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Information
CAMS All Topics Cover:
Risks and Methods of Money Laundering
and Terrorist Financing
What is Money Laundering?
Three Stages in the Money Laundering Cycle
The Economic and Social Consequences of Money Laundering
AML/CFT Compliance Programs and Individual Accountability
Methods of Money Laundering
Banks and Other Depository Institutions
ELECTRONIC TRANSFERS OF FUNDS
REMOTE DEPOSIT CAPTURE
CORRESPONDENT BANKING
PAYABLE THROUGH ACCCOUNTS
CONCENTRATION ACCOUNTS
PRIVATE BANKING
USE OF PRIVATE INVEST COMPANIES IN PRIVATE BANKING
POLITICALLY EXPOSED PERSONS (PEPS)
STRUCTURING
Credit Unions and Building Societies
Non-Bank Financial Institutions
CREDIT CARD INDUSTRY
THIRD-PARTY PAYMENT PROCESSORS
MONEY SERVICES BUSINESSES
INSURANCE COMPANIES
SECURITIES BROKER-DEALERS
Variety and Complexity of Securities
High-risk Securities
Multiple Layers and Third-party Risk
Non-Financial Businesses and Professions
DEALERS IN HIGH VALUE ITEMS (PRECIOUS METALS, JEWELRY, ART, ETC)
TRAVEL AGENCIES
VEHICLE SELLERS
GATEKEEPERS: NOTARIES, ACCOUNTANTS, AUDITORS, AND LAWYERS
INVESTMENT AND COMMODITY ADVISORS
TRUST AND COMPANY SERVICE PROVIDERS
REAL ESTATE
International Trade Activity
FREE TRADE ZONES
TRADE-BASED MONEY LAUNDERING TECHNIQUES
BLACK MARKET PESO EXCHANGE
Risk Associated with New
Payment Products and Services
Prepaid Cards, Mobile Payments And Internet-Based Payment Services
Virtual Currency
Corporate Vehicles Used to Facilitate Illicit Finance
Public Companies and Private Limited Companies
BEARER SHARES IN CORPORATE FORMATION
Shell and Shelf Companies
Trusts
Terrorist Financing
DIFFERENCES AND SIMILARITIES BETWEEN
TERRORIST FINANCING AND MONEY LAUNDERING
DETECTING TERRORIST FINANCING
HOW TERRORISTS RAISE, MOVE AND STORE FUNDS
Use of Hawala and Other Informal Value Transfer Systems
Use of Charities or Non-Profit Organizations (NPOs)
Emerging Risks for Terrorist Financing
International AML/CFT Standards
Financial Action Task Force (FATF)
FATF Objectives
FATF Recommendations
FATF Members and Observers
Non-Cooperative Countries
The Basel Committee on Banking Supervision
History of the Basel Committee
European Union Directives on Money Laundering
FIRST DIRECTIVE
SECOND DIRECTIVE
THIRD DIRECTIVE
FOURTH DIRECTIVE
OTHER RELEVANT LEGAL DOCUMENTS
FATF-Style Regional Bodies
FATF-STYLE REGIONAL BODIES AND FATF ASSOCIATE MEMBERS
ASIA/PACIFIC GROUP ON MONEY LAUNDERING (APG)
CARIBBEAN FINANCIAL ACTION TASK FORCE (CFATF)
COMMITTEE OF EXPERTS ON THE EVALUATION OF
ANTI-MONEY LAUNDERING MEASURES (MONEYVAL)
FINANCIAL ACTION TASK FORCE OF LATIN AMERICA (GAFILAT)
INTER GOVERNMENTAL ACTION GROUP AGAINST
MONEY LAUNDERING IN WEST AFRICA (GIABA)
MIDDLE EAST AND NORTH AFRICA FINANCIAL ACTION
TASK FORCE (MENAFATF)
EURASIAN GROUP ON COMBATING MONEY LAUNDERING
AND FINANCING OF TERRORISM (EAG)
EASTERN AND SOUTH AFRICAN ANTI-MONEY LAUNDERING GROUP (ESAAMLG)
TASK FORCE ON MONEY LANDERING IN CENTRAL AFRICA (GABAC)
Organization of American States:
Inter-American Drug Abuse Control Commission
(Comisión Interamericana Para El Control Del Abuso De Drogas)
Egmont Group of Financial Intelligence Units
The Wolfsberg Group
The World Bank and the International Monetary Fund
Key US Legislative and Regulatory Initiatives
Applied to Transactions Internationally
USA PATRIOT Act
The Reach of the US Criminal Money
Laundering and Civil Forfeiture Laws
