When should new business products to evaluated for AML concerns?
A. After they have been implemented so there is empirical data to review
B. Before they are launched into the market
C. At the time of the next enterprise risk assessment
D. On an annual basis
A compliance officer is looking to update an institution's private bank procedures. What should be included as recommended by the Wolfsberg AML Principles on Private Banking?
A. Approval of Politically Exposed Persons (PEPs) by at least one person other than the relationship manager
B. Dedicated automated AML monitoring of client activity
C. Review of client files annually if there are unusual transactions
D. The institution's senior management has primary responsibility for the relationship
What kind of person should perform the independent testing of an institution's anti-money laundering program?
A. A certified specialist in the anti-money laundering field
B. A former anti-money laundering officer from a similar institution
C. A person who reports directly to the Board of Directors or a Board Committee
D. A retired government regulator or federal law enforcement officer
What is suspicious activity or red flag with regard to a customer's activity? Choose 3 answers
A. Paying the tellers he deals with a regular gratuity
B. Exchanging small denomination bills for large ones
C. Engaging in wire transactions with an offshore account
D. Asking about the bank's fee schedule for a series of transactions
An anti-money laundering specialist working at a bank just received a legal request from a law enforcement agency mandating the release of all financial transaction records relating to an account at the bank. The specialist immediately recognizes the account as one owned by the bank Chief Executive Officer's brother. During research to gather the requested documents, the specialist finds several internal memos he had sent to the bank president with concerns regarding possible suspicious activity relating to this account. The specialist recalls the bank president verbally responded to each memo with an explanation of the activity and indicated there was no cause for concern. What should the specialist do with respect to these internal memos?
A. Place these memos in his personal files in case they are subsequently requested
B. Ask the bank president to document his instructions to the specialist
C. Call the law enforcement agent and suggest he modify the legal request to include these memos
D. Advise the bank's senior legal advisor ofthe situation
Which customer transaction with a securities dealer would indicate the highest suspicion of money laundering?
A. Frequent trades in unlisted securities throughout the day on a regular basis
B. Recurring transfers of money into a brokerage account subsequently invested in short-term securities
C. A high level of account activity with very low levels of securities transactions
D. Investment in securities with a significantly lower risk than the customer's expressedrisk tolerance
An anti-money laundering specialist has just developed and implemented an anti-money laundering program. What is the most effective resource to evaluate the effectiveness of the program?
A. The regulatorauthorities
B. A member of senior management
C. The anti-money laundering specialist
D. A qualified independent party/auditor
An anti-money laundering officer for a financial institution has been conducting a monthly self- assessment.
The officer reviews the accounts increase in compliance with a long standing know your Customer policy. The self-assessment for the latest month shows a significant increase in compliance deficiencies for the first time in more than a year.
What is the nest course of action for the anti- money laundering officer to take?
A. Inform the Board of Directors promptly of the Know Your Customer policy trend over the last six months.
B. Determine if there is a readily identifiable cause for the deficiencies
C. Implement a revision to the account-opening training program
D. Revise the policy to simplify Know Your Customer compliance before the report is issued
What are three indicators of money laundering associated with using electronic funds transfers? Choose 3 answers
A. Funds transfers to or from a financial secrecy haven without an apparent business reason
B. Regular and frequent transfers from the account of a large company said to be payment for goods bought on credit
C. Funds transfers are received or sent from the same person to or from different accounts
D. Payment or receipts with no apparent link to legitimate contracts, goods or services
A quarterly review is conducted on a retail customer's account at a bank located in a jurisdiction with currency reporting thresholds. A number of large deposits of financial instruments drawn on other institutions in amounts under thresholds were noted. This activity did not fit the account's historical profile. A suspicious transaction report will most likely be filed if what also occurred?
A. The customer has defaulted on a large loan with the bank
B. The deposited financial instruments were sequentiallynumbered
C. Four deposits were made during this period that exceeded the thresholds
D. The customer purchased financial instruments exceeding the threshold on three occasions
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