When investigating an AML event, which techniques would be used to investigate suspected mule accounts? (Choose three.)
A. Reconcile the stated purpose of the account with actual transaction history and compare with peer groups.
B. Determine if the suspected accounts are being accessed by a common person, telephone number, or device.
C. Contact the appropriate law enforcement agency and report the account activity.
D. Review the account history and determine if there are previous payments to charity accounts.
E. Establish the frequency in which the funds are moved in and out of the accounts.
F. Submit a SAR/STR to the national Financial Intelligence Unit (FIU).
What person or group is ultimately responsible for the institution's AML/CFT Program?
A. The AML audit committee
B. The AML/CFT Compliance Officer
C. The Chief Executive Officer (CEO)
D. The Board of Directors
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.
Which risks could an employee face for violations of AML/CFT laws and regulations? (Choose three.)
A. Being designated as a Politically Exposed Person (PEP)
B. Being named on a government sanctions list
C. Fines and imprisonment
D. Being placed on FATF greylist
E. Expulsion from the Wolfsberg Group
F. Loss of employment
Which steps should a financial institution (FI) take after receiving a request from law enforcement to keep an account open due to a criminal investigation? (Choose three.)
A. Inform the customer that the account is under investigation by law enforcement.
B. Ask for written documentation of the request.
C. Freeze the account to prevent the customer from transfering the funds out.
D. Maintain documentation of such requests for at least five years after the request has expired.
E. Ensure that the request indicates the duration for the request.
F. File a SAR/STR based on the law enforcement request.
A company service provider in Country A sets up a corporate structure for a client from Country B, which is known for corruption. The corporate structure includes a holding company in Country A with a bank account in one of the international banks located there.
During on-boarding, the client's wealth was estimated at $7.52 million. Shortly thereafter, the client's father became president of Country B. During a routine client review two years later, it was identified that client's wealth had grown to $510 million.
What are two red flags that indicate money laundering or financial terrorism? (Choose two.)
A. The client's account has not been reviewed for two years.
B. The client is from a country known for corruption.
C. The client is a family member of a PEP from a country known for corruption.
D. The substantial growth in wealth during a short period of time.
E. The holding company is in Country A with a bank account in one of the international banks.
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.
Which is a key role of FATF-Style Regional Bodies (FSRBs)?
A. Support the system of mutual evaluation
B. Setting regional standards for combatting money laundering
C. Bring additional terrorist financing laws into action in the region
D. Enforce the specific FATF laws in the region
When implementing a risk-based approach related to casinos, which risks are related to the customer as an individual? (Choose two.)
A. Transfer between customers
B. Casual customers
C. Improper use of third parties as customers
D. Customer from a high-risk country
E. Use of casino deposit accounts by the customer
A financial institution (FI) is being investigated for possible money laundering. When cooperating with law enforcement agencies, which additional steps should the FI ensure are taken? (Choose two.)
A. Centralized control is maintained over all requests and responses to ensure completeness and timely responses.
B. Make employees, including corporate officers, unavailable for interviews and refuse documents upon receipt of a subpoena.
C. Subpoenas and other information requests should be reviewed by senior management and an investigations group or counsel.
D. Address the document destruction policy to ensure the relevant documents are destroyed.
E. Inquiries from the media are not answered directly, but rather are addressed by replying, "No comment."
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