Office of Foreign Assets Control
Anti-Money Laundering/Counter-Terrorist Financing Compliance Programs
Assessing AML/CFT Risk
Maintaining an AML/CFT Risk Model
Understanding AML/CFT Risk
AML/CFT Risk Scoring
Assessing The Dynamic Risk of Customers
AML/CFT Risk Identification
CUSTOMER TYPE
GEOGRAPHIC LOCATION
PRODUCTS/SERVICES
AML/CFT Program
The Elements of an AML/CFT Program
A System of Internal Policies, Procedures, and Controls
AML POLICIES, PROCEDURES, AND CONTROLS
The Compliance Function
The Designation and Responsibilities of A Compliance Officer
COMMUNICATION
DELEGATION OF AML DUTIES
COMPLIANCE OFFICER ACCOUNTABILITY
AML/CFT Training
COMPONENTS OF AN EFFECTIVE TRAINING PROGRAM
WHO TO TRAIN
WHAT TO TRAIN ON
HOW TO TRAIN
WHEN TO TRAIN
WHERE TO TRAIN
Independent Audit
EVALUATING AN AML/CFT PROGRAM
Establishing a Culture of Compliance
Know Your Customer
CUSTOMER DUE DILIGENCE
MAIN ELEMENTS OF A CUSTOMER DUE DILIGENCE PROGRAM
ENHANCED DUE DILIGENCE
ENHANCED DUE DILIGENCE FOR HIGHER-RISK CUSTOMERS
ACCOUNT OPENING, CUSTOMER IDENTIFICATION AND VERIFICATION
CONSOLIDATED CUSTOMER DUE DILIGENCE
Economic Sanctions
UNITED NATIONS
EUROPEAN UNION
UNITED STATES
Sanctions List Screening
Politically Exposed Persons Screening
Know Your Employee
Suspicious or Unusual Transaction Monitoring and Reporting
Automated AML/CFT Solutions
Money Laundering and Terrorist Financing Red Flags
UNUSUAL CUSTOMER BEHAVIOR
UNUSUAL CUSTOMER IDENTIFICATION CIRCUMSTANCES
UNUSUAL CASH TRANSACTIONS
UNUSUAL NON-CASH DEPOSITS
UNUSUAL WIRE TRANSFER TRANSACTIONS
UNUSUAL SAFE DEPOSIT BOX ACTIVITY
UNUSUAL ACTIVITY IN CREDIT TRANSACTIONS
UNUSUAL COMMERCIAL ACCOUNT ACTIVITY
UNUSUAL TRADE FINANCING TRANSACTIONS
UNUSUAL INVESTMENT ACTIVITY
OTHER UNUSUAL CUSTOMER ACTIVITY
UNUSUAL EMPLOYEE ACTIVITY
UNUSUAL ACTIVITY IN A MONEY REMITTER/
CURRENCY EXCHANGE HOUSE SETTING
UNUSUAL ACTIVITY FOR VIRTUAL CURRENCY
UNUSUAL ACTIVITY IN AN INSURANCE COMPANY SETTING
UNUSUAL ACTIVITY IN A BROKER-DEALER SETTING
UNUSUAL REAL ESTATE ACTIVITY
UNUSUAL ACTIVITY FOR DEALERS OF
PRECIOUS METALS AND HIGH-VALUE ITEMS
UNUSUAL ACTIVITY INDICATIVE OF TRADE-BASED MONEY LAUNDERING
UNUSUAL ACTIVITY INDICATIVE OF HUMAN SMUGGLING
UNUSUAL ACTIVITY INDICATIVE OF HUMAN TRAFFICKING
UNUSUAL ACTIVITY INDICATIVE OF POTENTIAL TERRORIST FINANCING
CONDUCTING AND RESPONDING TO INVESTIGATIONS
Investigations Initiated by the Financial Institution
Sources of Investigations
REGULATORY RECOMMENDATIONS OR OFFICIAL FINDINGS
TRANSACTION MONITORING
REFERRALS FROM CUSTOMER-FACING EMPLOYEES
INTERNAL HOTLINES
NEGATIVE MEDIA INFORMATION
RECEIPT OF A GOVERNMENTAL SUBPOENA OR SEARCH WARRANT
SUBPOENA
SEARCH WARRANT
ORDERS TO RESTRAIN OR FREEZE ACCOUNTS OR ASSETS
Conducting the Investigation
UTILIZING THE INTERNET WHEN
CONDUCTING FINANCIAL INVESTIGATIONS
STR Decision-Making Process
FILING AN STR
QUALITY ASSURANCE
STR FILING OVERSIGHT/ESCALATION
Closing the Account
Communicating with Law Enforcement on STRs
Investigations Initiated by Law Enforcement
Decision to Prosecute a Financial Institution
for Money Laundering Violations
Responding to a Law Enforcement Investigation
Against a Financial Institution
Monitoring a Law Enforcement Investigation
Against a Financial Institution
Cooperating with Law Enforcement During
an Investigation Against a Financial Institution
Obtaining Counsel for an Investigation
Against a Financial Institution
