What must be materially true regarding transactions for United States (U.S.) sanctions laws to have jurisdiction?
A. Transactions are traced to illegal proceeds
B. Transactions are processed by a U.S. person
C. Transactions are stripped of beneficial owner information
D. Transactions are identified as proceeds of foreign corruption
How does the Financial Acton Task Force (FATF) communicate its findings regarding jurisdictions with strategic anti-money laundering / Counter Financing of Terrorism deficiencies?
A. By issuing documentation to the private sector
B. By issuing two formal documents three times per year
C. By issuing informal communication to FATF members
D. By issuing four formal documents to the deficient jurisdictions
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. Audit management
B. Human Resources
C. Business line managers
D. Designated board committee
A corporate services provider in a European Union (EU) country has a prospect from an African country who deals in oil and gas. The prospect intends to develop an oil terminal in his home country with a $75 million dollar loan secured by a third party, which is a trust formed in a Caribbean island with a holding company based in a European secrecy haven. A young lady is presented as an ultimate beneficial owner who has gained her wealth through a fitness studio in her home country.
What are two red flags that could indicate money laundering or financing terrorism? (Choose two.)
A. A loan worth $75 million with a third-party guarantor
B. The guarantor company's ownership structure is overly complex
C. The prospect wishes to have a corporate structure with a holding company in EU country
D. The ultimate beneficial owner is young lady who has gained her wealth through a small business
Under which two circumstances may law enforcement be given access to a financial institution customer's financial records? (Choose two.)
A. If the person is named in a suspicious transaction report
B. If law enforcement serves a legal summons or subpoena
C. If the investigation of a customer is made public in the media
D. If law enforcement has circumstantial evidence to suspect money laundering
Findings from a regulatory examination report states that the job descriptions of personnel outside of the compliance department do not include references to anti-money laundering responsibilities. Which action should the firm take?
A. Update all job descriptions to include anti-money laundering responsibilities
B. Respond that only compliance personnel have anti-money laundering responsibilities
C. Send an email to all staff stating that personnel must observe the anti-money laundering policy
D. Reply that a description of anti-money laundering responsibilities is included in the annual training
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?
A. Senior management
B. Board of directors
C. Business line managers
D. BSA/AML compliance officer
A compliance officer provides an overview of the bank's anti-money laundering program to a group of new tellers during employee orientation. Which training element should be delivered to this audience?
A. Results of recent risk assessments
B. Large cash transaction reporting procedures
C. The financial institution's surprise cash audit policy
D. Past check fraud losses incurred by the financial institution
Which red flag indicates high potential for money laundering in a real estate purchase?
A. The purchaser is a nominee
B. The purchaser had a previous bankruptcy
C. The purchaser owns a cash intensive business
D. The purchaser is not a resident where the property is located
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. With a one-time event conducted at initial customer onboarding
C. As an ongoing activity that may vary commensurate with the risk profile of the customer
D. As applicable to customers that pose higher money laundering or terrorist financing risk
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