ACAMS Test Review | 100% Correct
Answers | Verified | Latest 2024 Version
40 Recommendation highlights are? - vV
Risk-Base approach.
Designated categories of offenses.
Terrorist financing & financing of proliferation.
Knowledge & criminal liability.
A "Payable-Through Account" PTA is a master correspondent account established at a domestic bank by
a foreign bank. The Home-Country Customers of the foreign bank, which is called the "Master
Accountholder" are permitted to conduct a wide range of banking transactions through the PTA typically
those customers, called "sub-accountholders", can write checks make deposits & withdrawals, & wire
funds through the PTA almost as if they were direct, local customers of the US bank. The sub-
accountholders, who can number in the hundreds & who rarely have direct contact with the domestic US
banks, are given checks by which to draw funds on the PTA. In 1 US case the regulator found that the
domestic bank had failed to adequately supervise the PTAs. To implement effective internal control &
operating systems concerning PTAs, to establish "Know Your Customer" procedures for Sub-
Accountholders & to maintain adequate staffing. The - v v/ Preparing a "Risk Assessment" about each
PTA.
Obtaining a signed document from each Sub-Accountholder subjecting the subaccount to state & federal
laws & regulations in spite of any banking secrecy laws of any other jurisdiction.
Preparing a "PTA Action Plan" that examiners the adequacy of its capabilities to monitor PTAs & plans to
improve them.
Obtaining detailed information from the master account holder about the way it is supervised by its
home country agencies.
Conducting periodic verification of the information provided by the foreign bank.
Developing a policy regarding termination of PRA accounts where information it receives is materially
inaccurate or incomplete.
A bank in Italy holds a business account for a Italian company that sells gold throughout Europe & the
Western Hemisphere. The bank knows the purpose of this account is to receive payment for sales. A
review of the account shows a pattern of wire transfers coming from Payable-Through Accounts. There is
,
,
, A small Broker-Dealer has an AML compliance program that addresses procedures for filing STR &
includes policies, procedures a& internal controls for customer identification, monitoring accounts &
identifying Money Laundering red flags. Every employee of the broker dealer is trained via the internet in
January & in July on AML issues. The board doesn't take the internet training. Instead, the compliance
officer organizes a luncheon for them where an outsider comes in & trains them. The program provides
for the appointment of a compliance officer, & once a year the compliance officer conducts an audit to
test the program. In what respect does the program need improvement? - v'v'The AMI program should
be tested by an independent person, not the compliance officer.
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? -
VvV 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 & complete basis.
Failure to do so can result in adverse action & 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 & authority
form the government
About an hour before closing time, a construction worker comes to a financial institution & wants to
provide cash in exchange for sending money abroad. It is the middle of summer & the customer
indicates that he's been outside for the bulk of the day & needs to send money to a family member who
is in another country. Which of the following would be considered the biggest concern with the
customer & his request? - v'v' The customer is not able to provide a reasonable response as to the
source of the funds.
According to FATF Recommendations, countries should? - v'v Render Mutual Legal Assistance,
Notwithstanding the absence of dual criminality.
Where dual criminality is required consider the required, consider the requirement satisfied for all like
categorized & denominated offenses.
According to the 1999 U.S. Customs "trade advisory" titled "The Black Market Peso Exchange," What are
the 3 red flags as indicators of BMPE? - v'v/Payment made in cash by 3rd party with no connection to
transaction. Payment made by wire transfers from 3rd parties unconnected to transaction. Payment
made with checks, bank drafts or money order not drawn on the account of the purchaser.
According to the Basel Committee on Banking Supervision's paper entitled "Compliance and the
Compliance Function in banks," What are the responsibilities of the Board Of Directors for Compliance? -
Answers | Verified | Latest 2024 Version
40 Recommendation highlights are? - vV
Risk-Base approach.
Designated categories of offenses.
Terrorist financing & financing of proliferation.
Knowledge & criminal liability.
A "Payable-Through Account" PTA is a master correspondent account established at a domestic bank by
a foreign bank. The Home-Country Customers of the foreign bank, which is called the "Master
Accountholder" are permitted to conduct a wide range of banking transactions through the PTA typically
those customers, called "sub-accountholders", can write checks make deposits & withdrawals, & wire
funds through the PTA almost as if they were direct, local customers of the US bank. The sub-
accountholders, who can number in the hundreds & who rarely have direct contact with the domestic US
banks, are given checks by which to draw funds on the PTA. In 1 US case the regulator found that the
domestic bank had failed to adequately supervise the PTAs. To implement effective internal control &
operating systems concerning PTAs, to establish "Know Your Customer" procedures for Sub-
Accountholders & to maintain adequate staffing. The - v v/ Preparing a "Risk Assessment" about each
PTA.
Obtaining a signed document from each Sub-Accountholder subjecting the subaccount to state & federal
laws & regulations in spite of any banking secrecy laws of any other jurisdiction.
Preparing a "PTA Action Plan" that examiners the adequacy of its capabilities to monitor PTAs & plans to
improve them.
Obtaining detailed information from the master account holder about the way it is supervised by its
home country agencies.
Conducting periodic verification of the information provided by the foreign bank.
Developing a policy regarding termination of PRA accounts where information it receives is materially
inaccurate or incomplete.
A bank in Italy holds a business account for a Italian company that sells gold throughout Europe & the
Western Hemisphere. The bank knows the purpose of this account is to receive payment for sales. A
review of the account shows a pattern of wire transfers coming from Payable-Through Accounts. There is
,
,
, A small Broker-Dealer has an AML compliance program that addresses procedures for filing STR &
includes policies, procedures a& internal controls for customer identification, monitoring accounts &
identifying Money Laundering red flags. Every employee of the broker dealer is trained via the internet in
January & in July on AML issues. The board doesn't take the internet training. Instead, the compliance
officer organizes a luncheon for them where an outsider comes in & trains them. The program provides
for the appointment of a compliance officer, & once a year the compliance officer conducts an audit to
test the program. In what respect does the program need improvement? - v'v'The AMI program should
be tested by an independent person, not the compliance officer.
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? -
VvV 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 & complete basis.
Failure to do so can result in adverse action & 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 & authority
form the government
About an hour before closing time, a construction worker comes to a financial institution & wants to
provide cash in exchange for sending money abroad. It is the middle of summer & the customer
indicates that he's been outside for the bulk of the day & needs to send money to a family member who
is in another country. Which of the following would be considered the biggest concern with the
customer & his request? - v'v' The customer is not able to provide a reasonable response as to the
source of the funds.
According to FATF Recommendations, countries should? - v'v Render Mutual Legal Assistance,
Notwithstanding the absence of dual criminality.
Where dual criminality is required consider the required, consider the requirement satisfied for all like
categorized & denominated offenses.
According to the 1999 U.S. Customs "trade advisory" titled "The Black Market Peso Exchange," What are
the 3 red flags as indicators of BMPE? - v'v/Payment made in cash by 3rd party with no connection to
transaction. Payment made by wire transfers from 3rd parties unconnected to transaction. Payment
made with checks, bank drafts or money order not drawn on the account of the purchaser.
According to the Basel Committee on Banking Supervision's paper entitled "Compliance and the
Compliance Function in banks," What are the responsibilities of the Board Of Directors for Compliance? -