RETAINING COUNSEL
ATTORNEY-CLIENT PRIVILEGE APPLIED TO ENTITIES AND INDIVIDUALS
DISSEMINATION OF A WRITTEN REPORT BY COUNSEL
Notices to Employees as a Result of an
Investigation Against a Financial Institution
Interviewing Employees as a Result of a Law Enforcement
Investigation Against a Financial Institution
Media Relations
AML/CFT Cooperation between Countries
FATF Recommendations on Cooperation between Countries
International Money Laundering Information Network
Mutual Legal Assistance Treaties
Financial Intelligence Units
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Question 1 of 30
1. Question
Mr. Johnson, a new client at your financial institution, exhibits suspicious behavior such as making large cash deposits followed by immediate wire transfers to overseas accounts. What should be your immediate action as per CAMS guidelines?
Correct
According to the CAMS guidelines, suspicious behavior such as rapid cash deposits followed by wire transfers to foreign accounts should trigger the filing of a SAR with FinCEN. This requirement is in accordance with the Bank Secrecy Act (BSA), which mandates financial institutions to report suspicious activities to prevent money laundering and terrorist financing.
Incorrect
According to the CAMS guidelines, suspicious behavior such as rapid cash deposits followed by wire transfers to foreign accounts should trigger the filing of a SAR with FinCEN. This requirement is in accordance with the Bank Secrecy Act (BSA), which mandates financial institutions to report suspicious activities to prevent money laundering and terrorist financing.
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Question 2 of 30
2. Question
Mr. Smith, a compliance officer at a regional bank, receives a request from a correspondent bank for a large fund transfer to an offshore account. The request lacks sufficient customer due diligence (CDD) information. What action should Mr. Smith take?
Correct
According to the Financial Action Task Force (FATF) guidelines, correspondent banks must conduct thorough due diligence on their respondents and understand the nature of transactions to mitigate money laundering risks (FATF Recommendation 13). Mr. Smith should choose option (a) to ensure compliance with CDD requirements, which are crucial in correspondent banking relationships.
Incorrect
According to the Financial Action Task Force (FATF) guidelines, correspondent banks must conduct thorough due diligence on their respondents and understand the nature of transactions to mitigate money laundering risks (FATF Recommendation 13). Mr. Smith should choose option (a) to ensure compliance with CDD requirements, which are crucial in correspondent banking relationships.
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Question 3 of 30
3. Question
Ms. Garcia, a compliance officer at a multinational bank, notices frequent small-value transactions from a payable-through account (PTA) that lack a clear business purpose. What should Ms. Garcia consider when investigating these transactions?
Correct
Under the Bank Secrecy Act (BSA), banks must monitor PTAs to ensure transactions have a legitimate business purpose and comply with Anti-Money Laundering (AML) regulations (31 CFR 1020.210). Ms. Garcia should choose option (c) to conduct a review and establish the account’s purpose, aligning with regulatory expectations for PTAs.
