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C - ANSWER-The USA PATRIOT Act was passed in: A) 1970 B) 1985 C) 2001 D) 2007 D - ANSWER-The three stages of money laundering are: A) Lay... [Show More] ering, Placement, Refining B) Placement, Refining, Integration C) Refining. Integration, Layering D) Integration, Layering, Placement D - ANSWER-Which of the following would be satisfactory elements of an Anti-Money Laundering Program? I - A CAMS certified employee in the Investigations Unit writes up a few policies and procedures and posts them on the department bulletin board. II - Shortly after attaining their CAMS certification, the individual provides AML training to the Investigations Unit. III - The CAMS certified individual routinely reviews the work of the Investigations Unit. IV - The CAMS certified individual assumes the responsibility of a compliance watchdog. A) All of the above would be satisfactory B) II and IV would be satisfactory C) I and III would be satisfactory D) None of the above would be satisfactory The correct answer would be "D - None of the above would be satisfactory." I - The AML program must be approved by the Board of Directors. II - An AML training program is required of all personnel (and contractors). III - The review of the bank's Financial Intelligence Department, as part of the audit of the AML program, must be performed by an independent (and knowledgeable) party. IV - The Compliance Officer must be appointed by the Board of Directors (or upper management with the Board's approval). D - ANSWER-In determining what risks a customer poses, which consideration should NOT be a major factor? A) Where the customer resides or where the business is headquartered. B) What is the size of your financial institution. C) What occupation or type of business does the customer derive their income from. D) What are the customer's ethnic heritage, sexual orientation and political beliefs. The correct answer would be "D." The customer's ethnic heritage, sexual orientation and political beliefs are more discriminatory factors, and while they may help frame the context of certain transactions, they should not be a major factor in assessing risk. The size of your financial institution is a critical element in determining the level of sensitivity to risks for certain customers. Analysis questions require one to synthesize information, arrive at solutions and/or evaluate the usefulness of solutions. One needs to distinguish between facts and assumptions and to put various knowledge parts together to form a new knowledge component or solution to a problem. While this is also an important part of being a professional, it comprises only about 23% of the exam. B - ANSWER-In general, the three phases of money laundering are said to be: Placement: A. Structuring and manipulation. B. Layering and integration. C. Layering and smur ng. D. Integration and in ltration. A - ANSWER-Which of the following is the most common method of laundering money through a legal money services business? A. Purchasing structured money instruments. B. Smuggling bulk-cash. C. Transferring funds through Payable Through Accounts (PTAs). D. Exchanging Colombian pesos on the black market. A - ANSWER-Which statement is true? A. Bust-out schemes are popular in creating large bankruptcy frauds where businesses secure increasing loans in excess of the actual value of the company or property and then run with the money, leaving the lender to foreclose and take a substantial loss. B. Cuckoo smur ng is a signi cant money laundering technique identi ed by the Financial Action Task Force, where a form of structuring uses nested accounts with shell banks in secrecy havens. C. In its 40 Recommendations, the FATF issued a list of "designated categories of offense" that asserts crimes for a money laundering prosecution. D. E-cash is not attractive to the money launderer because it cannot be completely anonymous and does not allow for large amounts to be "transported" quickly and easily. BCD - ANSWER-Which three of the following is an indication of possible money laundering in an insurance industry scenario? A. Insurance products sold through intermediaries, agents or brokers. B. Single-premium insurance bonds, redeemed at a discount. C. Policyholders who are unconcerned about penalties for early cancellation. D. Policyholders who make full use of the "free look" period. AC - ANSWER-Which two activities are typically associated with the black market peso exchange (BMPE) money laundering system? A. Converting illicit drug proceeds from dollars or Euros to Colombian pesos. B. Converting illicit drug proceeds from Colombian pesos to dollars or Euros. C. Facilitating purchases by Colombian importers of goods manufactured in the United States or Europe through peso brokers. D. Facilitating purchases by European or U.S. importers of goods manufactured in Colombia through peso brokers. D - ANSWER-What is the Right of Reciprocity in the eld of international cooperation against money laundering? A. The legal principle that nancial institutions that have referred customers to other nancial institutions can share information about these customers with the other institutions. B. A rule of the Basel Committee allowing properly regulated nancial institutes of another member state of the Basel Committee to do business without additional supervision to the degree that the other state grants the same right. C. The right of each FATF member country to delegate prosecution of a case of money laundering to another member that is already investigating the same case. D. A rule in the law of a country allowing its authorities to cooperate with authorities of other countries to the degree that their law allows them to do the same. C - ANSWER-The greatest risk for money laundering is for casinos that A. Provide their customers with a wide array of gambling services. B. Operate in a non-Egmont member country. C. Allow customers with credit balances to withdraw funds by check in another jurisdiction. D. Only send suspicious transaction reports to the nancial intelligence unit of the country it operates in. B - ANSWER-Which statement is true regarding the risk of Politically Exposed Persons (PEPs)? A. PEPs provide access to third parties on whom the nancial institution has not conducted suf cient due diligence. B. PEPs have signi cantly greater exposure to the politically corrupt funds, including accepting bribes or misappropriating government funds. C. PEPs are foreign customers who inherently present additional risk as they are engaged in cross-border transactions. D. PEPs generally do not pose enhanced risks to an institution due to their political standing; rather, PEPs increase the prestige of an institution. B - ANSWER-Dirty money, derived from criminal activities of Belgian Criminal A, is sent to a foreign bank account of Corporation B. Then in Belgium, a new investment Company C is incorporated. Criminal A is appointed as a director of Company C. Company C borrows money from the foreign Company B and buys real estate in Belgium. The real estate is rented to third parties. Director (Criminal) A also rents an apartment in the building. With the funds generated by the rent, Company C pays off the loan to Corporation B, and the salary of Director A. Criminal A now converted his dirty money in legal funds. This laundering method is commonly referred to as what? A. Offsetting real estate transactions. B. Loan back. C. Cuckoo smur ng. D. Loan manipulation. ACD - ANSWER-A new customer approaches a bank to open a commercial account. The customer provides an address for the account located across the city from the branch. When asked by the account representative if the customer requires any additional banking services, the customer responds she is also interested in opening a personal investment account. The account representative refers the customer to their broker-dealer. The customer tells the rm representative she has never had a brokerage account before and has a few questions about how an investment account works. The customer asks how deposits can be made into her account, if there are any reporting requirements, and how to go about moving balances out of the account using wire transfers. No questions are asked about fees associated with these transactions. Which three items would be considered suspicious? A. The customer asks many questions about the brokerage account, but none of them are related to investing. B. The customer is opening a commercial account and at the same time a personal investment account. C. The address of the account holder and the branch where the customer came to open the account are not close to each other. D. That the customer appears unconcerned about the fees. A - ANSWER-International trade in goods and services can be used as either a cover for money laundering or as the laundering mechanism itself. What is MOST important for the launderer when engaging in this method? The ability: A. To over- or under-invoice the goods. B. To sell the exported goods for as much as possible. C. To use goods that do not need to be declared. D. To use high-value assets such as luxury cars or boats. C - ANSWER-Which of the following statements is true? Correspondent banking is MOST vulnerable to money laundering when the correspondent account is: A. Maintained for foreign nancial institutions that are banks. B. Not used to provide services directly to third parties. C. Maintained for a foreign bank that does not have a physical presence in any country. D. Maintained for a foreign private bank that is publicly traded and is a quali ed intermediary. D - ANSWER-Which statement is true? Lawyers: A. In FATF member countries can generally not be used to serve as formation agents to set up trusts, front companies or shell companies. B. And similar professional "gatekeepers" are called money services businesses. C. Can generally not be used to act as a nominee shareholder for a bene cial owner. D. Can be abused by launderers by using the accounts they set up for them for the placement and layering of funds. A - ANSWER-The Third EU Money Laundering Directive of 2005 applies to which of the following rms? A. Auditors, estate agents based in the EU. B. U.S. Financial institutions covered by the USA Patriot Act. C. Shell rms inside and outside the EU. D. EU based high value good dealers who deal in cash of 10,000 Euro or more. C - ANSWER-According to the EU Directives of 2001, an independent legal professional is obligated to report suspicion of money laundering in a client relationship when: A. Representing a client in a legal matter. B. Ascertaining the legal position for a client. C. Participating in nancial or corporate transactions. D. Obtaining information associated with a judicial proceeding. A - ANSWER-Which of the following is the most dif cult regulatory challenge facing a foreign nancial institution with a correspondent banking relationship in the U.S.? A. USA Patriot Act. B. Basel Due Diligence Principles for Banks. C. FATF Guidance on Terrorist Financing. D. UN Security Council Resolution on Correspondent Banking. CD - ANSWER-Which were the Basel Committee's two main motivations to encourage strong Know Your Customer programs in its paper "Customer Due Diligence for Banks?" A. A.Mirror FATF's KYC Recommendations. B. Meet European Union guidelines. C. Protect the safety and soundness of banks. D. Protect the integrity of banking systems. B - ANSWER-What is the de nition of a predicate offense? A. Lawful or unlawful activity that involves willful blindness, and if there is an international element to the crime, can lead to a suspicious activity report. B. Unlawful activity whose proceeds, if involved in the transaction, can give rise to prosecution for the crime of money laundering. C. An interface which is the underlying segment of a suspicious transaction monitoring system. D. A speci ed unlawful activity that is committed through concentration accounts deceiving customers that are not directly related to the account. B - ANSWER-What is considered a bene cial owner of an account? A person or entity: A. That has direct signatory authority over an account, and whose name appears on the account. B. That is ultimately entitled to the funds in the account, even though his name may not appear on the account. C. That is the originator and the destination of most (but not all) transactions conducted within the account, but who does not ultimately control such funds. D. That is a gatekeeper, has the legal title to the account, and typically transfers the funds to a trust. B - ANSWER-A bank in Italy holds a business account for an Italian company that sells gold throughout Europe and the Western Hemisphere. The bank knows the purpose of this account is to receive payment for sales. A review of the account shows a pattern of wire transfers coming from payable-through accounts. There is also a pattern of purchases of gold bullion held in Swiss banks. The MOST important factor in assessing whether money laundering is a threat is that the: A. Customer sells gold in regions where it carries an important or religious signi cance that adds to the high intrinsic value. B. Payments come from third-party accounts. C. Payments received are in the form of wire transfers instead of cash. D. Account holder maintains gold bullion rather than nished pieces of jewelry. ABC - ANSWER-Which of the following should a national legislature consider when criminalizing money laundering in line with the CFATF 19 Recommendations (choose three)? A. Do not limit the number of speci c predicate offenses for money laundering. B. Criminalize conspiracy or association to engage in money laundering. C. Indicate whether it is relevant that a predicate offense may have been committed outside the local jurisdiction. D. Require money laundering offenses to prove that the offender has actual knowledge of a criminal connection to the funds. ACD - ANSWER-Which three statements are true about the 3rd EU Directive on Money Laundering of 2005? It: A. A.Was proposed in order to update European Community legislation in line with the Financial Action Task Force (FATF) 40 Recommendations. B. Largely replicates the de nitions included in the Second Directive, including the de nition of a politically exposed person. C. Repeats the main customer due diligence requirements of the rst and second Directives, but adds more detail to the requirements by, for example, including a speci c requirement to identify the bene cial owner if one exists and includes ongoing monitoring requirements. D. Requires rms to apply the customer due diligence requirements to existing customers at appropriate times on a risk sensitive basis. D - ANSWER-The FATF 40 Recommendations say that countries should: A. Not allow bearer shares and legal persons that are able to issue bearer shares. B. Gather statistics on STRs; prosecutions and convictions; on property frozen, seized and con scated; and on mutual legal assistance, but not necessarily on other international requests for co- operation. C. Consider the feasibility of a system where banks and other nancial institutions and intermediaries would report currency transactions without indicating a minimum xed amount. D. Not approve the establishment or accept the continued operation of shell banks. C - ANSWER-Among the Principles for Information Exchange Between Financial Intelligence Units for Money Laundering Cases, issued by the Egmont Group on June 13, 2001, we nd which of the following? A. Information-sharing agreements must be drafted according to a model issued by the Egmont Group. B. Information-sharing agreements should not allow room for case-by-case solutions to speci c problems in case of NCCT countries. C. Information exchanged between FIUs may be used only for the speci c purpose for which the information was sought or provided. D. The requesting FIU may make use of the information shared by a disclosing FIU for administrative purposes without the prior consent of the disclosing FIU. C - ANSWER-In which stage of money laundering would you classify depositing small amounts of cash into several related accounts? A. Integration. B. Structuring. C. Placement. D. Construction. A - ANSWER-In which stage of money laundering would you classify the use of laundered funds to purchase high value assets and luxury items? A. Integration. B. Structuring. C. Placement. D. Construction. D - ANSWER-In most laws criminalizing money laundering, it is stated that: A. Financial institutions are not responsible for money laundering or suspicious transactions taking place within their accounts until the government places the customer on a watch list. B. Tipping off (telling customers that their accounts/ transactions are under investigation because of suspicion) is not punishable. C. The dirty money undergoing money laundering will not be con scated because of privacy laws. D. Employees of nancial institution who intentionally ignore clear signs of money laundering may be punished with imprisonment and/or nes. D - ANSWER-The tactic in which individuals make multiple deposits in small quantities to avoid detection is called: A. Paralleling. B. Integration. C. Investing. D. Structuring. C - ANSWER-In which case might a Suspicious Transaction Report NOT be necessary? A. A customer who deposits money of suspicious origins and refuses to answer questions from the nancial institution's staff. B. A customer who tries to move money that is suspected of being derived from criminal activity. C. A customer who owns a large supermarket and deposits large amounts of cash several times a day. D. A customer whose account is showing transaction activities which are beyond his known nancial capability. A - ANSWER-As part of their role in ghting money laundering, nancial institutions should: A. Designate a compliance of cer. B. Depend solely on The State's staff for combating money laundering. C. Refuse small cash deposits under the reporting threshold. D. Not open accounts for people from high risk jurisdictions. B - ANSWER-What could happen to compliance of cers if they do not comply with the anti-money laundering laws and regulations? A. Their employers could face reputation damage, but the employee is immune from penalty. B. Loss of job, prison penalties and nes, negative reputation to their employer. C. Nothing. Only the nancial institution's legal counsel will be responsible for complying with laws. D. Nothing. Only the staff directly handling transactions have to worry. C - ANSWER-What is willful blindness de ned as? A. Failing to le a Suspicious Transaction Report for dealing with companies or nancial institutions from offshore tax havens. B. Not following customer identi cation procedures as set out in the institution's procedures. C. Deliberate avoidance of knowledge of the facts or ignoring obvious money laundering red ags. D. Deliberate avoidance of a customer based on the assumption that his or her behavior suggested a potential threat as money launderer and/or terrorist. A - ANSWER-In anti-money laundering terminology a "red ag" is: A. A warning sign used to bring attention to potentially suspicious, risky transactions or activities. B. A general banking term used once the balance is negative / overdue. C. The standard ag of countries not cooperative in ghting money laundering and terrorist nancing. D. An indicator that a customer is listed on an economic sanctions list. C - ANSWER-The Reporting Of cer of a nancial institution should: A. Report everything that comes his way from anyone in the organization. B. Report everything that comes his way from senior management or Board of Directors. C. Review available information related to the customer, transactions, pro le, history and le a Suspicious Transaction Report for only those customers where a suspicion of money laundering exists. D. Report only what the Reporting Of cer's superior agrees should be reported. C - ANSWER-Which of the following statements is true? A. Credit cards are not likely to be used in the layering phase of money laundering because of restrictions in cash payments. B. Credit cards are effective instruments for laundering money because the transactions do not create an audit trail. C. A launderer can launder money by prepaying his credit card using funds that are already in the banking system, creating a credit balance on his account, and requesting a credit refund. D. A launderer can use illicit funds that are already in the banking system to pay his credit card bill for goods purchased, which is an example of placement. A - ANSWER-Why is a Payable Through Account vulnerable to money laundering? A. These are master correspondent accounts that allow the customers of the foreign bank to do a wide range of transactions. B. These are correspondent accounts located in a non- cooperative country or territory. C. These are nested correspondent accounts at a foreign shell bank with customers with whom the domestic bank did not exercise due diligence. D. These are master escrow accounts on which a domestic bank generally does not conduct periodic veri cation. B - ANSWER-What is the reasoning behind implementing a "risk-based anti-money laundering approach"? A. It will keep the regulators focused on money laundering controls in sectors beyond banks. B. Institutions can best use their limited resources to focus on matters where the money laundering risks are highest. C. A quantitative approach will generate better results than a qualitative approach. D. It allows the institution to focus on selling products that have a better return on investment. A - ANSWER-According to the FATF 40 Recommendations, "designated non- nancial businesses and professions" include: A. Casinos, real estate agents and dealers in precious stones. B. Money service businesses, gatekeepers, and issuers of electronic money. C. Dealers in precious metals, lawyers, commodity futures traders. D. Life insurance companies, real estate agents and notaries. C - ANSWER-According to the FATF 40 Recommendations, the threshold for identifying occasional customers at nancial institutions is: A. EURO/US$ 5,000. B. EURO/US$ 10,000. C. EURO/US$ 15,000. D. EURO/US$ 20,000. B - ANSWER-Tom works as a compliance of cer at ABC Bank. He is looking at the transactions of one of the bank's customers, Mr. Brown, the owner of a check cashing company. Over the last six months, Mr. Brown has not made withdrawals of cash against check deposits. He also deposited two checks for US$2,000 each that were issued by a casino. When checking the KYC le, Tom sees that, when opening the account, Mr. Brown had requested detailed information about fees and commission that are charged by the bank. What should arouse Tom's suspicion the most? Mr. Brown: A. Deposited checks from casinos. B. Did not make withdrawals of cash against check deposits. C. Showed uncommon curiosity about commissions and fees charged. D. Does not have an escrow account. A - ANSWER-A small broker-dealer has an AML compliance program that addresses procedures for ling Suspicious Transaction Reports and includes policies, procedures and internal controls for customer identi cation, monitoring accounts and identifying money laundering red ags. Every employee of the broker dealer is trained via the Internet in January and in July on AML issues. The board does not take the Internet training. Instead, the compliance of cer organizes a luncheon for them where an outsider comes in and trains them. The program provides for the appointment of a compliance of cer, and once a year the compliance of cer conducts an audit to test the program. In what respect does the program need improvement? A. The AML program should be tested by an independent person, not the compliance of cer. B. The AML program should be tested more than once per year. C. The board should receive the same training provided to the employees. D. Employees should not be trained via the Internet, because classroom training is better. D - ANSWER-Susan works as a senior Money Laundering Reporting Of cer at XYZ Bank. She is taking a closer look at the activity of several customers. What would arouse her suspicion the MOST? A. A customer who owns several check cashing companies in town and rents