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Question #111

In order for a terrorist organization to move funds from Cyprus to England through trade-based money laundering, which technique would be used?

A . An England-based exporter under-invoices a shipment to Cyprus.
B . An England-based exporter over-invoices a shipment to Cyprus.
C . A Cyprus-based exporter short-ships a shipment to London.
D . A Cyprus-based exporter over-invoices a shipment to London.

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Question #112

In May 2002, the Wolfsberg Principles on Private Banking were revised and included a section that prohibits the use of internal non-client accounts in a manner that would prevent officials from appropriate monitoring movements of funds or keep clients from being linked to the movement of funds on their behalf.

What is another name for these internal, non-client accounts?

A . Trust accounts
B . Correspondent accounts
C . Concentration accounts
D . Pay through accounts

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Question #113

Which three criteria does a shell bank meet according to the Wolfsberg Principles on Correspondent Banking? Choose 3 answers.

A . It does not conduct business at a fixed address in a jurisdiction in which it is authorized to conduct business.
B . It does not employ one or more individuals at its fixed address where it is authorized to conduct business or maintain operating records at that address
C . It is not subject to AML laws that require it to implement an AML program
D . It is not subject to inspection by the banking authority that licensed it to conduct banking activities

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Question #114

Which is a red flag for funds transfers?

A . Funds transfers are received in numerous small quantities from entities that are in related industries.
B . Funds transfers are repeatedly sent to the same beneficiary out of line with the business purpose.
C . Funds transfers are repetitive and within expected patterns.
D . Funds transfers are to a higher-risk geographic location with a known supplier within the same industry as the originator.

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Richtige Antwort: B
B

Explanation:

Funds transfers are electronic payments that move money from one account to another, either within the same financial institution or across different institutions, countries, or currencies1. Funds transfers are commonly used for legitimate purposes, such as remittances, trade, or investment, but they can also be abused by money launderers, terrorists, or fraudsters to move illicit funds or conceal their origin or destination2. Therefore, financial institutions and other entities that offer funds transfer services are required to apply anti-money laundering and counter-terrorism financing (AML/CFT) measures, such as customer due diligence, transaction monitoring, record-keeping, and reporting of suspicious activities2.

One of the red flags for funds transfers that may indicate money laundering or other criminal activity is when funds transfers are repeatedly sent to the same beneficiary out of line with the business purpose3. This could suggest that the originator and the beneficiary are colluding to layer or integrate illicit funds, or to evade reporting or sanctions requirements. For example, a business may send multiple funds transfers to the same supplier, but the amounts or frequencies do not match the invoices or contracts, or the supplier is located in a high-risk jurisdiction or is subject to sanctions. Alternatively, an individual may send frequent funds transfers to the same person, but the relationship or the reason for the transfers is unclear or inconsistent, or the person is associated with a criminal or terrorist organization. In such cases, the financial institution or the funds transfer service provider should conduct enhanced due diligence, verify the source and purpose of the funds, and report any suspicious activity to the relevant authorities.

Reference: 1: Wire Transfer Definition – Investopedia

2: International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation – The FATF Recommendations | FATF

3: Wire Transfer Red Flags: Money Laundering & Fraud Risks – Alessa1

Reference: https://www.fmu.gov.pk/docs/Red-flags-for-banks.pdf

Question #115

Which are key objectives of the Egmont Group? (Select Two.)

A . Setting international standards that aim to prevent
B . AML Providing a platform for the secure exchange of financial intelligence
C . Serving as a prudential regulator for global financial institutions
D . Serving as an authoritative body in the field of anti-corruption
E . Serving as a united body of financial intelligence units across the world

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Question #115

Which are key objectives of the Egmont Group? (Select Two.)