Incorrect
Under the Bank Secrecy Act (BSA), banks must monitor PTAs to ensure transactions have a legitimate business purpose and comply with Anti-Money Laundering (AML) regulations (31 CFR 1020.210). Ms. Garcia should choose option (c) to conduct a review and establish the account’s purpose, aligning with regulatory expectations for PTAs.
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Question 4 of 30
4. Question
Mr. Johnson, a financial analyst, notices unusual activity in a concentration account with frequent transfers from various subsidiaries. What action should Mr. Johnson take regarding these transactions?
Correct
According to the Financial Crimes Enforcement Network (FinCEN) guidelines, concentration accounts should be monitored for unusual patterns that may indicate money laundering or other illicit activities (FinCEN Guidance FIN-2013-G002). Mr. Johnson should choose option (d) to conduct a risk-based review, ensuring compliance with AML standards for concentration accounts.
Incorrect
According to the Financial Crimes Enforcement Network (FinCEN) guidelines, concentration accounts should be monitored for unusual patterns that may indicate money laundering or other illicit activities (FinCEN Guidance FIN-2013-G002). Mr. Johnson should choose option (d) to conduct a risk-based review, ensuring compliance with AML standards for concentration accounts.
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Question 5 of 30
5. Question
Dr. Lee, a private banker, receives a significant deposit from a politically exposed person (PEP) without sufficient source of funds documentation. What should Dr. Lee do regarding this deposit?
Correct
Under the Wolfsberg Group’s Principles on Private Banking, private bankers must conduct enhanced due diligence on PEPs to mitigate financial crime risks (Wolfsberg FAQs on PEPs). Dr. Lee should choose option (b) to request additional documentation, aligning with best practices in private banking compliance with AML requirements.
Incorrect
Under the Wolfsberg Group’s Principles on Private Banking, private bankers must conduct enhanced due diligence on PEPs to mitigate financial crime risks (Wolfsberg FAQs on PEPs). Dr. Lee should choose option (b) to request additional documentation, aligning with best practices in private banking compliance with AML requirements.
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Question 6 of 30
6. Question
Ms. Patel, a compliance officer, discovers that a client’s private investment company (PIC) regularly transfers funds to undisclosed beneficiaries. What should Ms. Patel consider regarding these transactions?
Correct
According to the USA PATRIOT Act, financial institutions must monitor transactions involving PICs for potential money laundering risks (USA PATRIOT Act Section 312). Ms. Patel should choose option (c) to request disclosure of beneficiaries and transaction purposes, ensuring compliance with AML regulations related to PICs.
Incorrect
According to the USA PATRIOT Act, financial institutions must monitor transactions involving PICs for potential money laundering risks (USA PATRIOT Act Section 312). Ms. Patel should choose option (c) to request disclosure of beneficiaries and transaction purposes, ensuring compliance with AML regulations related to PICs.
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Question 7 of 30
7. Question
Mr. Thompson, a compliance officer, discovers that a politically exposed person (PEP) is a beneficial owner of multiple accounts. What action should Mr. Thompson take regarding these accounts?
Correct
Under the FATF Recommendations, financial institutions must apply enhanced due diligence measures to manage risks associated with PEPs (FATF Recommendation 12). Mr. Thompson should choose option (b) to implement enhanced due diligence measures, ensuring compliance with AML requirements for accounts associated with PEPs.
Incorrect
Under the FATF Recommendations, financial institutions must apply enhanced due diligence measures to manage risks associated with PEPs (FATF Recommendation 12). Mr. Thompson should choose option (b) to implement enhanced due diligence measures, ensuring compliance with AML requirements for accounts associated with PEPs.
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Question 8 of 30
8. Question
Ms. Stewart, a compliance officer, notices a pattern of multiple cash deposits just below the threshold for currency transaction reports (CTRs). What should Ms. Stewart consider regarding these deposits?
Correct
Under the BSA regulations, financial institutions must monitor transactions for potential structuring, which involves breaking transactions into smaller amounts to avoid reporting requirements (31 CFR 1020.320). Ms. Stewart should choose option (a) to file a SAR with FinCEN, complying with AML obligations related to structuring activities.