safe deposit boxes at different branches. B. A customer who avoids taking vacations. C. A small business that provides nancial statements which are not prepared by an accountant. D. A customer involved in investment management who guarantees a very high rate of return, well above what other competitors can offer. A - ANSWER-Which of the following best describes the "alternative remittance system"? A. The transfer of values between countries, outside of the legitimate banking system. B. A non-electronic data remittance system used in several NCCT countries to report suspicious activities. C. Old-fashioned reporting requirements commonly used in non-cooperative countries and territories. D. The transfer of funds between two or more nancial institutions using concentration accounts. D - ANSWER-An AML compliance of cer was reviewing customers at XYZ Bank and one of the customers (Mr. Sam Tropicana) attracted her attention. Through a period of several months, cash deposits and withdrawals were transacted through his account with amounts ranging between US $7,500 and US $17,000. In addition, Sam deposited two checks, issued by a casino into his account for US $32,000 each. When opening the account, Sam stated that he operated an import/export company. Which of the following additional items should arouse the suspicion of an anti-money laundering compliance of cer the most? A. Sam maintained a personal account as well as the business account. B. Sam's home telephone number was disconnected last month. C. Sam asked for a letter of credit to nance some imports from a new supplier. D. Sam conducted large cash transactions for his import/ export business. ABD - ANSWER-Which three of the following statements are true? A. Online gambling provides an excellent method of laundering because transactions are conducted primarily through credit or debit cards and the sites are typically unregulated offshore rms. B. An institution can know when a credit card is used for online gambling transactions because the cards rely on codes that illustrate the type of transactions. C. Online gambling provides an excellent method of laundering because it lends itself to any type of cash movement and there is no face-to-face contact with the customer. D. Some banks no longer allow the use of credit cards for online gambling transactions. A - ANSWER-What are the three key goals of an anti-money laundering program? A. Prevent and detect money laundering and terrorist nancing; report suspicious activity to proper authorities if the laws or regulations require it; train all pertinent employees. B. Satisfy regulatory requirements; report suspicious activity to proper authorities if the laws or regulations require it; train all pertinent employees. C. Train all pertinent employees if the laws require it; prevent money laundering; prevent terrorist nancing. D. Reduce regulatory burdens; help the court systems in convicting money launderers; protect the institution A - ANSWER-An anti-money laundering specialist is employed by a large bank. An account owner is well-known to the specialist and the account has been open at the bank for several years. The specialist noticed that nancial instruments have been deposited in a suspicious manner over the last four months, leading him to le two Suspicious Transaction Reports (STRs) on the account. Recently, suspicious activity involving high-risk countries has been detected over the last few days. Various law enforcement agencies have called to discuss the STRs with the specialist. The specialist has asked the agents whether they think the relationship with the customer should be terminated. These agents advised that this a business decision for the bank to make. The specialist has kept the legal advisors and upper management apprised of the activity and has provided them copies of the STRs. Which of the following should the specialist recommend? A. Terminate the relationship with this account owner if possible. B. Monitor the account for continued suspicious activity. C. Contact the account owner again about the nature of suspicious transactions. D. Seek guidance from regulators regarding a decision to terminate the account. A - ANSWER-The FATF has consistently noted the use of casinos in money laundering schemes in its annual typologies reports. One laundering technique involving casinos is: A. Asking for winners' checks to be made out in the name of third persons or without a payee. B. Abusing casinos by circumventing its gatekeepers. C. Prepaying a casino token or chip by using funds that are already in the casino system, creating a debit balance. D. Extensive gambling via multiple games throughout the casino. C - ANSWER-Which of the following should an anti-money laundering specialist include on an internal investigation log? A. A government order on a customer that garnishes his wages for failure to pay child support. B. Supporting documentation and materials for denying service to a client with a bad credit rating. C. Notes pertaining to activity that is unusual, but for which a Suspicious Transaction Report has not been led. D. Reference to a memorandum to the company's corporate management relating to budgetary and similar concerns. A - ANSWER-What are the three key criteria in AML risk rating? A. Customer type, geographic location, products and services used. B. Geographic location, customer type, employment status. C. Products and services used, customer type and prior banking relations. D. Employment status, customer type, products and services used. C - ANSWER-A nancial institution is looking to establish an online account opening service. The institution plans to offer this product to new and existing customers within the country. Which of the following would be the best plan of action for an AML specialist to recommend enabling the institution to verify the customer's identity? A. Do not offer the product, as it is too high risk as the customer cannot be seen to verify their identity. B. Require all customers to send a copy of valid photo identi cation to the institution. C. Ensure that the institution has a reliable third party source that will enable veri cation of the customer. D. Allow customers to enter required information, but require all customers to come to the institution in person for veri cation. B - ANSWER-Which of the following controls would most effectively minimize the need to correct failures to collect required customer information in the account opening process? A. A quality review staff that checks paper applications to ensure all elds are complete. B. An automated account opening platform that requires data entry prior to allowing the account to be opened. C. Requiring that a manager review and approve all new account applications. D. Documenting a procedure that sets forth the steps required to open an account. A - ANSWER-When conducting training for AML purposes for account opening staff, which of the following addresses the most important aspects to consider in the training? A. What the employees need to do, the importance of AML efforts and the penalties for non-compliance. B. The governmental AML bodies, what the employees need to do and the importance of AML efforts. C. The penalties for non-compliance, the governmental AML bodies, and what employees need to do. D. The importance of AML efforts, the governmental AML bodies and the penalties for non-compliance. A - ANSWER-When drafting an AML policy, which of the following internal parties is most important to have approve the policy? A. Senior management. B. The audit department. C. The sales team management. D. The operational staff management. D - ANSWER-Suzy is an AML compliance of cer at an institution that is looking to open treasury management services (e.g., wires, check clearing, foreign draft issuance) for correspondent banking customers. Which of the following should Suzy be most concerned about regarding the institution's capabilities regarding these customers? A. Whether the new account systems will be able to handle customers with foreign names. B. Whether the correspondent accounts will be approved by government regulators. C. Whether the correspondent accounts will be able to provide evidence of their customers' identities at account opening D. Whether the correspondent accounts will be able to be monitored by the institution's monitoring systems. A - ANSWER-John is an AML compliance of cer at a nancial institution that is looking at an electronic KYC tool to facilitate the account opening process. Which of the following aspects would be most useful for John to consider when assessing vendors providing the tools? A. How well can the vendor work with the institution's existing account systems and account opening processes? B. Can the vendor provide training on how to use the new tool? C. Can the tool prevent fraudulent accounts from being opened? D. Can the tool provide alerts to the AML compliance staff when it nds a match with a customer in a jurisdiction with inadequate AML controls? C - ANSWER-A customer wants to establish a sizable relationship with a nancial institution. The AML of cer is not comfortable with the client's explanation for the source of the funds, but the client manager is vouching for the client and is eager to open the relationship quickly. What should the AML of cer do to validate the client's sources of funds? A. Accept the client manager's approval of the client. B. Allow the account to be opened but be sure to monitor the account activity. C. Perform a background investigation to determine whether the client's source of funds is credible. D. Decline the account. C - ANSWER-An AML compliance officer is investigating unusual activity that she has noticed in a customer's accounts. The customer has a retirement account, a savings account in trust for his son, a joint checking account with his wife, a company checking account and an individual brokerage account. The compliance of cer believes the customer may be embezzling funds from his business. Which is the best path for her to follow up on her suspicions? A. Focus on the checking accounts, as the checking accounts allow the fastest movement of funds. B. Ignore the savings and brokerage accounts, as these are not used in the placement stage of money laundering. C. Look at the movement of funds in all the accounts, as the customer may be using all of them to launder money. D. Focus on the business account, as the customer is embezzling money from the company. D - ANSWER-About an hour before closing time, a construction worker comes to a financial institution and wants to provide cash in exchange for sending money abroad. It is the middle of summer and the customer indicates that he's been outside for the bulk of the day and needs to send money to a family member who is in another country. Which of the following would be considered the biggest concern with the customer and his request? A. The customer is sweating; probably because he is nervous due to the fact he's trying to launder narcotics proceeds. B. The customer is sending money to a relative in a high- risk foreign location. C. The customer seems slightly distracted when asked questions by the nancial institution's staff. D. The customer is not able to provide a reasonable response as to the source of the funds. A - ANSWER-A customer at a brokerage firm indicated that he was primarily a conservative, long-range investor. The customer has recently been engaging in day trading in penny stocks. What should an AML compliance of cer do in such a situation? A. Check with the account of cer to see if the customer has indicated a change in his investment strategy. B. Report the customer as suspicious due to investing in penny stocks. C. Contact the customer and ask why he is engaged in high-risk day-trading activity. D. Refer the customer for senior management for approval. C - ANSWER-A financial institution branch manager who has been in place for over ten years has not taken a vacation for almost four years. The company does not allow employees to roll vacation over from year to year. An AML compliance of cer has noticed unusual