A . Setting international standards that aim to prevent
B . AML Providing a platform for the secure exchange of financial intelligence
C . Serving as a prudential regulator for global financial institutions
D . Serving as an authoritative body in the field of anti-corruption
E . Serving as a united body of financial intelligence units across the world

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Question #117

A bank customer operates a fuel station as a sole proprietorship. The customer places deposits and other credits in a business account. The customer routinely transfers money from the business account to a brokerage account where he invests in money market securities. The customer also routinely makes monthly transfers to a credit card and line of credit to pay off balances. The volume of activity flowing through the business account has doubled in the past 3 months. An internal investigator reviews business account statements and credit card activity for the past 3 months, scans media articles about the customer, and interviews the account officer about the customer and account activity. This internal investigation did not provide an explanation for the increased activity1.

Which of the following should the anti-money laundering specialist recommend to the internal investigator?

A . Concentrate on trades made in the brokerage account.
B . Review activity in all related customer accounts in the past year.
C . Analyze account activity for selected accounts since the accounts were opened.
D . No additional steps are necessary because this was a thorough review of the activity.

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Question #118

Which two factors should increase the risk of a correspondent bank customer and require additional due diligence according to the Wolfsberg Anti-Money Laundering Principles for Correspondent Banking? (Choose two.)

A . The customer is located in a Financial Action Task Force member country and provides services primarily to a local individual customer.
B . The customer is located in a Financial Action Task Force member country and the bank’s head of information security is a politically exposed person.
C . The customer is located in a Financial Action Task Force member country and provides services to other correspondent banks in neighboring countries.
D . The customer is located in a non-Financial Action Task Force member country and services mostly commercial customers who engage in international trade.

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Richtige Antwort: BD
BD

Explanation:

According to the Wolfsberg Anti-Money Laundering Principles for Correspondent Banking, the risk of a correspondent bank customer depends on various factors, such as the nature of the customer’s business, the customer’s location, the products and services offered, the customer’s ownership and management structure, and the customer’s customer base1. Among these factors, two that should increase the risk and require additional due diligence are:

The customer is located in a Financial Action Task Force (FATF) member country and the bank’s head of information security is a politically exposed person (PEP). A PEP is an individual who is or has been entrusted with a prominent public function, such as a senior government official, a judicial or military officer, a senior executive of a state-owned corporation, or a political party leader2. PEPs pose a higher risk of money laundering, corruption, or bribery due to their influence and access to public funds3. Therefore, a correspondent bank customer that has a PEP in a key position should be subject to enhanced due diligence, such as verifying the source of funds, the purpose of the relationship, and the PEP’s reputation and integrity4.

The customer is located in a non-FATF member country and services mostly commercial customers who engage in international trade. A non-FATF member country is a country that is not part of the FATF, an inter-governmental body that sets standards and promotes effective implementation of legal, regulatory, and operational measures for combating money laundering, terrorist financing, and other related threats to the integrity of the international financial system5. Non-FATF member countries may have weaker or less consistent anti-money laundering and counter-terrorist financing regimes, and may pose a higher risk of financial crime or sanctions evasion6. Moreover, a correspondent bank customer that services mostly commercial customers who engage in international trade may be exposed to trade-based money laundering, which is the process of disguising the proceeds of crime and moving value through the use of trade transactions7. Therefore, a correspondent bank customer that operates in a non-FATF member country and deals with international trade should be subject to enhanced due diligence, such as obtaining information on the nature and volume of the trade transactions, the origin and destination of the goods, and the identity and reputation of the trade counterparties8.

The other options are not correct because they do not necessarily increase the risk of a correspondent bank customer or require additional due diligence. A customer that is located in a FATF member country and provides services primarily to a local individual customer may pose a lower risk of money laundering or terrorist financing, as the customer’s activities are subject to the FATF standards and recommendations, and the customer’s customer base is less likely to involve complex or cross-border transactions. A customer that is located in a FATF member country and provides services to other correspondent banks in neighboring countries may also pose a lower risk of money laundering or terrorist financing, as the customer’s activities are subject to the FATF standards and recommendations, and the customer’s customer base is composed of regulated financial institutions that are subject to their own anti-money laundering and counter-terrorist financing obligations.

