FIUs) take when submitting a request to another FIU? (Choose two.)
An auction house dealing in fine art and antiques sells a well-known painting at a price of $12 million to an agent bidding for a group of local investors. The same painting sold ten years prior at auction for $5 million. The auction house receives payment for the painting via wire transfer from an account maintained in an offshore jurisdiction by the investor group. No beneficial ownership information is available for the account.
What are the two money laundering red flags? (Choose two.)
After a FATF mutual evaluation process, which are resulting actions for jurisdictions that are determined to have strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing? (Choose two.)
UN sanctionsare themost effective and legitimate non-violent multilateral toolsto respond tointernational security threatswhen they:
A compliance officer is developing an anti-money laundering program for a financial institution located in a Financial Action Task Force member country. The institution conducts business with customers located in countries/jurisdictions that are not members of Financia Action Task Force. Which of the following issues should be addressed in the program?
1. The requirement to identify the beneficial owners of accounts.
2. The requirement for customer identification for the opening of new accounts.
3. The financial institution's obligation to report suspicious transactions.
4. The obligation to freeze funds involved in suspicious transactions.
Which private banking situation requires due diligence actions to be implemented according to the AML principles of the Wolfsberg group?
A Trust and Company Service Provider (TCSP) providing services should have policies and procedures in place to identify critical information of the:
Client A is flagged for a high volume of outgoing transfers. Further investigation reveals Client A has a potentially key role in a network linked to human trafficking. After filing a suspicious activity report, what step should the investigator take next?
AnAML compliance officeris drafting plans toaddress deficiencies identified in an independent audit.
Which approach is thebest option?
Thegoal of the Egmont Group of Financial Intelligence Units (FIUs)is to provide aforum for FIUsto: (Select Three.)
Which statement is true regarding the FATF standards for SARs/STRs information sharing within a financial group?
Which of the following is a critical consideration for private sector firms when sharing data and intelligence to combat financial crime?
According to the 5th EU Money Laundering Directive, member states require entities to apply enhanced customer due diligence measures with respect to business relationships or transactions involving high-risk third country nationals. Which are included in these requirements? (Choose three.)
A bank maintains a number of United States (U.S.) dollar correspondent accounts for foreign financial institutions. Upon a routine review of a U.S. dollar correspondent account owned by Foreign Bank A, a number of transactions appear to have been originated by Foreign Bank B outside the expected activity for this account. These transactions appear suspicious and a suspicious transaction report was filed by the compliance officer.
Which step should the compliance officer take?
A financial institution files a suspicious transaction report on a customer as the result of a high volume of large currency deposits to pay off a loan. A law enforcement officer calls the anti-money laundering officer to discuss the suspicious transaction report. Which of the following is the anti-money laundering officer legally permitted to do?
1. Discuss any aspects of the reported activity.
2. Provide copies of the customer's loan documents.
3. Explain the customer's loan payment history.
4. Send the deposit documents referenced in the suspicious transaction report.
Which are red flags indicating potential engagement of a bank employee in money laundering? (Select Two.)
AFinancial Intelligence Unit (FIU)in a country receives aSARinvolving potential money laundering. The FIU wants toshare this information with a foreign FIU.
Which mechanism allowssecure information sharingbetween FIUs?
Which is a FATF characteristic used to assess a country's effectiveness of its AML regime?
An international bank is headquartered in Madrid, Spain, with an office in New York City (NYC), US. The Madrid office is investigating a transaction originating from a customer of the NYC office and inquires whether the NYC office can share any relevant further information on the individual. Upon further research, the NYC office finds that they have filed a Suspicious Activity Report (SAR) on the individual in the previous year.
Which factors need to be considered before sharing the requested information? (Select Two.)
Which measure to mitigate risk does the Basel Committee’s Customer Due Diligence Principles suggest banks apply when accepting business from non-face-to-face customers?
A legal instrument which is executed between two nations and governs cross-border information sharing Is known as a.
Who meets the standard to perform the AML audit? (Select Two.)
A bank has opened a new account for a well-known attorney to manage client funds. During the first six months, bank staff observe the account receives multiple deposits via wire transfer. They also observe that the attorney withdraws cash, makes payments to various people, and transfers funds to the law firm’s account online.
What is considered a red flag for potential money laundering in this situation?
Why should a financial institution (Fl) require an update of its AML risk assessment?
The Financial Action Task Force recommends the incorporation of some measures in customer due diligence programs including:
Which scenariobest justifies why a financial institution (FI) might close a customer’s account?
According to guidelines issued by Basel Committee on Banking Supervision relating to corporate governance principles for banks, what is the role of the board of directors in addressing an institution's AML oversight and governance?
Following a recent exercise which explained how a correspondent banking operation could be used by money launderers, an anti-money laundering specialist decided to re-write the due diligence procedures for entering into agreements with foreign financial institutions. Which of the following information should be included to establish a rigorous "Know Your Respondent" procedure?
1.Respondent's management, nature of license, and major business activity.
2. Computer equipment and software capability.
3. The quality of supervision in the home country.
4. Respondent's location, in particular the existence of a real physical presence.
The owner of a local retail store makes multiple deposits daily at a bank. When the owner makes these deposits, it is noted that he goes to different tellers (cashiers). The deposits consist of cash in amounts less than the currency reporting threshold. Which of the following best describes this activity?
Potential indicators of money laundering associated with Trust and Company Service Providers include: (Select Two.)
A prospective client walks into an accounting firm wanting to incorporate a company. The accountant feels uncomfortable after the meeting. Which two of the accountant's observations warrant escalation to the compliance officer? (Select Two.)