activity in several accounts at the branch location. What should the AML of cer do? A. Insist that the manager take a vacation, as not taking one is a red ag. B. Report the manager to authorities for engaging in suspicious activity. C. Determine whether the manager has engaged in transactions in the accounts where the unusual activity has occurred. D. Conduct a background check to see if the manager has been convicted of criminal activity. D - ANSWER-An AML compliance of cer is looking to establish a suspicious activity reporting process at her small institution. Which of the following would be the best course of action? A. Allow employees to refer suspicious activity directly to the government authorities to le as quickly as possible. B. Have employees refer all unusual activity to the internal independent audit department to assess whether the activity should be reported. C. Have employees refer all unusual activity to senior management to ensure they are aware of all unusual activity within the organization. D. Have employees refer all unusual activity to her so that she may conduct an investigation into what needs to be reported to authorities. B - ANSWER-In general, the three phases of money laundering are said to be: Placement: A. Structuring and manipulation. B. Layering and integration. C. Layering and smur ng. D. Integration and in ltration. A - ANSWER-Which of the following is the most common method of laundering money through a legal money services business? A. Purchasing structured money instruments. B. Smuggling bulk-cash. C. Transferring funds through Payable Through Accounts (PTAs). D. Exchanging Colombian pesos on the black market. A - ANSWER-Which statement is true? A. Bust-out schemes are popular in creating large bankruptcy frauds where businesses secure increasing loans in excess of the actual value of the company or property and then run with the money, leaving the lender to foreclose and take a substantial loss. B. Cuckoo smur ng is a signi cant money laundering technique identi ed by the Financial Action Task Force, where a form of structuring uses nested accounts with shell banks in secrecy havens. C. In its 40 Recommendations, the FATF issued a list of "designated categories of offense" that asserts crimes for a money laundering prosecution. D. E-cash is not attractive to the money launderer because it cannot be completely anonymous and does not allow for large amounts to be "transported" quickly and easily. BCD - ANSWER-Which three of the following is an indication of possible money laundering in an insurance industry scenario? A. Insurance products sold through intermediaries, agents or brokers. B. Single-premium insurance bonds, redeemed at a discount. C. Policyholders who are unconcerned about penalties for early cancellation. D. Policyholders who make full use of the "free look" period. AC - ANSWER-Which two activities are typically associated with the black market peso exchange (BMPE) money laundering system? A. Converting illicit drug proceeds from dollars or Euros to Colombian pesos. B. Converting illicit drug proceeds from Colombian pesos to dollars or Euros. C. Facilitating purchases by Colombian importers of goods manufactured in the United States or Europe through peso brokers. D. Facilitating purchases by European or U.S. importers of goods manufactured in Colombia through peso brokers. D - ANSWER-What is the Right of Reciprocity in the eld of international cooperation against money laundering? A. The legal principle that nancial institutions that have referred customers to other nancial institutions can share information about these customers with the other institutions. B. A rule of the Basel Committee allowing properly regulated nancial institutes of another member state of the Basel Committee to do business without additional supervision to the degree that the other state grants the same right. C. The right of each FATF member country t [Show Less]
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ACAMS Practice Test (Book) with Complete Solutions
Which of the following is the most common method of laundering money through a legal money services business? - ANSWER-Purchasing structured money instrume... [Show More] nts In general, the 3 phases of money laundering are said to be: Placement; - ANSWER-Layering and integration Which statement is true? - ANSWER-Bust-out schemes are popular in creating large bankruptcy frauds where businesses secure increasing loans in excess of the actual value of the company or property and then run with the money. Leaving the lender to foreclose and take a substantial loss Which 3 of the following is an indication of possible money laundering in an insurance industry scenario? - ANSWER--Single-premium insurance bonds, redeemed at a discount -Policyholders who are unconcerned about penalties for early cancellation -Policyholders who make full use of the "free look" period Which 2 activities are typically associated with the black market peso exchange (BMPE) money laundering system? - ANSWER--Converting illicit drug proceeds from dollars or Euros to Colombian pesos -Facilitating purchases by Colombian importers of goods manufactured in the United States or Europe through peso brokers What is the Right of Reciprocity in the field of in the field of international cooperation against money laundering? - ANSWER-A rule in the law of a country allowing its authorities to cooperate with authorities of other countries to the degree that their law allows them to do the same The greatest risk for money laundering is for casinos that - ANSWER-Allow customers with credit balances to withdraw funds by check in another jurisdiction Which statement is true regarding the risk of Politically Exposed Persons (PEPs)? - ANSWER-PEPs have significantly greater exposure to the politically corrupt funds, including accepting bribes or misappropriating government funds Dirty money, derived from criminal activities of Belgian Criminal A, is sent to a foreign bank account of Corporation B. Then in Belgium, a new investment Company C is incorporated. Criminal A is appointed as a director of Company C. Company C borrows money from the foreign Company B and buys real estate in Belgium. The real estate is rented to third parties. Director (Criminal) A also rents an apartment in the building .With the funds generated by the rent, Company C pays off the loan to Corporation B, and the salary of Director A. Criminal A now converted his dirty money in legal funds .This laundering method is commonly referred to as what? - ANSWER-Loan back A new customer approaches a bank to open a commercial account. The customer provides an address for the account located across the city from the branch. When asked by the account representative if the customer requires any additional banking services, the customer responds she is also interested in opening a personal investment account. The account representative refers the customer to their broke-dealer. The customer tells the firm representative she has never had a brokerage account before and has a few questions about how an investment account works. The customer asks how deposits can be made into her account, if there are any reporting requirements, and how to go about moving balances out of the account using wire transfers. No questions are asked about fees associated with these transactions. Which three items would be considered suspicious? - ANSWER-The customer asks many questions about the brokerage account, but none of them are related to investing. The address of the account holder and the branch where the customer came to open the account are not close to each other. That the customer appears unconcerned about the fees. International trade in goods and services can be used as either a cover for money laundering or as the laundering mechanism itself. What is MOST important for the launderer when engaging in this method? The ability: - ANSWER-To over-or under-invoice the goods. Which of the following statements is true? Correspondent banking is MOST vulnerable to money laundering when the correspondent account is: - ANSWER-Maintained for a foreign bank that does not have a physical presence in any country. Which statement is true? Lawyers: - ANSWER-Can be abused by launderers by using the accounts they set up for them for the placement and layering of funds. The Third EU Money Laundering Directive of 2005 applies to which of the following firms? - ANSWER-Auditors, estate agents based in the EU. According to the EU Directives of 2001, an independent legal professional is obligated to report suspicion of money laundering in a client relationship when: - ANSWER-Participating in financial or corporate transactions. Which of the followings is the most difficult regulatory challenge facing a foreign financial institution with a correspondent banking relationship in the U.S.? - ANSWER-USA Patriot Act Which were the Basel Committee's 2 main motivations to encourage strong Know Your Customer programs in it's paper "Customer Due Diligence for Banks? - ANSWER--Protect the safety and soundness of banks -Protect the integrity of banking systems What is the definition of a predicate offense? - ANSWER-Unlawful activity whose proceeds, if involved in the transaction, can give rise to prosecution for the crime of money laundering What is considered a beneficial owner of an account? A person or entity: - ANSWER-That is ultimately entitled to the funds in the account, even though his name may not appear on the account A bank in Italy holds a business account for a Italian company that sells gold throughout Europe and the Western Hemisphere. The bank knows the purpose of this account is to receive payment for sales. A review of the account shows a pattern of wire transfers coming from payable-through accounts. There is also a pattern of purchases of gold bullion held in Swiss banks. The MOST important factor in assessing whether money laundering is a threat is that the: - ANSWER-Payments come from third-party accounts Which of the following should a national legislature consider when criminalizing money laundering in like with the CFATF 19 Recommendation (choose 3)? - ANSWER--Do not limit the number of specific predicate offenses for money laundering -Criminalize conspiracy or association to engage in money laundering -Indicate whether it is relevant that a predicate offense may have been committed outside the local jurisdiction Which 3 statements are true about the 3rd EU Directive on Money Laundering of 2005? it: - ANSWER--A Was proposed in order to update European Community legislation in line with the Financial Action Task Force (FATF) 40 recommendation -Repeats the main customer due diligence requirements of the first and second directives, but adds more detail to the requirements by, for example, including a specific requirement to identify the beneficial owner if one exists and includes ongoing monitoring requirements -Requires firms to apply the customer due diligence requirements to existing customers at appropriate times on a risk sensitive basis The FATF 40 Recommendations say that countries should: - ANSWER-Not approve the establishment or accept the continued operation of shell banks Among the Principles for information Exchange Between Financial Intelligence Units for Money Laundering cases, issued by the Egmont Group on June 13, 2001, we find which of the following? - ANSWER-Information exchanged between FIUs may be used only for the specific purpose for which the information was sought or provided In which stage of money laundering would you classify depositing small amounts of cash into several related accounts? - ANSWER-Placement In which stage of money laundering would you classify the use of laundered funds to purchase high value assets and luxury items? - ANSWER-Integration In most laws criminalizing money laundering, it is stated that: - ANSWER-Employees of financial institution who intentionally ignore clear signs of money laundering may be punished with imprisonment an/or fines The tactic in which individuals make multiple deposits in small quantities to avoid detection is