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| Section | Objectives |
|---|---|
| Transaction Monitoring and Reporting | - Case management and investigation processes - Suspicious Activity Reports (SAR) / STR filing - Suspicious activity detection and monitoring systems |
| Customer Due Diligence (CDD) and KYC | - Enhanced due diligence for high-risk customers - Customer identification and verification - Beneficial ownership and PEP screening |
| AML Compliance Framework | - Regulatory obligations and enforcement expectations - Internal controls and governance - AML compliance program structure |
| Financial Crime Typologies and Risk | - Risk assessment methodologies - Sanctions and embargo compliance - Common money laundering typologies across industries |
| AML and CTF Fundamentals | - International AML/CTF standards and FATF recommendations - Money laundering and terrorist financing concepts - Stages and typologies of money laundering |
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NEW QUESTION # 819
Which is a red flag for funds transfers?
Answer: B
NEW QUESTION # 820
What are two legal risks of having inadequate privacy policies and procedures? (Choose two.)
Answer: A,B
Explanation:
Having inadequate privacy policies and procedures can expose an organization to legal risks such as industry or regulatory sanctions and charges of deceptive business practices. Industry or regulatory sanctions can result from violating the laws and regulations that govern data privacy and protection, such as the GDPR, the CCPA, or the GLBA. These sanctions can include fines, penalties, injunctions, or revocation of licenses. Charges of deceptive business practices can arise from misleading or false statements about how the organization collects, uses, or discloses personal data, or from failing to comply with its own privacy policies and procedures. These charges can lead to lawsuits, settlements, or enforcement actions by authorities such as the FTC or the state attorneys general.
References: =
* The 4 Biggest Risks of Non-Compliance With Data Privacy Regulations
* Security and privacy laws, regulations, and compliance: The complete guide
* An Ethical Approach to Data Privacy Protection
NEW QUESTION # 821
Client A is flagged for a high volume of outgoing transfers. Further investigation reveals Client A has a potentially key role in a network linked to human trafficking. After filing a suspicious activity report, what step should the investigator take next?
Answer: C
Explanation:
Explanation
After filing a suspicious activity report (SAR), an investigator should prepare a summary for senior management recommending client off-boarding. This is because client off-boarding is a risk-based decision that requires senior management approval and may involve legal considerations. Informing other local financial institutions about the client, restraining or blocking the client's account(s), or contacting law enforcement directly are not appropriate actions for an investigator to take after filing a SAR, as they may compromise the confidentiality of the SAR, violate privacy laws, or interfere with ongoing investigations.
NEW QUESTION # 822
In order to protect investigative materials from disclosure when conducting an internal Investigation of any employee of a financial institution, legal counsel of that financial should________?
Answer: A
NEW QUESTION # 823
A bank account is established for a new business customer. The business was established five years ago with an address in another state. The business website contains few details other than stating it is a real estate business.
One principal has an international telephone number and appears to be living in another country. The other principal works out of a recreational vehicle.
What warrants enhanced due diligence in this scenario?
Answer: A
Explanation:
Money laundering through real estate is a common method of disguising the source and ownership of illicit funds. Real estate transactions often involve large amounts of money, complex legal structures, and cross-border transfers, which can obscure the true nature and origin of the funds. The new business customer in this scenario raises several red flags that warrant enhanced due diligence, such as:
The business was established five years ago but has a vague website and no physical presence in the state where it is registered.
One of the principals has an international phone number and lives abroad, which could indicate a foreign shell company or a politically exposed person.
The other principal works out of a recreational vehicle, which could suggest a lack of legitimate business activity or income.
The business claims to be a real estate business, but does not provide any details about its projects, clients, or partners.
These factors suggest that the business may be involved in money laundering through real estate, either by purchasing properties with illicit funds, using properties to generate illegal income, or selling properties to launder money. Therefore, the financial institution should conduct enhanced due diligence to verify the identity, background, and source of funds of the business and its principals, as well as the purpose and nature of the account relationship.
References:
ACAMS Study Guide for the CAMS Certification Examination - 6th Edition, Chapter 2: Money Laundering Risks and Methods, pp. 46-47 Enhanced Due Diligence in Construction and Real Estate, by James Swenson, Ethixbase 360 Due Diligence & Legal Considerations in Commercial Real Estate, by Justia
NEW QUESTION # 824
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