ANTI-MONEY LAUNDERING ACTUAL COMPLETE
EXAM|WITH ACCURATE QUESTIONS AND VERIFIED
ANSWERS|GRADED A
ABC Bank was served with a search warrant. What next steps should the
Bank consider? Ans✓✓✓ 1. Call the financial institution's in‐house or
outside counsel, 2. Review the warrant to understand its scope, 3. Ask
for and obtain a copy of the warrant, 4. Ask for a copy of the affidavit
that supports the search warrant
(the agents are not obligated to provide a copy of the affidavit, but, if a
financial institution is allowed to see the affidavit, the financial
institution can learn more about the purpose of the investigation), 5.
Remain present while the agents record an inventory of all items
they seize and remove from the premises. Keep track of the
records taken by the agents, 6. Ask for a copy of law enforcement's
inventory of what they have
seized, and 7. Write down the names and agency affiliations of the
agents who conduct the search.
ABC Bank was served with a subpoena compelling the production of
certain documents on a personal checking account. Describe the steps
the bank should consider taking upon receipt of the subpoena. Ans✓✓✓
If an institution is served with a summons or subpoena compelling the
production of certain documents, the institution should have its senior
management and/or counsel review the summons or subpoena. If there
are no grounds for contesting the summons or subpoena, the institution
should take all appropriate measures to comply with the summons or
subpoena on a timely and complete basis. Failure to do so can result in
adverse action and penalties for the institution. Also, the financial
,institution should not notify the customer who is being investigated. If
the government asks the bank to keep certain accounts open, such a
request should be obtained in writing under proper letterhead and
authority from the government.
According to a 2001 report, "Money
Laundering in Canada: An Analysis of RCMPCases," what are the four
related reasons to establish or control a shell company for
money laundering purposes? Ans✓✓✓ • Shell companies accomplish
the objective of
converting the cash proceeds of crime into
alternative assets, • Through the use of shell companies, the launderer
can create the perception that illicit funds have been generated from a
legitimate source, • Once a shell company is established, a wide range of
legitimate and/or bogus business transactions can be used to further the
laundering process, and • Shell companies can also be effective in
concealing criminal ownership. Nominees can be used as
owners, directors, officers or shareholders.
According to FATF, what three circumstances should be kept in mind
when dealing with
possible cuckoo smurfing activity? Ans✓✓✓ • The existence of these
deposits is not necessarily grounds to reconsider the relationship with a
custome • It could be the indicator of laundering, therefore it
should be examined carefully. • Law enforcement will need information
on the depositor, so banks should seek to identify cash deposits made by
third parties and should retain surveillance
,footage.
According to FATF's paper called "Money Laundering and Terrorist
Financing Vulnerabilities of Commercial Websites and Internet Payment
Systems," what are the different classes/types of commercial websites?
Ans✓✓✓ • Mediated customer‐to‐customer, sites that allow private
individuals to sell to one another via an online marketplace, • Mediated
business‐to‐customer, sites that allow multiple merchants to sell to
consumers via an online marketplace, • Non‐mediated customer‐to‐
customer (i.e. Bulletin board services and online classifieds), sites that
only allow customers to advertise goods they want to sell, • Direct
business‐to‐customer, merchants that sell goods to consumers via their
own websites, and • Direct business‐to‐business websites, merchants
selling to merchants.
According to FATF's paper called "Risk‐Based Approach Guidance for
Casinos," what are the potential transaction risks for land‐based and
internet casinos? Ans✓✓✓ According to FATF's paper called "Risk‐
Based Approach Guidance for Casinos,"casinos should consider
operational aspects (i.e. products, services, games, and accounts/account
activities) that
can be used to facilitate money laundering and terrorist financing
activities. In addition, land‐based and Internet casinos have the
following potential transaction risks: • Proceeds of crime, • Cash, •
Transfers between customers, • Loan sharking, • Use of casino deposit
accounts, and • Redemption of chips, tickets, or tokens for currency.
According to FATF's Recommendations (2012), what are the designated
thresholds for
, transactions under Recommendations 10, 22, and 23? Ans✓✓✓ FATF
also designated specific thresholds that trigger AML scrutiny. For
example, the threshold that financial institutions should monitor for
occasional customers is €15,000 [Recommendation 10]; for casinos,
including Internetcasinos, it is €3,000 [Recommendation 22]; and for
dealers in precious metals, when engaged in any cash transaction, it is
€15,000 [Recommendation 22‐23].
According to Section 312 of the USA Patriot Act, the due diligence
program for correspondent and private banking accounts must address
what three measures? Ans✓✓✓ • Determining whether enhanced due
diligence is necessary, • Assessing the money laundering risk presented
by the correspondent account, • Applying risk‐based procedures and
controls reasonably designed to detect and report suspected money
laundering.
According to statements by the U.S. Treasury and Internal Revenue
Service (IRS), what are some patterns financial institutions can look for
as they investigate possible
money laundering? Ans✓✓✓ • Unusually high monthly balances in
comparison to known sources of income, • Unusually large deposits,
deposits in round numbers or deposits in repeated amounts that are not
attributable to legitimate sources of income, • Multiple deposits made
under reportable thresholds, • The timing of deposits. This is particularly
important when dates of illegal payments are known, • Checks written
for unusually large amounts (in relation to the suspect's known
practices), or • A lack of account activity. This might indicate
transactions in currency or the existence of other unknown bank
accounts.
