A customer has held an account at a local credit institution for 10 years. The account has received deposits twice weekly for the same amount and has never shown signs of suspect behavior. Monitoring software 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
What do Financial Action Task Force (FATF)-style regional bodies do for their members to help combat money laundering and terrorist financing?
A. They provide technical assistance to members in implementing FATF recommendations
B. They assist member countries in penalizing entities that violate FATF standards and recommendations
C. They work with members on areas of concern outside of anti-money laundering and terrorist financing
D. They supervise member country financial institutions relating to anti-money laundering and terrorist financing
The local manager of a remote mortgage origination department of a financial institution has just discovered that sanctions screening of new customers is not being performed. Which action should the local manager take in this situation?
A. Start screening new customers
B. Immediately inform the regulators
C. Immediately inform senior management
D. Do nothing because the department only handles a very small number of mortgages
A periodic review of the account of a small household goods business reveals multiple shipments of goods to a country classified by the bank as high risk. They were transshipped through another country prior to the final destination. In the past three months, volumes over 25,000 units. The business has been a customer of a bank for 10 years.
Records show previous shipments to destinations primarily in Europe involving quantities of 5,000 units or less. Recent shipments are listed as being received by the same company as the earlier shipments and payments are being received from the same originator, but the unit price of the goods is three times higher than before.
Which two red flags indicate potential trade-based money laundering? (Choose two.)
A. The shipments of the same goods are now going to a different location.
B. The goods are transshipped through one or more jurisdictions for no apparent economic reason.
C. The size of the shipments appear inconsistent with the exporter's previous business activities.
D. The goods are shipped to a jurisdiction that the bank classifies as "high risk" for money laundering activities.
Which action by a prospective customer during the account opening process requires further investigation?
A. Listing a long-distance phone number
B. Questioning reporting requirements
C. Expressing knowledge of the financial industry
D. Providing driver's license
A Money Laundering Reporting Officer's (MLRO) lack of action led to deficiencies in the bank's AML program and a civil monetary penalty being levied against the MLRO. Why was this direct action taken against the MLRO?
A. The MLRO is the only individual that can be held responsible for AML program deficiencies.
B. MLROs can be held to an individual accountability standard and face potential penalties for contributing to AML program deficiencies.
C. The MLRO agreed to the civil penalty so that the bank would not be found liable for the AML program deficiencies.
D. Action was brought against the MLRO because banks cannot be found liable for AML program deficiencies.
Which transaction should result in a SAR/STR filing?
A. A small business owner deposits checks totaling $9,950 USD on a daily basis without providing a legitimate purpose.
B. A small business owner deposits $25,000 USD in cash proceeds with a business equipment bill of sale.
C. A national food-chain restaurant with multiple cash transactions at various branch locations.
D. A national food-chain restaurant makes multiple, anticipated cash transactions that are above the daily reporting threshold.
What types of things should an institution incorporate in it AML policies and procedures? Choose 3 answers
A. On-going training, as well as initial training of new employees
B. Periodic audits, to be performed by independent staff at least once a year
C. Ability to incorporate relevant legislative and regulatory AML changes
D. Review of the AML policy by the Board of Directors
Which are essential elements of a KYC program identified by the Basel Committee on Banking Supervision? (Choose two.)
A. Internal control
B. Customer acceptance policy
C. Code of conduct
D. Risk appetite
E. Risk management
Which is a primary purpose of imposing economic sanctions?
A. Preventing depletion of natural resources
B. Changing the behavior of the country
C. Minimizing the export of trade goods
D. Promoting competition of domestic technology