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| Section | Weight | Objectives |
|---|---|---|
| Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) | 25% | - AML/CFT Regulatory Bodies and Guidance
|
| Money Laundering Risks and Methods | 26% | - Payment Systems and Money Laundering Methods
|
| AML/CFT Compliance Program | 26% | - Customer Identification Program (CIP) and Customer Due Diligence (CDD)
|
| AML/CFT Investigations and Enforcement | 23% | - Cooperation and Information Sharing
|
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NEW QUESTION # 394
A compliance officer is developing management reporting information to provide leadership with insights into the financial crime risk related to an institution's customer population.
Which of the following is a key risk indicator to include in the reporting to allow leadership to monitor whether there are any key changes to the inherent risk of the customer population? (Choose two.)
Answer: A,D
Explanation:
Percentage change in transaction monitoring alerts escalated for investigation and number/percentage of senior PEPs onboarded are key risk indicators that can highlight shifts in the inherent risk profile of the customer base, enabling leadership to proactively address emerging financial crime risks.
NEW QUESTION # 395
the Financing of Terrorism (CFT)]
A financial institution has expanded its scope of services so that it is attracting the business of politically exposed persons (PEPs) who had previously never been part of the customer base.
Which two courses of action should the compliance officer include in the institution's procedures for considering PEPs as customers? (Choose two.)
Answer: A,D
Explanation:
According to the Anti-Money Laundering Specialist (the 6th edition) resources, PEPs are individuals who are or have been entrusted with prominent public functions, such as heads of state, senior politicians, senior government, judicial or military officials, senior executives of state-owned corporations, or important political party officials1. PEPs pose a higher risk of money laundering and corruption due to their position and influence2. Therefore, financial institutions should apply enhanced due diligence and ongoing monitoring measures when dealing with PEPs as customers3. This includes:
* Conducting enhanced ongoing monitoring of the businessrelationship to detect and report any suspicious transactions or activities4. This may involve more frequent reviews, higher-level approvals, or increased documentation of the transactions and the rationale behind them.
* Taking adequate measures to establish the source of wealth and source of funds which are involved in the business relationship or occasional transaction. This may involve verifying the origin, legitimacy, and purpose of the funds, as well as the economic activities and assets of the PEP.
The other two options are incorrect because:
* Expedite due diligence when a PEP is pre-approved by a member of senior management is not a recommended course of action, as it may compromise the quality and integrity of the due diligence process. Pre-approval by senior management does not exempt the financial institution from conducting thorough and timely due diligence on the PEP and the business relationship.
* Obtain appropriate senior management approval for establishing a business relationship with a PEP from a high risk country is a necessary but not sufficient course of action, as it does not address the ongoing monitoring and source of funds aspects of the PEP risk management. Senior management approval is required for establishing or continuing a business relationship with a PEP, regardless of the country of origin or residence of the PEP.
:
1: ACAMS, CAMS Study Guide, 6th Edition, Chapter 4, p. 83 2: ACAMS, CAMS Study Guide, 6th Edition, Chapter 4, p. 84 3: ACAMS, CAMS Study Guide, 6th Edition, Chapter 4, p. 85 4: ACAMS, CAMS Study Guide, 6th Edition, Chapter 4, p. 86 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 4, p. 87 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 4, p. 86 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 4, p.
87 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 4, p. 88 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 4, p. 88 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 4, p. 88 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 4, p. 88
NEW QUESTION # 396
A compliance officer at a small local bank reads in the newspaper that a high ranking local public official, who is a long-standing account holder, is being investigated by the competent authorities for accepting bribes. The compliance officer immediately checks the official's account and new account the official opened at the bank a few weeks ago. The compliance officer's investigation of these accounts discloses that the official's long-standing account had no unusual activity and that the recently opened had no activity since it was opened. What should the compliance officer do next?
Answer: A
NEW QUESTION # 397
What should afinancial institution (FI) doin response to aformal law enforcement requestto produce documents?
Answer: B
Explanation:
FIs mustcooperate with law enforcement requestswhile ensuringlegal compliance.
* Option C (Correct):Adesignated compliance officershould handledocument preparation and internal review.
* Option A (Incorrect):There isno requirementto wait for theCEO's approval.
* Option B (Incorrect):Privacy policies should already align withAML laws, delaying compliance isnot recommended.
* Option D (Incorrect):Blocking a lawful requestcould lead tolegal and regulatory action.
Reference:FATF Recommendation 40 (International Cooperation), U.S. Bank Secrecy Act (BSA) Subpoena Guidelines, Egmont Group FIU Cooperation Standards.
NEW QUESTION # 398
A compliance officer at a large financial institution has been tasked by senior management to lead a team in an internal review and potential revision of the institution's customer onboarding program following a regulatory enforcement action of another institution.
Which step should the compliance officer perform first?
Answer: B
Explanation:
The compliance officer should perform the first step of reviewing the institution's risk assessment before implementing any changes to the customer onboarding program. The risk assessment is a key component of the AML compliance program, as it identifies and measures the institution's exposure to money laundering and terrorist financing risks. The risk assessment should be updated regularly and reflect the institution's products, services, customers, geographic locations, and delivery channels. By reviewing the risk assessment, the compliance officer can determine the adequacy and effectiveness of the current customer onboarding program and identify any gaps or weaknesses that need to be addressed. The compliance officer can also benchmark the institution's risk assessment against the regulatory expectations and best practices in the industry.
The other steps are also important, but they should be performed after the risk assessment review. Revising training materials for frontline staff, conducting enhanced due diligence on high risk customers, and resolving substantive discrepancies in customer verification are all part of the customer onboarding program, but they depend on the risk assessment to provide the appropriate level of controls and procedures. For example, the training materials should reflect the risk assessment results and the revised customer onboarding policies. The enhanced due diligence should be applied to customers who pose a higher risk according to the risk assessment criteria. The customer verification should be consistent with the risk assessment and the customer identification program.
References:
* AML KYC Onboarding Lifecycle Process Flow | Guide - AdvisoryHQ
* New EBA AML Guidelines on the use of Remote Customer Onboarding Solutions - Bird & Bird
* KYC Onboarding Process 2023 - AML requirements - Sumsub
Review of any AML/CFT program begins with the Risk Based Approached. It should first check the internal system to identify risk factors and design program accordingly.
NEW QUESTION # 399
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