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| Section | Objectives |
|---|---|
| AML Compliance Framework | - AML compliance program structure - Regulatory obligations and enforcement expectations - Internal controls and governance |
| Financial Crime Typologies and Risk | - Sanctions and embargo compliance - Risk assessment methodologies - 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 |
| Customer Due Diligence (CDD) and KYC | - Enhanced due diligence for high-risk customers - Customer identification and verification - Beneficial ownership and PEP screening |
| Transaction Monitoring and Reporting | - Suspicious Activity Reports (SAR) / STR filing - Case management and investigation processes - Suspicious activity detection and monitoring systems |
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NEW QUESTION # 298
What are three potential issues for foreign financial institutions maintaining correspondent accounts with U.S.
banks under the Patriot Act?
Answer: A,C,D
NEW QUESTION # 299
A customer puts high-denomination cash notes into a poker machine at a casino. Without placing any bets, the customer collected winnings in the form of a check from the casino.
Which money laundering threats could result from the customer's activities?
Answer: D
Explanation:
1. A. Micro-structuring cash:
The customer's behavior of putting high-denomination cash notes into a poker machine without placing bets and then collecting winnings in the form of a check resembles "structuring" or "smurfing." Structuring involves breaking down large sums of money into smaller transactions to avoid detection. In this case, the customer may be attempting to legitimize illicit funds by converting them into casino winnings1.
2. B. Legitimizing illicit funds:
By using the poker machine to convert cash into a check, the customer is potentially legitimizing illicit funds.
The casino winnings obtained through this process may appear legitimate, even though the initial source of the cash remains suspicious1.
A: Micro-structuring cash:
The customer's actions of repeatedly inserting high-denomination cash notes into the poker machine without placing bets and then collecting winnings in the form of a check resemble structuring. Structuring involves deliberately breaking down large amounts of cash into smaller transactions to avoid detection. Money launderers engage in structuring to obscure the origin of funds and make them appear legitimate. In this case, the customer's behavior raises red flags and warrants further investigation.
B: Legitimizing Illicit Funds:
By converting cash into casino winnings (in the form of a check), the customer may be attempting to legitimize illicit funds. The casino winnings obtained through this process could be used to create a veneer of legitimacy, even though the initial source of the cash remains suspicious. Casinos are attractive for money launderers due to the anonymity and fluidity of transactions, making it challenging to trace the origin of funds1.
References: 1: Anti-Money Laundering Specialist (6th edition), ACAMS, Chapter 3: "Money Laundering and Terrorist Financing Methods," Section 3.1.2: "Structuring."
NEW QUESTION # 300
Which of the following statements is true regarding Office of Foreign Assets Control (OFAC) sanctions?
(Select Two.)
Answer: B,C
Explanation:
OFAC sanctions are a key element of the U.S. AML/CFT framework. According to the CAMS 6th Edition and OFAC regulations:
* Blocked funds must be placed into an interest-bearing account on a financial institution's books (B):"Blocked property must be held in a separate interest-bearing account on the books of the U.S.
financial institution."(CAMS 6th Edition, Sanctions Compliance; OFAC FAQs)
* Sanctions can be either comprehensive or selective using the blocking of assets and trade restrictions (C):"OFAC administers both comprehensive and targeted (selective) sanctions programs to fulfill U.S. foreign policy and national security goals."(CAMS 6th Edition, Sanctions Compliance) Incorrect Options:
* A: OFAC can sanction entities, vessels, and organizations-not just individuals or those in foreign countries.
* D: There is no automatic expiration of OFAC sanctions after five years.
References:
CAMS 6th Edition, OFAC and Sanctions Programs
U).S. Treasury, OFAC FAQs
NEW QUESTION # 301
A bank teller receives a written request from a police officer to review a previous customer's account on a pre-populated form with the officer's official letter head. The officer suspects the previous customer is engaging in smurfing. Which action should the bank teller perform?
Answer: A
NEW QUESTION # 302
What are the regulatory risks to a bank employee who willfully violates anti-money laundering laws?
Answer: A
Explanation:
A bank employee who willfully violates anti-money laundering laws faces the risk of criminal investigation and imprisonment, as these are serious offenses that could result in felony charges and penalties. According to the U.S. Department of Justice, individuals who knowingly violate the Bank Secrecy Act (BSA) or other anti- money laundering laws could face up to 10 years in prison and/or a fine of up to $500,0001. Similarly, in other jurisdictions, such as the UK, Canada, and Australia,individuals who commit money laundering offenses could face imprisonment and/or fines234.
:
1: U.S. Department of Justice, Criminal Resource Manual, Title 18 U.S.C. § 1956. Laundering of Monetary Instruments, Section 2101 2: UK Government, Proceeds of Crime Act 2002, Part 7: Money Laundering Offences, Section 327-329 3: Government of Canada, Criminal Code, Part XII.1: Laundering of Proceeds of Crime, Section 462.31 4: Australian Government, Criminal Code Act 1995, Chapter 10: National Infrastructure, Part 10.2: Money Laundering, Section 400.3-400.9 Penalties for AML/CFT violations, including criminal and civil penalties, fines, jail terms, as well as internal sanctions, such as disciplinary action up to and including termination of employment.
NEW QUESTION # 303
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