EXAM|WITH ACCURATE QUESTIONS AND VERIFIED
ANSWERS|GRADED A
ABC Bank was served with a search warrant. What next steps should the
Bank consider? Ans✓✓✓ 1. Call the financial institution's in‐house or
outside counsel, 2. Review the warrant to understand its scope, 3. Ask
for and obtain a copy of the warrant, 4. Ask for a copy of the affidavit
that supports the search warrant
(the agents are not obligated to provide a copy of the affidavit, but, if a
financial institution is allowed to see the affidavit, the financial
institution can learn more about the purpose of the investigation), 5.
Remain present while the agents record an inventory of all items
they seize and remove from the premises. Keep track of the
records taken by the agents, 6. Ask for a copy of law enforcement's
inventory of what they have
seized, and 7. Write down the names and agency affiliations of the
agents who conduct the search.
ABC Bank was served with a subpoena compelling the production of
certain documents on a personal checking account. Describe the steps
the bank should consider taking upon receipt of the subpoena. Ans✓✓✓
If an institution is served with a summons or subpoena compelling the
production of certain documents, the institution should have its senior
management and/or counsel review the summons or subpoena. If there
are no grounds for contesting the summons or subpoena, the institution
should take all appropriate measures to comply with the summons or
subpoena on a timely and complete basis. Failure to do so can result in
adverse action and penalties for the institution. Also, the financial
,institution should not notify the customer who is being investigated. If
the government asks the bank to keep certain accounts open, such a
request should be obtained in writing under proper letterhead and
authority from the government.
According to a 2001 report, "Money
Laundering in Canada: An Analysis of RCMPCases," what are the four
related reasons to establish or control a shell company for
money laundering purposes? Ans✓✓✓ • Shell companies accomplish
the objective of
converting the cash proceeds of crime into
alternative assets, • Through the use of shell companies, the launderer
can create the perception that illicit funds have been generated from a
legitimate source, • Once a shell company is established, a wide range of
legitimate and/or bogus business transactions can be used to further the
laundering process, and • Shell companies can also be effective in
concealing criminal ownership. Nominees can be used as
owners, directors, officers or shareholders.
According to FATF, what three circumstances should be kept in mind
when dealing with
possible cuckoo smurfing activity? Ans✓✓✓ • The existence of these
deposits is not necessarily grounds to reconsider the relationship with a
custome • It could be the indicator of laundering, therefore it
should be examined carefully. • Law enforcement will need information
on the depositor, so banks should seek to identify cash deposits made by
third parties and should retain surveillance
,footage.
According to FATF's paper called "Money Laundering and Terrorist
Financing Vulnerabilities of Commercial Websites and Internet Payment
Systems," what are the different classes/types of commercial websites?
Ans✓✓✓ • Mediated customer‐to‐customer, sites that allow private
individuals to sell to one another via an online marketplace, • Mediated
business‐to‐customer, sites that allow multiple merchants to sell to
consumers via an online marketplace, • Non‐mediated customer‐to‐
customer (i.e. Bulletin board services and online classifieds), sites that
only allow customers to advertise goods they want to sell, • Direct
business‐to‐customer, merchants that sell goods to consumers via their
own websites, and • Direct business‐to‐business websites, merchants
selling to merchants.
According to FATF's paper called "Risk‐Based Approach Guidance for
Casinos," what are the potential transaction risks for land‐based and
internet casinos? Ans✓✓✓ According to FATF's paper called "Risk‐
Based Approach Guidance for Casinos,"casinos should consider
operational aspects (i.e. products, services, games, and accounts/account
activities) that
can be used to facilitate money laundering and terrorist financing
activities. In addition, land‐based and Internet casinos have the
following potential transaction risks: • Proceeds of crime, • Cash, •
Transfers between customers, • Loan sharking, • Use of casino deposit
accounts, and • Redemption of chips, tickets, or tokens for currency.
According to FATF's Recommendations (2012), what are the designated
thresholds for
, transactions under Recommendations 10, 22, and 23? Ans✓✓✓ FATF
also designated specific thresholds that trigger AML scrutiny. For
example, the threshold that financial institutions should monitor for
occasional customers is €15,000 [Recommendation 10]; for casinos,
including Internetcasinos, it is €3,000 [Recommendation 22]; and for
dealers in precious metals, when engaged in any cash transaction, it is
€15,000 [Recommendation 22‐23].
According to Section 312 of the USA Patriot Act, the due diligence
program for correspondent and private banking accounts must address
what three measures? Ans✓✓✓ • Determining whether enhanced due
diligence is necessary, • Assessing the money laundering risk presented
by the correspondent account, • Applying risk‐based procedures and
controls reasonably designed to detect and report suspected money
laundering.
According to statements by the U.S. Treasury and Internal Revenue
Service (IRS), what are some patterns financial institutions can look for
as they investigate possible
money laundering? Ans✓✓✓ • Unusually high monthly balances in
comparison to known sources of income, • Unusually large deposits,
deposits in round numbers or deposits in repeated amounts that are not
attributable to legitimate sources of income, • Multiple deposits made
under reportable thresholds, • The timing of deposits. This is particularly
important when dates of illegal payments are known, • Checks written
for unusually large amounts (in relation to the suspect's known
practices), or • A lack of account activity. This might indicate
transactions in currency or the existence of other unknown bank
accounts.
