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Question #81

Which of the following customers require the most enhanced due diligence?

A . A resident of a non-cooperative jurisdiction.
B . An international business corporation.
C . A politically exposed person.
D . An established customer.

Richtige Antwort: C
C

Explanation:

A politically exposed person (PEP) is a customer who requires the most enhanced due diligence (EDD). This is because PEPs are individuals who hold or have held prominent public positions, such as heads of state, senior politicians, judges, military officers, or directors of state-owned enterprises, and who may pose a higher risk of money laundering, corruption, or bribery due to their influence and access to public funds1. EDD measures for PEPs may include obtaining senior management approval, establishing the source of wealth and funds, and conducting enhanced ongoing monitoring of the business relationship2.

The other customers listed do not necessarily require the most EDD, although they may still present a higher risk of money laundering depending on the circumstances. A resident of a non-cooperative jurisdiction is a customer who lives in a country or territory that has been identified by the Financial Action Task Force (FATF) or other international bodies as having weak or deficient anti-money laundering (AML) standards or posing a threat to the international financial system3. EDD measures for such customers may include obtaining additional information or documentation, applying extra scrutiny to transactions, or refusing to establish or continue the business relationship4. An international business corporation is a customer who operates in multiple jurisdictions and may have complex or opaque ownership structures that can conceal the identity or activity of the beneficial owners or controllers. EDD measures for such customers may include verifying the legal existence and structure of the entity, identifying the beneficial owners and controllers, and understanding the nature and purpose of the business relationship. An established customer is a customer who has a long-standing and regular business relationship with the financial institution and who may have a lower risk of money laundering due to the familiarity and trust that has been built over time. EDD measures for such customers may not be required unless there are changes in the customer’s profile, behavior, or risk level.

Reference: 1: Politically Exposed Persons (Recommendations 12 and 22) – FATF1 2: High-risk customers, including politically exposed persons | FCA2 3: High-Risk and Other Monitored Jurisdictions – FATF3 4: Your responsibilities under money laundering supervision | GOV.UK4: International Business Corporations – ACAMS: Anti-Money Laundering Customer Due Diligence | Veriff.com: Customer Due Diligence – ACAMS: Anti-money laundering C a guide to customer due diligence

Question #82

What are two sources for maintaining up-to-date sanctions information? (Choose two.)

A . U.S. Federal Bureau of Investigation’s National Security Letters
B . U.S. Department of the Treasury Office of Foreign Assets Control
C . U.S. Department of the Treasury C Section 311 C Special Measures
D . Financial Action Task Force’s list of High Risk and Non-Cooperative Jurisdictions

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Question #83

Which is an objective of the Financial Action Task Force (FATF)-Style Regional Bodies (FSRBs)?

A . To issue their own recommendations, considering local typologies, ignoring the FATF 40 recommendations
B . To work in parallel with FATF by operating on the basis of (mutual, joint, or common) recognition of their work
C . To enforce implementation of the FATF recommendations amongst its member countries
D . To work independently from FATF and to be closely involved in improving law enforcement outcomes in their regions

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Question #84

A compliance officer is conducting a review of the automated transaction monitoring system.

What would be most likely to result in a change in the monitoring system parameters?

A . The local paper runs stories that sully the institution’s reputation in the marketplace
B . Law enforcement issues a subpoena for a particular customer’s account records
C . The national Financial intelligence Unit issues new risk indicators
D . The institution’s creditworthiness thresholds change

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Richtige Antwort: C
C

Explanation:

An automated transaction monitoring system is a tool that analyzes transactions and customer behavior for signs of money laundering or other financial crimes, and generates alerts when suspicious or unusual activity is detected. The system relies on a set of rules and parameters that define what constitutes normal and abnormal transactions, based on the risk profile and business nature of the financial institution or business. These rules and parameters need to be periodically reviewed and updated to ensure that they are effective and compliant with the latest regulations and best practices.

One of the factors that would most likely result in a change in the monitoring system parameters is when the national Financial intelligence Unit (FIU) issues new risk indicators. The FIU is a central authority that collects, analyzes, and disseminates financial intelligence related to money laundering, terrorist financing, and other financial crimes. The FIU also provides guidance and feedback to financial institutions and businesses on how to comply with their anti-money laundering (AML) obligations and improve their transaction monitoring systems. The FIU may issue new risk indicators based on its analysis of emerging trends, typologies, and threats in the financial sector, or based on international standards and recommendations. These risk indicators are intended to help financial institutions and businesses identify and report suspicious transactions more effectively and efficiently.

Therefore, when the FIU issues new risk indicators, the financial institution or business should review its existing monitoring system parameters and adjust them accordingly to reflect the new risks and scenarios. For example, the FIU may issue new risk indicators related to the use of cryptocurrencies, virtual assets, or online platforms for money laundering or terrorist financing. In that case, the financial institution or business should update its monitoring system parameters to include new rules, thresholds, or patterns that capture these activities and generate alerts for further investigation.

Reference: 1: The Complete Guide to Transaction Monitoring: Everything to Know

2: AML Scenarios: Transaction Monitoring Challenges

3: Setting AML Transaction Monitoring Thresholds

4: Automated Transaction Monitoring C Considerations for System Implementation

5: ACAMS (2020). CAMS Certification Package (6th Edition)

Question #85

A local law enforcement officer notifies the bank compliance officer that he is working on an insurance fraud scheme that appears to be running transactions using the account of a bank employee. The law enforcement officer refers to a kiting suspicious transaction report filed by the compliance officer and requests further information.

What action should the compliance officer take?

A . Inform the board of directors
B . Call the employee and demand an explanation
C . Allow access to the bank’s documents immediately
D . Provide the information to the law enforcement in response to a formal written request

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Question #86

When a government imposes economic sanctions on a target, the purpose is to:

A . Indicate that the use of military force is likely unless the target complies with the government’s interests.
B . Encourage non-governmental organizations (NGOs) to increase the provision of humanitarian and charitable aid to the target.
C . Protect the rights of the citizens of the target country against their own government and improve financial stability in the region.
D . Alter the behavior of the state or non-state target that threatens the interests of that government or violates international norms.

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Question #87

Which step should financial institutions take when complying with sanctions requirements?

A . Adopt automatic screening systems to detect designated persons and entities.
B . Change the risk profile to "high-risk" if an existing customer becomes a sanctioned entity and continue monitoring further transactions.
C . Conduct enhanced due diligence (EDD) for prohibited entities on the sanctions list.
D . Freeze the funds or assets of designated persons and entities once this decision is approved by the board.

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Question #88

Which are the two most common controls a financial institution (FI) uses to identify suspicious money-laundering activity? (Choose two.)

A . Sanctions screening
B . Adverse media information
C . Governmental subpoena
D . Search warrant
E . Transaction monitoring rules

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Question #89

The Egmont Group Statement of Purpose

A . 1, 2, and 3 only
B . 1, 2, and 4 only
C . 1, 3, and 4 only
D . 2, 3, and 4 only

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Question #90

When should a financial institution (FI) exit a relationship? (Choose two.)

A . The reputational risk to the FI posed by closing the account
B . The request from law enforcement to close the account
C . The FI’s requirements for opening an account
D . The suspicious conduct of the account holder
E . The FI’s stated policies and procedures for closing an account

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