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| Section | Weight | Objectives |
|---|---|---|
| Topic 1: Detecting and Preventing Financial Crime | 20% | - Investigations and enforcement
|
| Topic 2: Money Laundering and Terrorist Financing Concepts | 30% | - Global AML/CFT standards
|
| Topic 3: AML Compliance Framework | 25% | - Compliance program components
|
| Topic 4: Risk Management and Due Diligence | 25% | - Transaction monitoring and reporting
|
1. In the context of terrorist financing, which of the following are potential indicators of the abuse of non-profit organizations (NPOs)? (Choose two.)
A) Frequent changes in leadership and mission statements
B) Extensive transparency in financial reporting and governance practices
C) Operating in high-risk jurisdictions with limited oversight
D) Large and unaccounted cash donations from anonymous sources
E) Involvement in community development and humanitarian aid projects
2. What are the rules imposed by the Office of Foreign Assets Control (OFAC) for legal entities and persons related to the US? (Select Two.)
A) A foreign individual visiting the US for a short vacation is obligated to follow OFAC rules.
B) Any foreign corporation is also penalized if it conducts transactions with sanctioned countries under OFAC rules.
C) The head office of a foreign legal entity which has a branch in the US does not need to comply with OFAC rules.
D) A subsidiary of a legal entity of the US, which is formally registered in a foreign country, is exempt from OFAC rules.
E) Nationals of the US must comply with OFAC rules, regardless of where they are located in the world.
3. Section 319(a) of the USA PATRIOT Act:
A) Provides the U.S. Department of Treasury with the authority to apply graduated, proportionate measures against a foreign jurisdiction, foreign financial organization, type of international transaction, or type of account.
B) Allows the appropriate federal banking agency to require a financial organization to produce, within 120 hours, records or information related to the organization's AML compliance or related to a customer of the organization or any account opened, maintained, administered, or managed in the U.S. by the financial organization.
C) Permits the U.S. Government to seize funds from a correspondent bank account in the U.S. that has been opened and maintained for a foreign bank in the same amount as has been deposited with the foreign bank.
D) Requires due diligence, and in certain situations enhanced due diligence (EDD), for foreign correspondent accounts, which includes virtually all account relationships that organizations can have with a foreign financial organization and private banking for non-citizens of the U.S.
4. The Basel Committee on Banking Supervision published guidelines on the "Sound management of risks related to money laundering and financing of terrorism." With regard to identifying and accepting customers, it recommends that banks: (Select Two.)
A) Establish policies and procedures for customer due diligence that vary based on risk.
B) Are prohibited from offering numbered accounts to customers, even if procedures are established to gather and maintain due diligence information.
C) Establish policies and procedures to identify and verify customers, beneficial owners, and any individuals that can transact on behalf of their customers.
D) Establish policies and procedures to ensure due diligence activities are identical for all customers.
E) Establish policies and procedures that encourage processing transactions while due diligence information is being established and verified.
5. A compliance officer at a large bank has been tasked with investigating a series of unusual transactions involving a long-time customer. The customer has made several large cash deposits into multiple accounts within a short period, raising red flags. After gathering and analyzing transaction data, reviewing customer records, and cross-referencing external sources, the compliance officer determines that there is a reasonable suspicion of money laundering. As part of documenting this investigation, the compliance officer must decide how and when to escalate the matter internally and whether to file a suspicious activity report (SAR). What is the next critical step in this process?
A) Document the customer's transaction history and keep the investigation confidential until further suspicious activity is detected.
B) Report the investigation to external auditors and await further guidance before taking any action.
C) Draft a SAR that includes a detailed chronology of the transactions, customer background and the rationale for suspicion, and submit it to the relevant financial intelligence unit (FIU) within the regulatory timelines.
D) Immediately escalate the case to senior management, recommending the closure of the customer's accounts due to potential reputational risk.
Solutions:
| Question # 1 Answer: C,D | Question # 2 Answer: B,E | Question # 3 Answer: C | Question # 4 Answer: A,C | Question # 5 Answer: C |
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