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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. igh 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

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

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

An anti-money laundering specialist at a large institution is responsible for information 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 inquires 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 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

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

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 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

An anti-money laundering specialist at a large institution is responsible for information 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 inquires received from law enforcement

D. Notification of management changes in the different major divisions

Answer: B

What should a bank focus on to ensure on-going compliance with its AML program?

A. It should ensure that it develops and provides on-going 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 bank¡¯s AML program

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

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

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

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

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 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

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