called: - ANSWER-Structuring In which case might a Suspicious Transaction Report NOT be necessary? - ANSWER-A customer who owns a large supermarket and deposits large amounts of cash several times a day As part of their role in fighting money laundering, financial institutions should: - ANSWER-Designate a compliance officer What could happen to compliance officers if they do not comply with the anti-money laundering laws and regulations? - ANSWER-Loss of job, prison penalties and fines, negative reputation to their employer What is willful blindness defined as? - ANSWER-Deliberate avoidance of knowledge of the facts or ignoring obvious money laundering red flags In anti-money laundering terminology a "red flag" is: - ANSWER-A warning sign used to bring attention to potentially suspicious, risky transactions or activities The Reporting Officer of a financial institution should: - ANSWER-Review available information related to the customer, transactions, profile, history and file a Suspicious Transaction Report for only those customers where a suspicion of money laundering exists Which of the following statements is true? - ANSWER-A launderer can launder money by prepaying his credit card using funds that are already in the banking system, creating a credit balance on his account, and requesting a credit refund Why is a Payable Through Account vulnerable to money laundering? - ANSWER-These are master correspondent accounts that allow the customers of the foreign bank to do a wide range of transactions What is the reasoning behind implementing a "risk-based anti-money laundering approach? - ANSWER-Institutions can best use their limited resources to focus on matters where the money laundering risks are highest According to the FATF 40 Recommendations, "designated non-financial businesses and professions" Include: - ANSWER-Casinos, real estate agents and dealers in precious stones According to the FATF 40 Recommendation, the threshold for identifying occasional customers at financial institutions is: - ANSWER-EURO/US $15,000 Tom works as a compliance officer at ABC Bank, he is looking at the transactions of one of the bank's customers, Me. Brown, the owner of a check cashing company. Over the last 6 months, Me. Brown has not made withdrawals of cash against check deposits. He also deposited two checks for US$2000 each that were issued by a casino. When checking the KYC file, Tom sees that, when opening the account, Mr. Brown had requested detailed information about fees and commission that are charged by the bank. What should arouse Tom's suspicion the most? Mr. Brown: - ANSWER-Did not make withdrawals of cash against check deposits A small broker-dealer has an AML compliance program that addresses procedures for filing Suspicious Transaction Reports and includes policies, procedures and internal controls for customer identification, monitoring accounts and identifying money laundering red flags. Every employee of the broker dealer is trained via the internet in January and in July on AML issues. The board does not take the internet training. Instead, the compliance officer organizes a luncheon for them where and outsider comes in and trains them. The Program provides for the appointment of a compliance officer, and once a year the compliance officer conducts an audit to test the program. In what respect does the program need improvement? - ANSWER-The AML program should be tested by an independent person, not the compliance officer Susan works as a senior Money Laundering Reporting Officer at XYZ Bank. She is taking a closer look at the activity of several customers. What would arouse her suspicion the MOST? - ANSWER-A customer involved in investment management who guarantees a very high rate of return, will above what other competitors can offer Which of the following best describes the "alternative remittance system"? - ANSWER-The transfer of values between countries, outside of the legitimate banking system An AML compliance officer was reviewing customers at XYZ Bank and one of the customers (Mr. Sam Tropicana) attracted her attention. Through a period of several months, cash deposits and withdrawals were transacted through his account with amounts ranging between US $7,500 and US $17,000. In addition, Sam deposited 2 checks, issued by a casino into his account for US $32,000 each. When opening the account, Sam stated that he operated an import/export company. Which of the following additional items should arouse the suspicion of an anti-money laundering compliance officer the most? - ANSWER-Sam conducted large cash transactions for his import/export business Which 3 of the following statements are true? - ANSWER--Online gambling provides and excellent method of laundering because transactions are conducted primarily through credit or debit cards and the sites are typically unregulated offshore firms -An institution can know when a credit card is used for online gambling transactions because the cards rely on codes that illustrate the type of transactions -Some banks no longer allow the use of credit cards for online gambling What are the 3 key goals of an anti-money laundering program? - ANSWER-Prevent and detect money laundering and terrorist financing; report suspicious activity to proper authorities if the laws or regulations require; train all pertinent employees An anti-money laundering specialist is employed by a large bank. An account owner is well known to the specialist and the account has been open at the bank for several years. The specialist noticed that financial instruments have been deposited in a suspicious manner over the last 4 months, leading him to file 2 Suspicious Transaction Reports (STRs) on the account. Recently, suspicious activity involving high-risk countries has been detected over the last few days. Various law enforcement agencies have called to discuss the STRs with the specialist. The specialist has asked the agents whether they think the relationship with the customer should be terminated. These agents advised that this a business decision for the bank to make. The specialist has kept the legal advisors and upper management apprised of the activity and has provided them copies of the STRs. Which of the following should the specialist recommend? - ANSWER-Terminate the relationship with this account owner if possible The FATF has consistently noted the use of casinos in money laundering schemes in its annual typologies reports. One laundering technique involving casinos is: - ANSWER-Asking for winners' checks to be made out in the name of third persons or without a payee Which of the following should an anti-money laundering specialist include on a internal investigation log? - ANSWER-Notes pertaining to activity that is unusual, but for which a Suspicious Transaction Report has not been filed What are 3 key criteria in AML risk rating? - ANSWER-Customer type, geographic location, products and services used A financial institution is looking to establish an online account opening service. The institution plans to offer this product to new and existing customers within the country. Which of the following would be the best plan of action for an AML specialist to recommend enabling the institution to verify the customer's identify? - ANSWER-Ensure that the institution has a reliable third party source that will enable verification of the customer Which of the following controls would most effectively minimize the need to correct failures to collect required customer information in the account opening process? - ANSWER-An automated account opening platform that requires data entry prior to allowing the account to be opened When conduction training for AML purposes for account opening staff, which of the following addresses the most important aspects to consider in the training? - ANSWER-What the employees need to do, the importance of AML efforts and the penalties for non-compliance When drafting an AML policy, which of the following internal parties is most important to have approve the policy? - ANSWER-Senior Management Suzy is an AML compliance officer at an institution that is looking to open treasury management services (e.g., wires, checks clearing, foreign draft issuance) for correspondent banking customers. Which of the following should Suzy be most concerned about regarding the institution's capabilities regarding these customers? - ANSWER-Whether the correspondent accounts will be able to be monitored by the institution's monitoring systems John is an AML compliance officer at a financial institution that is looking at an electronic KYC tool to facilitate the account opening process. Which of the following aspects would be most useful for John to consider when assessing vendors providing the tools? - ANSWER-How well can the vendor work with the institution's existing account systems and account opening processes? A customer wants to establish a sizable relationship with a financial institution. The AML officer is not comfortable with the client's explanation for the source of the fund, but the client manager is vouching for the client and is eager to open the relationship quickly. What should the AML officer do to validate the client's sources of funds? - ANSWER-Perform background investigation to determine whether the client's source of funds is credible An AML compliance officer is investigating unusual activity that she has noticed in a customer's accounts. The customer has a retirement account, a savings account in trust for his son, a joint checking account with his wife, a company checking account and an individual brokerage account. The compliance officer believes the customer may be embezzling funds form his business. Which is the best path for her to follow up on her suspicions? - ANSWER-Look at the movement of funds in all the accounts, as the customer may be using all ofthem to launder money About an hour before closing time, a construction worker comes to a financial institution and wants to provide cash in exchange for sending money abroad. It is the middle of summer and the customer indicates that he's been outside for the bulk of the day and needs to send money to a family member who is in another country. Which of the following would be considered the biggest concern with the customer and his request? - ANSWER-The customer is not able to provide a reasonable response as to the source of the funds [Show Less]
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ACAMS Exam Practice Questions and Answers with Complete Solutions