Answer BD

According to the Wolfsberg Anti-Money Laundering Principles for Correspondent Banking, the risk of a correspondent bank customer depends on various factors, such as the nature of the customer’s business, the customer’s location, the products and services offered, the customer’s ownership and management structure, and the customer’s customer base1. Among these factors, two that should increase the risk and require additional due diligence are:

The customer is located in a Financial Action Task Force (FATF) member country and the bank’s head of information security is a politically exposed person (PEP). A PEP is an individual who is or has been entrusted with a prominent public function, such as a senior government official, a judicial or military officer, a senior executive of a state-owned corporation, or a political party leader2. PEPs pose a higher risk of money laundering, corruption, or bribery due to their influence and access to public funds3. Therefore, a correspondent bank customer that has a PEP in a key position should be subject to enhanced due diligence, such as verifying the source of funds, the purpose of the relationship, and the PEP’s reputation and integrity4.

The customer is located in a non-FATF member country and services mostly commercial customers who engage in international trade. A non-FATF member country is a country that is not part of the FATF, an inter-governmental body that sets standards and promotes effective implementation of legal, regulatory, and operational measures for combating money laundering, terrorist financing, and other related threats to the integrity of the international financial system5. Non-FATF member countries may have weaker or less consistent anti-money laundering and counter-terrorist financing regimes, and may pose a higher risk of financial crime or sanctions evasion6. Moreover, a correspondent bank customer that services mostly commercial customers who engage in international trade may be exposed to trade-based money laundering, which is the process of disguising the proceeds of crime and moving value through the use of trade transactions7. Therefore, a correspondent bank customer that operates in a non-FATF member country and deals with international trade should be subject to enhanced due diligence, such as obtaining information on the nature and volume of the trade transactions, the origin and destination of the goods, and the identity and reputation of the trade counterparties8.

Question #119

Which principles should be included in a FATF-Style Regional Body (FSRB) update? (Choose two.)

A . Issue country-specific Mutual Evaluation reports
B . Address AML/CFT technical assistance of individual members
C . Identify jurisdictions with weak AML/CFT regimes
D . Establish AML/CFT standards and typologies
E . Protect the reputation and standing of FATF

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Richtige Antwort: A, C
A, C

Explanation:

According to the Anti-Money Laundering Specialist (the 6th edition) resources, FSRBs are regional organizations that help the FATF implement its global AML/CFT policy and standards in over 200 affiliated countries1. FSRBs have their own high-level principles and objectives that govern their relationship with the FATF and their members2. Among these principles and objectives, two that should be included in a FSRB update are:

Issue country-specific Mutual Evaluation reports. This is the process by which FSRBs assess the compliance and effectiveness of their members’ AML/CFT systems, based on the FATF standards and methodology3. Mutual Evaluation reports provide an in-depth analysis of the strengths and weaknesses of each jurisdiction, as well as recommendations for improvement4.

Identify jurisdictions with weak AML/CFT regimes. This is the process by which FSRBs, in coordination with the FATF, monitor and publicly list the countries that pose a risk to the international financial system due to their strategic deficiencies in AML/CFT. This process aims to encourage and assist these jurisdictions to address their gaps and enhance their cooperation with the global network. The other three options are incorrect because:

Address AML/CFT technical assistance of individual members is not a principle that should be included in a FSRB update, as it is not a core function of FSRBs. FSRBs may facilitate or coordinate technical assistance, but they are not the primary providers or funders of such assistance. Establish AML/CFT standards and typologies is not a principle that should be included in a FSRB update, as it is not a role of FSRBs. FSRBs are expected to adopt and implement the FATF standards, not to create their own. Typologies are the methods and trends of money laundering and terrorist financing, which are identified and analyzed by the FATF and FSRBs through research and workshops. Protect the reputation and standing of FATF is not a principle that should be included in a FSRB update, as it is not a responsibility of FSRBs. FSRBs are autonomous and independent organizations that have their own governance and accountability mechanisms. FSRBs are expected to cooperate and coordinate with the FATF, but not to act as its agents or representatives.

