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. The new account deposit is $25.5 million
B. A corporate account is opened on behalf of several beneficial owners
C. The compliance officer receives the query regarding the movement of funds
D. The customer's stated investment goal is not reflective of account activity
The vice president of the foreign correspondent banking department at a large United States bank has been notified that a foreign bank with an offshore license wants to open a correspondent account. Which two things must the vice president acquire under the USA PATRIOT Act? (Choose two.)
A. A list of all the customers of the correspondent bank
B. A list of the types of businesses served by the correspondent bank
C. Information relating to the foreign bank's anti-money laundering program
D. The identity of 10% owners of the correspondent bank, unless it is publicly traded
What are two legal risks of having inadequate privacy policies and procedures? (Choose two.)
A. Diminished reputation
B. Industry of regulatory sanctions
C. Charges of deceptive business practices
D. Higher marketing and public relations costs
Which method to launder money through deposit-taking institutions is closely associated with international trade?
A. Forming a shell company
B. Using Black Market Peso Exchange
C. Structuring cash deposits withdrawals
D. Investing in legitimate business with illicit funds
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
What should countries do to help prevent non-profit organizations from being abused for the financing of terrorism according to the Financial Action Task Force 40 Recommendations?
A. Allow for freezing assets of non-profit organizations
B. Require all non-profit organizations to register with the country's financial intelligence unit
C. Ensure non-profit organizations cannot be used to conceal or obscure the diversion of funds intended for legitimate purposes to terrorists' organizations
D. Create laws that forbid non-profit organizations from completing cross-border transactions without first running them through known terrorist data bases
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. Change procedures to require that the necessary information is obtained
B. Change procedures and systems as necessary and provide employee training
C. Send a notice to customers asking them to provide the necessary information
D. Change systems to ensure the required information is automatically obtained from all customers
An anti-money laundering audit identifies a significant weakness in how transaction monitoring alerts are cleared. Audit sampling identified potentially suspicious activity that was cleared as not suspicious. Management accepts the audit finding and develops a remediation plan.
What is the role of the auditor during the correction phase?
A. Directing the remediation of the deficiency in a timely manner
B. Developing procedures to provide sufficient risk-based documentation for clearing alerts
C. Providing training to the alert clearing department on the importance of effective alert clearing
D. Validating the successful remediation of the issue once management indicates the issue is resolved
What poses the greatest money laundering risk for a financial institution offering on-line services to customers?
A. There is a greater difficulty in matching the customer with the provided identification documentation
B. There is a lack of humanreview of the customer's transactions
C. Institutions offering on-line services have no possibility to properly verify the identity of their customers
D. Customers have direct access to their accounts without being detected
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
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