How do drug traffickers and other criminals use the fine art industry to disguise illicit proceeds? A. They use forged or fraudulent invoicing of priceles... [Show More] s works of art by auction houses B. They commingle legitimate and illicit proceeds by principals for payment of fine art C. They immediately resell priceless works of art after purchase from a foreign auction house D. They use anonymous agents to buy the art and have the payment wired from offshore havens - ANSWER-D An anti-money laundering specialist at a large institution is responsible for informing senior management about the status of the anti-money laundering program across the organization. Which report is the most useful? A. The total credit exposure for non-cooperative countries and territories B. Results of related audits and examinations C. Details on inquiries received from law enforcement D. Notification of management changes in the different major divisions - ANSWER-B What is most valuable when using the internet as an investigative source? A. A team of AML investigators B. A reference list of websites known to yield credible information C. A combination of independent thinking and technical skills D. A powerful search engine - ANSWER-B What should senior management do in order to promote a culture of anti-money laundering compliance? A. They should include compliance with AML procedures as condition of employment B. They should attend all training sessions with front-line employment C. They should have close ties with the independent auditors of the AML program D. They should base employee compensation on the amount of suspicious activity they detect - ANSWER-A What is the result of an increased awareness of the potential for gatekeepers to assist in money laundering in recent years? A. The IMF has raised the profile of gatekeepers, requiring that countries regulate them B. Lawyers who represent money launderers can more easily be prosecuted C. Accountants are no longer considered gatekeepers, since they are not permitted to set up companies or trusts D. The FATF recommendations cover lawyers performing financial transactions - ANSWER-B Which three are principles found in the document "Principles of information Exchange between Financial Intelligence Units (FIUs)"? A. The exchange of information between FIUs should take place as informally and as rapidly as possible and with no prerequisites, while guaranteeing protection of privacy and confidentiality of the shared data B. Differences in the definition of offenses that fall under the competence of FIUs should be before free exchange of information takes place C. The Egmont principle of free exchange of information at the FIU level should be possible on the basis of reciprocity, including spontaneous exchange D. It should be possible for communication between FIUs to take place directly and without intermediaries - ANSWER-A,C,D What are three risk factors a financial institution should examine with regard to a proposed new product? A. The complexity of the product B. The need to verify the identification of the customer C. Whether the product is easily transferable D. Whether other financial institutions are marketing the product - ANSWER-A,B,C In some instances, a financial institution may receive a warrant from law enforcement authorities to search its premises. A search warrant is a grant of permission from a court for a law enforcement agency to search certain designated premises and seize specific categories of items or information. Generally, what is the required threshold for the requesting agency to establish in order to obtain a search warrant of a financial institution? A. Reasonable belief B. Probable cause C. A preponderance of the evidence D. Clear and Convincing proof - ANSWER-A Which three characteristics make non-profit organizations vulnerable to misuse for terrorist financing? A. Enjoying the public trust B. Having access to a considerable sources of funds C. Being listed as government nonprofit organization D. Having a global presence for national and international operations and financial transactions - ANSWER-A, B, D An anti-money laundering specialist at a financial institution has received a legal request to provide all transaction records for a specific individual since 2004. Which three items should be delivered? A. Monthly statements and transaction activities for that individual since 2004 B. All wire transfer for that individual since 2004 C. All security trading activities for that individual since 2004 D. Signature cards from accounts opened by that individual since 2004 - ANSWER-A,B,C How do payable through accounts (PTAs) differ from normal foreign correspondent accounts? A. The customers do not have to worry about sanctions list screening such as OFAC B. The customers have the ability to directly control funds at the correspondent bank C. The customers can contact the correspondent bank directly to send wire transfers D. The customers can hide their identity through the use of cover payments in U.S. dollars - ANSWER-A What is the term for trading through multiple accounts, where an individual generates offsetting profits and losses and transfers of positions through accounts that do not appear to be commonly controlled? A. Ponzi scheme B. Market Manipulation C. Net Trading D. Wash Trading - ANSWER-D The Wolfsberg Principles for Private Banking list circumstances that would require additional due diligence, including activities that involve which three of these choices? A. Foreign jurisdictions B. High Risk Countries, including those identified by credible sources as having inadequate Anti-Money Laundering standards C. High Risk activities, involving clients and beneficial owners whose source of wealth originates from activities known to be vulnerable to money laundering D. Public officials, including those individuals who have or had positions of public trust - ANSWER-B,C,D Which three are examples of best practices terms of ensuring an adequate AML program? A. Engage an independent party to perform a periodic review of the program B. Review applicable domestic and international AML guidance C. Perform a risk analysis on a regular basis and compare it to the coverage of the AML program D. Review the accuracy of account opening applications - ANSWER-B,C,D Which three statements are true regarding the extraterritorial reach of laws and legislation of the U.S.? A. The criminal anti-money laundering law can apply to transactions that occur partially overseas B. Economic and trade sanctions by OFAC may pose extraterritorial risks for financial institutions and businesses outside the U.S. C. The extraterritorial reach covers all transactions throughout the global economy D. The defendant does not need to know the funds came from an illegal activity under state, federal or foreign law - ANSWER-A,B,D What is a criterion for FATF membership? A. The country should be democracy B. The country should be a member of a FATF-style regional body C. The country should have already implemented all of the FATF Recommendations D. The country should have already implemented the standards of the European Union Directives - ANSWER-B According to the Second European Union Money Laundering Directive, what may knowledge of criminal conduct be inferred from? A. Subjective, factual circumstances B. Objective, factual circumstances C. Objective, non-factual circumstances D. Subjective, non-factual circumstances - ANSWER-B In which type of banking transaction is price manipulation, as a form of money laundering, a common practice? A. Redeeming an annuity B. Sending a wire transfer C. Issuing a letter of credit D. Subscribing to a cash management account - ANSWER-C Which two aspects of the security broker dealer industry increase its exposure to money laundering? Choose 2 answers A. The routine use of wire transfers from, to or through multiple jurisdictions B. They easy conversion of holdings to cash with significant loss of principal C. Disposing of cash through securities purchases D. Fast paced transactions conducted electronically - ANSWER-C,D To ensure that an institution's anti-money laundering program is current, which step should be taken? A. The program should be evaluated and updated at least every six months be the Board of Directors B. The program should be reviews by a federal law enforcement officer for gaps in controls C. The program should be sent to the institution's government regulator on a periodic basis D. The program should be reassessed at least annually - ANSWER-D A prospective AML officer comes highly recommended by a bank's up-stream correspondent institution of similar size and make-up, located in a different city in the same country. The bank is interested in hiring the individual. What should be the next step taken by the Board of Directors? A. Do a thorough background check B. Confer with its regulatory agency to determine whether it is appropriate to hire the person C. Hire the individual, relying on the recommendation of its correspondent D. Hire the individual on a probationary basis so that the institution can determine if the individual is sufficiently experienced and capable - ANSWER-A Which type of transactions present the highest risk? A. Wire transfers from a publicly listed company B. Payroll payments C. Social insurance payments D. Foreign exchanges - ANSWER-D According to experts, what is the most effective way to prevent money laundering through financial institutions? A. ensuring that transaction monitoring systems can identify terrorist financing B. collecting information on beneficial owners in foreign customers C. instituting a policy prohibiting the acceptance of funds intended for terrorist financing D. implementing a sound customer due diligence program - ANSWER-D What should a bank focus on to ensure ongoing compliance with its AML program? A. it should ensure that it develops and provides ongoing targeted training of all current and new employees B. it should subject all new employees to criminal background checks before being hired C. it should review and update its transaction monitoring system D. it should ensure that the regulators have reviewed and have approved the banks AML program - ANSWER-A What should a compliance officer do during an ongoing investigation into a clients activities by a competent authority? A. ensure communication with regulatory and law enforcement authorities is conducted only through the board of directors B. communicate only in writing regulatory in law enforcement authorities in line with applicable local laws C. communicate with regulatory and law enforcement authorities in line with applicable local laws D only provide information that is specifically and directly requested - ANSWER-A How can dealers in high value items be at risk for money laundering? A. the value of precious metals such as gold and silver is constantly fluctuating B. carrying large amounts of Jens of high value is physically easy C. paperwork is not required to ship precious metals and gems D. drug dealers prefer cash to precious metals and Jim - ANSWER-B Which activity is most likely to facilitate money laundering through online systems with inadequate controls A. conducting a large volume of transactions B. providing continuous worldwide access C. conducting anonymous transactions D. conducting large value transaction - ANSWER-B In the FATF 40 recommendations the focus on AML efforts has been expanded beyond financial institutions. which 3 businesses and or professions are covered? Choose 3 answers A. casinos when customers engage in financial transactions equal to or above a designated threshold B. Real estate agents when they are involved in transactions for clients concerning buying and selling properties C. dealers in art when they engage in any cash transaction with a customer at or above a designated threshold D. trust and company service providers - ANSWER-B, C, D When requested by law enforcement via legal process to provide records or documentation what should the officers of financial institutions do? A. provide all records and documents the officer believes would be pertinent to the law enforcement agent's investigation B. Refuse to provide any records or documents until the agent narrows the scope of the request down to what he or she actually needs C. Not act on the legal process until the bank officer has contact with the agent and learns what the agent is investigating D. if there is no basis for contesting the requeat, provide what is requested - ANSWER-C Which AML standards have force of law? A. standards as defined in the third European Union money laundering directive B. standards as defined by the united nations C. standards as defined by world bank/international monetary fund (IMF) D. 40 recommendations - ANSWER-A What are some red flags pertaining to potentially suspicious transactions by a customer? Choose 3 A. Having multiple addresses and/or moving frequently B. Having a commercial account with cash deposits C. Have a common address with several other bank clients D. Having multiple individuals use the ATM card connected with the account in different cities - ANSWER-A, C, D An anti-money laundering expert is hired by a new internet bank to assess the money laundering threat to the bank. What is the most important recommendation for the expert to make given it is an online bank? A. The bank should limit the amount of money which can be processed per transaction B. The bank should ensure that prospective new customers can be properly identified C. The bank should set up automated programs to analyze transactions for money laundering activity D. The bank should ensure that a firewall is set up to protect the transactions - ANSWER-A