Reference: 1: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 64 2: FATF, High-Level Principles for the Relationship between the FATF and the FATF-Style Regional Bodies, February 2019, 3 3: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 65 4: FATF, FATF Methodology for Assessing Technical Compliance with the FATF Recommendations and the Effectiveness of AML/CFT Systems, February 2013 (updated October 2019), [12]: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 66: FATF, High-Risk and Other Monitored Jurisdictions, 4: FATF, High-Level Principles for the Relationship between the FATF and the FATF-Style Regional Bodies, February 2019, 3, p. 4: FATF, High-Level Principles for the Relationship between the FATF and the FATF-Style Regional Bodies, February 2019, 3, p. 2: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 67: FATF, High-Level Principles for the Relationship between the FATF and the FATF-Style Regional Bodies, February 2019, 3, p. 3: FATF, High-Level Principles for the Relationship between the FATF and the FATF-Style Regional Bodies, February 2019, 3, p. 5: FATF, FATF Methodology for Assessing Technical Compliance with the FATF Recommendations and the Effectiveness of AML/CFT Systems, February 2013 (updated October 2019), [12], p. 9: FATF, High-Risk and Other Monitored Jurisdictions, 4, p. 1

Reference: https://www.fatf-gafi.org/media/fatf/documents/High-Level%20Principles%20and%20Objectives%20for%20FATF%20and%20FSRBs.pdf

Question #120

To ensure that an institution’s anti-money laundering program is current, which step should be taken?

A . The program should be evaluated and updated at least every six months be the Board of Directors
B . The program should be reviews by a federal law enforcement officer for gaps in controls
C . The program should be sent to the institution’s government regulator on a periodic basis
D . The program should be reassessed at least annually

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Richtige Antwort: D
D

Explanation:

According to the Anti-Money Laundering Specialist (the 6th edition) by ACAMS, an institution’s anti-money laundering program should be reassessed at least annually to ensure that it is current, effective, and compliant with the applicable laws and regulations. The reassessment should include a review of the institution’s risk assessment, policies and procedures, internal controls, training, and independent testing. The reassessment should also consider any changes in the institution’s products, services, customers, geographic locations, or business environment that may affect its exposure to money laundering and terrorist financing risks1.

The other options are not consistent with the best practices of maintaining an up-to-date anti-money laundering program. For example:

The program should be evaluated and updated at least every six months by the Board of Directors. While the Board of Directors has the ultimate responsibility for overseeing the institution’s anti-money laundering program, it is not required to evaluate and update the program every six months. This may be too frequent and impractical, especially for large and complex institutions. The Board of Directors should, however, approve the program and any significant changes, and ensure that senior management implements and enforces the program effectively1.

The program should be reviewed by a federal law enforcement officer for gaps in controls. While federal law enforcement agencies may conduct investigations or examinations of the institution’s anti-money laundering program, they are not responsible for reviewing the program for gaps in controls. This is the role of the institution’s internal audit function or an external independent party, who should conduct periodic testing of the program’s adequacy and effectiveness1.

The program should be sent to the institution’s government regulator on a periodic basis. While the institution’s government regulator may request or review the institution’s anti-money laundering program as part of its supervisory or enforcement activities, the institution is not obligated to send the program to the regulator on a periodic basis. The institution should, however, report any suspicious or unusual transactions or activities to the relevant authorities, such as the Financial Crimes Enforcement Network (FinCEN) or the Office of Foreign Assets Control (OFAC)1.

Reference: Anti-Money Laundering Specialist (the 6th edition) by ACAMS