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| Section | Weight | Objectives |
|---|---|---|
| Building an AFC Compliance Program | ||
| Tools and Technologies to Fight Financial Crime | ||
| Global AFC Frameworks, Governance and Regulations | - AML Regulatory Framework (Elective options: Canada, EU, UK, USA) | |
| Understanding Risks and Methods of Financial Crime | 30% | - Financial Crime Risks related to gaming and gambling - Financial Crime Risks related to real estate - Financial Crime Risks related to insurance products - Financial Crime Risks related to MSBs, PSPs, and ecommerce platforms - Financial Crime Risks related to gatekeepers - Financial Crime Risks related to Politically Exposed Persons (PEPs) and high-risk customers - Financial Crime Risks related to trusts and company service providers - Financial Crime Risks related to VASPs, cryptoassets, and related products - Financial Crime Risks related to products within other financial sectors |
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NEW QUESTION # 17
A financial institution has received complaints about friction in the onboarding process when additional information is requested. Which potential solutions could help ensure a better customer onboarding experience with reduced friction? (Select Two.)
Answer: B,C
Explanation:
Customer onboarding is a critical AML/CFT process that must balance regulatory compliance with customer experience. Excessive friction can lead to customer dissatisfaction and abandonment.
Implementing internal or external tools--such as digital onboarding platforms, document collection tools, and workflow automation--can significantly streamline information gathering and reduce delays while maintaining compliance standards.
Additionally, consistent training of all employees involved in onboarding ensures that information requests are clear, consistent, and proportionate. Well-trained staff reduce rework, confusion, and unnecessary follow-ups, improving customer trust and efficiency.
Restricting decision-making to managers can slow processes, and delaying updates to processes reduces adaptability to evolving risks and regulatory expectations.
NEW QUESTION # 18
While there are legitimate reasons for trust and company service providers (TCSPs) to appoint a nominee shareholder, which feature of a nominee shareholder presents the greatest financial crime risk?
Answer: A
Explanation:
Nominee shareholders may be used for legitimate commercial reasons; however, FATF guidance identifies nominee arrangements as a significant money laundering risk when they obscure beneficial ownership.
The greatest risk arises when nominee shareholders provide anonymity to the true beneficial owner, preventing transparency in public registers and complicating due diligence. Criminals may exploit this opacity to conceal ownership, evade sanctions, launder illicit proceeds, or avoid tax and regulatory scrutiny.
The ability to hide ownership undermines one of the core objectives of AML/CFT frameworks: identifying and verifying beneficial owners. As a result, regulators require enhanced due diligence and clear documentation when nominee shareholders are involved.
Other features-such as administrative efficiency, compliance with local laws, or ease of share transfer-do not inherently increase financial crime risk when transparency and disclosure requirements are met.
NEW QUESTION # 19
Which of the following are included in the 11 Immediate Outcomes outlined in the Financial Action Task Force (FATF) methodology for assessing technical compliance with the FATF Recommendations and the effectiveness of AML/CFT/CPF systems during mutual evaluations? (Select Three.)
Answer: B,C,D
NEW QUESTION # 20
In order to prevent financial crime risk, the implemented policies, controls, and procedures must:
Answer: D
Explanation:
Effective AML/CFT policies, controls, and procedures must be risk-based, proportionate, and well-governed, as emphasized by FATF and national regulators. Proportionality ensures that controls are appropriate to the firm's size, complexity, products, services, and risk exposure.
Senior management approval is essential to establish accountability and tone from the top.
Regular review ensures policies remain effective as risks, regulations, and business models evolve.
AML responsibility is shared across the three lines of defense, not owned solely by the business.
External validation may support assurance but does not replace internal accountability. While technology can enhance controls, regulators do not mandate the use of advanced or cutting-edge solutions; effectiveness and governance are more important than sophistication.
NEW QUESTION # 21
Which regulation permits financial institutions, upon providing notice to the US Department of the Treasury, to share information with one another in order to identify and report activities that may involve money laundering or terrorist activity to the federal government?
Answer: D
Explanation:
USA PATRIOT Act Section 314(b)allows financial institutions tovoluntarily share information with one another, after notifying the U.S. Treasury, toidentify and report possible money laundering or terrorist financing activities.
Key elements include:
Voluntary participation
Prior notice to FinCEN (part of the U.S. Treasury)
Protection from liability when acting in good faith
Enhanced collaborative detection across institutions
Section 314(a)refers toinformation sharing between law enforcement and financial institutions, not peer-to-peer sharing.
COSMICis an initiative in certain jurisdictions like Singapore, not U.S. regulation.
Regulation (EU) 2024/1624is part of the EU AML framework, not relevant to U.S. institutions.
NEW QUESTION # 22
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