Why is the Mutual Legal Assistance Treaty (MLAT) a gateway for international cooperation? A. They provide a legal basis for transmitting evidence that can be used for prosecution and judicial proceedings B. They receive reports of suspicious transactions from financial institutions to disseminate to lacal law enforcementy and foreign FIUs C. They obtain intelligence that might lead to evidence D. They issue the principles of information exchange between financial intelligence units (FIUs) - ANSWER-A Which element is generally required of al anti-money laundering programs? A. A computer based suspicious activity monitoring system B. A qualified compliance officer to manage the program C. Annual in-person AML training for all employees D. An enhanced due diligence program for all new customers - ANSWER-B After an institution files an STR with regard to a particular account, a law enforcement agent requests the institution to keep the account open until adised otherwise directed by law enorcement. What steps should the institution take? A. The institution should close the account in order not to be caught in the middle of a law enforcement investigation B. THe institution should follow the request of the law enforcement agent and keep the account open C. The institution should request a written letter from the law enforcement agency signed by the appropriate authorized signature D> THe institution should keep the account open only if doing so comports with the bank's own AML procedures. - ANSWER-C A customer has held an account at a local credit institution for 1 years. The account has received deposits twice for the same amount and has never shown signs of suspect behavior. Monitoring saftware indicated that in the past few months the account has received several large deposits that were not in line with the account history. When asked, the customer states she recently sold a piece of property, which is supported with a proof of sale. What should the compliance officer do next? A. Investigate these unusual transactions further B. Contact the local FIU for advice C. File an STR with the competent authorities D. Document reasons for not filing a STR - ANSWER-C What is one recommendation of the Basel Committee's 2001 paper Customer Due Dilligence for Banks? A. Numbered accounts should not be allowed B. Certain types of private banking can be exempt from KYC procedures C. Banks should develop clear descriptions of acceptable customers D. Politically Exposed Persons (PEPs) should not be accepted as customers - ANSWER-C A remittance company received a money order from a senior political figure in the Philippines to transfer a large sum of money to a charity group in the Philippines. A review of the charity group revealed a director having close ties with a known terrorist group primarily financed through kidnapping and extortion. What is a key risk indicator associated with terrorism financing? A. The sender is a PEP and should be subject to enhanced due diligence B. A large sum sent by money order to a charity C. There is no risk relating to terrorism financing when the charity group in operating legitimately in that country D. There is a link between the charity group and a known terrorist group - ANSWER-D In performing a risk analysis, which factor(s) should a financial institution review? A. The level of its gross revenue B. Recent regulatory actions against financial institutions of comparable size C. Its customer base, location, products and services D. The adequacy and completeness of its STR filings - ANSWER-C What should law enforcement provide when asking an institution to keep an account open? A. An explanation of the underlying conduct that is being investigated B. A written request with an explanation of the scope of the investigation C. An in-person visit by an investigating official to explain why the account must remain open D. A written request on government agency letterhead with the appropriate signature - ANSWER-D Which example describes the vulnerability of the securities sector for money laundering? A. A non-US person seeks to open a brokerage account with a US broker-dealer B. A broker-dealer must have a customer identification program in place C. Broker-dealers generally have a higher percentage of inexperienced staff D. Compensation for broker-dealers is generally based on commissions - ANSWER-D Ina ddition to monitoring for suspicious activity, what are electronic monitoring systems also valuable for? A.Identifying how customers are using products B. Highlighting the skills of the system analysts C. Proving to the Board of Directors that the FIU is doing its job D. Meeting mandatory regulatory requirements for system implementation - ANSWER-D In which three situations is correspondent banking most vulnerable to money laundering? Choose 3 A. When allowing foreign banks to use the correspondent account to conduct large financial transations on behalf of their customers B. When allowing the correspondent bank account to be used as a payable through account (PTA) C. When allowing the correspondent bank account to be used by other banks D. When allowing financial institutions, without prior due dilligence, to access correspondent network for routing their financial transactions - ANSWER-A, B, C How does a regulatory body typically obtain international assistance in a money laundering inquiry? A. By filing a request under Egmont guidelines B. By submitting a request for overseas assistance to the corresponding supervisory body C. By contacting the FATF, Organization for Economic Co-operation and Development, or other international organizations ans seeking their intervention D. By communicating with the head of complinace for the financial institution - ANSWER-B Federal law requires all US financial institutions to secure and maintain all records and supporting documentation used in suspicious activity reporting for how many years? A. 2 B. 5 C. 10 D. No requirement - ANSWER-B What is a major money laundering risk associated with a number of prepaid cards as opposed to credit or debit cards? A. The risk of losing the prepaid cards B. The inability to load the card with cash C. The global access to cash through ATMs D. The anonymous access to funds - ANSWER-D An audit completed the previous week revealed that a private banking customer submitted incomplete documents when establishing an account earlier in the year. The cutomer received weekly electronic fund transfers froma narcotic-producing jurisdiction. While the relationship manager who opened the account is on leave for 5 weeks, the customer requests that the institution remit a substantial sum to a country that represents a high risk for money laundering. The relationship manager is a friend of the anti-money laundering specialist. What the anti-money laundering officer do first? A. File a suspicious transaction reprt with the competent authority B. Investigate the transfer of funds C. Suspend the transfer until the relationship manager returns D. Postpone the follow-up on the audit finding - ANSWER-A Why would a credit card account likely not be used in the placement phase of money laundering? A. Customer Identification is required B. Cash payments are generally restricted C. Credit refunds have a waiting period D. Credit cards can access ATMs globally - ANSWER-B What are some red flags financial institutions should be aware of when trying to verify the identity of a customer? Choose 3 A. Customer having unusual documents from a foreign country B. Customer being new to the community C. Customer having no permanent address D. Customer not having a connected phone - ANSWER-A, C, D A compliance officer is looking to modify procedures covering correspondent banking relationships. Which three would be recommended under the Wolfsburg Principles on Correspondent Banking? Choose 3 A. Prohibition on offering products or services to shell banks B. Risk-based rating of central and regional development banks C. Periodic risk-based reviews of cents D. Assessing the regulatory status and history of the client - ANSWER-A, C, D When an institutioon conducts an internal investigation into an account following a law enforcement inquiry, it should consider a number of factors to independently determine if the account should be closed. Which three considerations should be made when making the determination about closing an accoutn? Choose 3 A. The institution's policies and procedures for closing an account B. Oral requests by a law enforcement agency or prosecutor for the account to be closed C. signed written requests by a law enforcement agency or prosecutor on official letterhead for the account to remain open D. The level of seriousness of the underlying conduct - ANSWER-A, B, C A profitable customer who operated an import-export business has multiple accounts with the same institution at branches in different locations. The customer receives funds from a jurisdiction perceived as highly corrupt according to Transparency International ratings. The customer makes frequent transfers among the accounts and prefers to manage the accounts separately. What should the institution do to mitigate the risk associated with the accounts? A. File a suspicious transaction report B. Diminish the importance of the subjective Transparency International rating C. Cnduct a trade-once manpulation analysis D. Develop a system to monitor all the activity - ANSWER-A What should be part of an institution's monitoring and STR filing process? Choose 3 A. Review on a regular basis of all high-risk accounts and transactions B. Review of STR filing trends and typologies C. Periodic training on the identification of red flags D. Requirement that the Board of Directors approve the filing of an STR - ANSWER-A, B, C A commission rogatoire would be used in which gateway to obtain information from another country? A. An FIU request under the Egmont principles B. An MLAT C. A supervisory channel request with the Basel Committee D. A FATF request - ANSWER-A The purpose of an anti-money laundering program should be to do what? A. Detect all illegal activity perpetrated by customers B. Avoid criticism and sanctions from government regulators C. Focus monitoring efforts on riskier transaction and customers D. Detect and report cash structuring and suspicious transactions - ANSWER-C What facilitates law enforcement agents obtaining evidence from authorities in a foreign country relating to criminal activity? A. MLAT B. Patriot Act communications system C. The World Wide Network of Information Sharing D. MLAT Executive Agreement - ANSWER-A Which three entities does the Third European Union Money Laundering Directive apply to? A. Financial institutions B. Defense attorneys C. Casinos D. Real Estate Agents - ANSWER-A, C, D Which two statements about the Wolfsburg Group are true? A. It is composed of representatives of financial intelligence units from around the world B. It focuses primarily on Know Your Customer, AML, and CTF guidance C. It based its original guidance combating the laundering of proceeds of narcotics trafficking D. It has no power to impose its principles/guidance - ANSWER-B, D After evaluating recent changes to international standards, an anti-money laundering specialist should consider enhanced due diligence on accounts held by which three groups of people? A. Lawyers B. Foreign Exchange Dealers C. Retail Account Holders D. Precious metal dealers - ANSWER-A, B, D Which of the following is the most common risk with a Personal or Private Investment Company (PIC)? A. They are almost always owned by politically exposed persons B. They are usually established in financial secrecy havens C. They often lack transparent ownership D. They are not publicly traded - ANSWER-C Pursuant to the Third European Union Money Laundering Directive, how long after being out of prominent office should a person NOT be considered to be a Politically Exposed Person (PEP)? A. 1 year B. 2 years C. 3 years D. 4 years - ANSWER-A Which method most likely indicates the placement stage of money laundering dirty money in a land based casino? A. Transferring substantial