The Office of Foreign Assets Control requirements have an extraterritorial reach because compliance is required by:
A. entities registered in the US.
B. intermediaries of a transaction with a US nexus.
C. foreign financial intelligence units.
D. US persons in the US.
A senior government official is trying to open an account in a financial institution (FI) that operates in a different country from where the official is domiciled. The official is using an asset manager intermediary to represent them. According to the Wolfsberg Group, which next steps should the FI take regarding the opening of the account? (Choose three.)
A. Report to authorities that a possible suspicious activity is being undertaken by a politically exposed person.
B. Determine whether the intermediary representative is acting on the officer's behalf.
C. Ensure the official's client file is updated so that the information is maintained in a consistent and complete manner.
D. Perform due diligence procedures on the managing intermediary.
E. Reasonably establish if the source of wealth and funds of the official is legitimate.
F. Screen for applicable sanctions only for the official in the name of the person for whom the account will be opened.
According to the Financial Action Task Force methodology, which situations would require a financial institution (FI) to consider filing a suspicious activity report?
A. A FI is unable to verify the relevant customer due diligence documents.
B. A transaction involves funds exchanged from crypto to fiat currencies.
C. A FI identifies the payer is a dealer in precious metals or stones.
D. A beneficiary of a transaction is a politically exposed person.
A bank received a subpoena regarding one of its clients. The financial intelligence unit of the bank should review the subpoena and:
A. adjust the client's risk score and close the case.
B. file a suspicious activity report (SAR), including the receipt of the subpoena in the SAR narrative.
C. close the client's account by informing the client of the subpoena.
D. perform a transaction review and respond fully to the subpoena.
A company contracts a life insurance policy with a savings feature of 100,000 USD for an individual in a high-risk country. The policy receives monthly cash deposits from unknown third parties. A minimal part of the deposit is invested and the rest is withdrawn by the end of the month. Which are the circumstances to consider as a risk for money laundering? (Choose two.)
A. Unidentified third parties depositing cash to the policy
B. A company established in a high-risk country contracting a policy for a domestic individual
C. A policy for an amount of 100,000 USD is to be considered high and suspicious
D. A life insurance policy with a savings feature for a national from a high-risk country
E. The regular withdrawals from the policy by the end of the month
The AML investigator is reviewing the transaction monitoring alerts and the customer's historical profile for the past two years. A review of the negative news search from a blog indicates that the customer was previously part of a terrorist group. Which activities warrant further escalation? (Choose two.)
A. The credit transactions in the account relate mostly to salary and rental income from property.
B. The account received a large cash deposit followed by systematic automated teller machine (ATM) withdrawals until the balance was nominal.
C. The customer conducts multiple cash transactions on a regular basis which do not match the customer's occupation.
D. The customer remitted monies in several transactions to the account of a recognized charity non-profit organization.
E. The customer has bought and sold several real estate properties over the last year.
Which economic and social factors could create a dependency on illicit activities and money laundering? (Choose two.)
A. Weaker development of economy and job opportunities
B. Weaker financial inclusion
C. Weakness of public service and governmental funding
D. Wider exposure to organized crime and corruption
E. Weakness of private sector legitimacy
Customers of a telecommunications firm received an email explaining an issue with their last order. The customers were directed to the company website via a link in the email to provide personal information. Both the email and website were fake. What type of cybercrime has been committed?
A. Tumbling
B. Spear phishing
C. Malware
D. Cryptojacking
A compliance analyst has recently investigated an account where money was deposited in amounts below the reporting limit and almost entirely withdrawn in a foreign country. Which type of money laundering is the compliance analyst potentially identifying?
A. Check Kiting
B. Structuring
C. Microstructuring
D. Trade-based
How should a compliance program respond to an AML audit finding?
A. By nominating an independent party to implement the corrective action
B. By giving recommendations for each finding as part of an audit report
C. By using the findings to identify and assess their money laundering risk
D. By closing the accounts that were subject to findings
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