amounts of money from a client's credit card to a client's VIP account B. Buying casino chips against a bank draft C. Redeeming smaller denomination casino chips for largest denomination chips D. Using cash to buy casino winnings from legitimate winners at a premium - ANSWER-D A compliance officer at a small local bank reads in the newspaper that a high ranking local public official, who is a long-standing account holder, is being investigated by the competent authorities for accepting bribes. The compliance officer immediately checks the official's account and new account the official opened at the bank a few weeks ago. The compliance officer's investigation of these accounts discloses that the official's long-standing account had no unusual activity and that the recently opened had no activity since it was opened. What should the compliance officer do next? A. Wait until the new account receives funds and confirm their source B. Call the competent authorities to assess the need to file a suspicious transaction report C. Meet with staff who opened the account to understand its nature and purpose D. Call the office to confirm the need for multiple accounts - ANSWER-B What is a key element required to ensure an anti-money laundering compliance program is effectively embedded into an institution's culture? A. An internal audit B. Ongoing Training C. Peer review D. A record retention policy - ANSWER-B In 2004, COnsolidated KYC Risk Management was issued by the Basel Committee on Banking SUpervision (BCBS). What is a key message in thie document? A. KYC Risk Management required a yearly consolidation effort B. KYC RIsk Management means an established decentralized process for promulgating policies and prodedures C. Policies and procedures should be designed not merely to comply strictly with all relevant laws and regulations D. Consolidated KYC risk management for a group is critical and trumps jurisdictional rules that limit information sharing - ANSWER-D In order to protect investigative material from disclosure when conducting an internal investigation of any employee of a financial institution, legal counsel of that financial_________________? A. Request formal company authorization to conduct the investigation. Such authorization should be granted, if possible, by the board of directors or audit committee B. Refuse to provide any records or documents to law enorcement because the bank has client privelege with its bank customers C. Let the bank hire any and all contract investigators to conduct the internal investigation. That way legal is not a party to the action and may remain independent D. Not mark files or documents with priveleged and confidential: Attorney-Client Privelege and/or Work-Product. THose marks will only encourage law enforcement opposing attorneys to seize those files - ANSWER-A Which situation is the highest risk for money laundering and terrorist financing activity? A. A customer purchases casino chips, using small denomination bank notes, but does not engage in game play before redeeming the chips for a casino check B. A customer purchases casino chips and engages in significant game play before requesting a casino check for the remainder C. A customer purchases casino chips using a credit card and engages in minimal game play before redeeming the chips for a casino check D. A customer purchases casino chips using credit from an account at an affiliated casino and engages in significant game play before redeeming the chips for a casino check - ANSWER-C The marketing department presents a business plan targeting individuals holding important public positions. What are some steps the financial institution should implement as part of the plan to target such individuals? A. Investigate the source of funds B. Determine the purpose of the account C. Deermine if the client appears on the Basel Committee on Banking Supervision's list of public officials D. Take all resaonable steps to check the background of the individual based on public information - ANSWER-A, B, D The board of directors and the senior management of a financial institution should ensure that which three are established and followed with regard to an effective AML program? A. There is a strong compliance program B. International guidance is followed and understood C. They are kept informed of all major AML issues D. Regulatory compliance is made part of all relevant job descriptions - ANSWER-A, C, D What is operational risk? A. THe potential for loss of public confidence in an organization's integrity B. The potential for loss resulting from too much credit or loan exposure to one borrower C. The potential for loss due to inadequate processes, people, systems, or external events D. The potential for law suits, fines, and penalties increasing an organizations's expenses - ANSWER-C How should a financial institution deter money laundering through new accounts? Choose 3 A. Document the identity of the party opening the account B. Query owner's names against FATF database C. Determine the beneficial owner(s) of the account D. Seek to determine the source of deposited funds - ANSWER-A, C, D What are the European Union Directives on Money Laudering? A. They are voluntary codes of best practice for the financial sector B. They are written by the Wolfsberg Group C. They require members to implement certain laws to prevent money laundering D. They require financial institutions to report suspicious activity to the Egmont Group in Brussels - ANSWER-C Why do government entities around the world believe that a risk-based approach to AML/CFT compliance is a preferable prescriptive measure? A. It is easier for examiners to make subjective criticisms B. It is more flexible, effective, and proportionate C. It allows institutions to focus their attention on only high risk customers D. It allows the creation of hard and fast rules that must be followe - ANSWER-B When providing reporting of STRs to the board, which of the following should be provided? A. A numerical summary of all the STRs B. A numerical summary of all the STRs and a summary of key STRs, including PEPs, key employees C. A summary fo all key STRs, including PEPs, and key employees D. All the STRs filed with the national FIU - ANSWER-C Why do trusts established in certain offshore jurisdictions make good vehicles to lanuder money? A. Names of the settlor and beneficiaries are not publicly available B. Trusts are typically set up to minimize taxes C. Offshore jurisdictions are unfamiliar with trusts D. Trusts may hold assets of significant size - ANSWER-D What are some of the methods for sharing information and cooperating on an international basis? Choose 3 A. Mutual Assistance Legal Treaties B. International Money Laundering Information Network C. Regulatory sharing through Supervisory Channels D. Issuant subpoenas - ANSWER-A, B, C What are three indicators of money laundering associated with using electronic finds transfers? Choose 3 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 - ANSWER-A, C, D 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 the 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 occured? A. The customer has defaulted on a large loan with the bank B. The deposited financial instruments were sequntially numbered C. Four deposits were made during this period that exceeded the trhresholds D. The customer purchased financial instruments exceeding the threshold on three occasions - ANSWER-B 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 - ANSWER-A What is suspicious activity or red flag with regard to a customer's activity? Choose 3 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 - ANSWER-A, B, C 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 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 of the situation - ANSWER-D 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 expressed risk tolerance - ANSWER-C 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 regulator authorities B. A member of senior management C. The anti-money laundering specialist D. A qualified independent party/auditor - ANSWER-D 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 next course of action for the anti-money laundering officer to take? A. Inform the Board of DIrectors promptly of the KYC 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 trainng program D. Revise the policy to simplify KYC compliance before the report is issued - ANSWER-C To guard against acquisition or control of a financial institution by money launderers and their associates, what should supervisory agencies require? A. Adequate surety bonds, cash deposits, or equivalencies B. Comprehensive compliance programs C. Prospective owners have prior experience in the area of finance D. Thorough due diligence on prospective owners - ANSWER-D What is one of the indicators of a Black Market Peso Exchange? A. A wire transfer from a third party not connected with a transaction B. A large deposit of pesos converted into US dollars C. A transfer of US dollars to Central or South America to be converted into pesos D. An illegal entity that exchanges pesos for US dollars for illegal immigrants - ANSWER-A What are some of the useful tools or methods in conducting an internal AML investigation? Choose 3 A. Reviewing documents, particularly of relevant accounts B. Interviewing knowlegeable employees of the institution C. Subpoenaing the owners of the relevant accounts D. Exploring leads through internet searches - ANSWER-A, B, D What should an effective anti-money laundering training program include? A. Computer-based modules titled differently for each job description in the bank B. Random testing of employees to ensure proper understanding of policies C. Real-life money laundering examples D. Lists of anti-money laundering regulations - ANSWER-C When should new business products be 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 - ANSWER-B 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 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 - ANSWER-A Which action should be taken regarding a particular account once suspicious activity is reported by the institution? A. Notify the client that the transaction has been reported B. Freeze the funds pending notification from the competent authority C. Secure all supporting documentation D. Immedialtely close the account - ANSWER-C 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 human review 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 - ANSWER-A Which action should an FIU consider taking when it has information that might be useful to another FIU? A. In accordance with Wolfsberg guidelines, submit the information to the other FIU in written form B. Supply the information to the other FIU spontaneously as soon as the relevance of sharing the information is identified C. Take no action until contacted by the other FIU D. Request approval from the Egmont Group prior to sharing the information with the other FIU - ANSWER-B Which statement is true about banking regulatory agencies having the authority to obtain information from regulated institutions? A. The regulatory agencies may only obtain information from the regulated institution's books and records by virtue of a search warrant B. A search warrnat may be substituted by a court subpoena compelling the institution to produce the information to the regulatory agency C. The agencies authority to conduct examinations negates the need for a warrant or subpoena D. If a regulatory agency intends to prosecute a regulated institution, a warrant or subpoena must first be granted before the information can be obtained - ANSWER-C When and how should an institution appraise the AML risk of a newly developed product? Choose 3 A. The institution should request the Compliance Officer to review and evaluate the AML risk prior to the product going live B. The institution should roll the product out on a preliminary basis to determine what risks develop with regard to the product C. The institution should review the previous administrative actions to determine [Show Less]
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