Incorrect
Under the BSA regulations, financial institutions must monitor transactions for potential structuring, which involves breaking transactions into smaller amounts to avoid reporting requirements (31 CFR 1020.320). Ms. Stewart should choose option (a) to file a SAR with FinCEN, complying with AML obligations related to structuring activities.
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Question 9 of 30
9. Question
Mr. Evans, a compliance officer at a credit union, receives a large cash deposit from a member without sufficient identification. What action should Mr. Evans take regarding this deposit?
Correct
According to the Financial Conduct Authority (FCA) regulations, credit unions must verify the identity of members and monitor transactions for suspicious activities (FCA Handbook, CASS 5.5). Mr. Evans should choose option (b) to decline the deposit until proper identification is provided, aligning with AML requirements for credit unions and building societies.
Incorrect
According to the Financial Conduct Authority (FCA) regulations, credit unions must verify the identity of members and monitor transactions for suspicious activities (FCA Handbook, CASS 5.5). Mr. Evans should choose option (b) to decline the deposit until proper identification is provided, aligning with AML requirements for credit unions and building societies.
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Question 10 of 30
10. Question
Ms. Yang, a compliance officer at a money services business (MSB), notices significant remittance transactions with inconsistent customer information. What should Ms. Yang consider regarding these transactions?
Correct
Under the USA PATRIOT Act, MSBs must implement robust AML programs and monitor transactions for suspicious activities (USA PATRIOT Act Section 352). Ms. Yang should choose option (c) to implement enhanced customer due diligence measures, ensuring compliance with AML regulations for non-bank financial institutions.
Incorrect
Under the USA PATRIOT Act, MSBs must implement robust AML programs and monitor transactions for suspicious activities (USA PATRIOT Act Section 352). Ms. Yang should choose option (c) to implement enhanced customer due diligence measures, ensuring compliance with AML regulations for non-bank financial institutions.
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Question 11 of 30
11. Question
Mr. Davis, a compliance officer at a credit card issuer, identifies multiple instances of rapid account opening followed by large cash advances. What action should Mr. Davis take regarding these accounts?
Correct
According to the Payment Card Industry Data Security Standard (PCI DSS), credit card issuers must monitor accounts for suspicious activities and implement appropriate fraud prevention measures (PCI DSS Requirement 12). Mr. Davis should choose option (d) to freeze the accounts and notify law enforcement, aligning with AML requirements for the credit card industry.
Incorrect
According to the Payment Card Industry Data Security Standard (PCI DSS), credit card issuers must monitor accounts for suspicious activities and implement appropriate fraud prevention measures (PCI DSS Requirement 12). Mr. Davis should choose option (d) to freeze the accounts and notify law enforcement, aligning with AML requirements for the credit card industry.
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Question 12 of 30
12. Question
Mr. Anderson operates a small e-commerce platform that uses a third-party payment processor to handle transactions. Recently, he noticed an unusual pattern of transactions involving large sums of money from several new accounts that seem unrelated to any actual sales. What should Mr. Anderson do in this situation?
Correct
According to the Financial Action Task Force (FATF) Guidance on Payment Services, it is crucial for businesses using third-party payment processors to monitor transactions for suspicious activity. Reporting suspicious transactions to the payment processor’s compliance department ensures compliance with anti-money laundering (AML) regulations and helps prevent potential money laundering activities (FATF, Recommendation 16).
Incorrect
According to the Financial Action Task Force (FATF) Guidance on Payment Services, it is crucial for businesses using third-party payment processors to monitor transactions for suspicious activity. Reporting suspicious transactions to the payment processor’s compliance department ensures compliance with anti-money laundering (AML) regulations and helps prevent potential money laundering activities (FATF, Recommendation 16).
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Question 13 of 30
13. Question
Ms. Garcia runs a money services business (MSB) that offers currency exchange and money transfer services. A customer requests to send a large amount of cash to a foreign country without providing clear information on the purpose of the transaction. What is the appropriate action for Ms. Garcia?
Correct
Explanation: According to the Bank Secrecy Act (BSA) and Financial Crimes Enforcement Network (FinCEN) guidelines for MSBs, conducting enhanced due diligence (EDD) is necessary for transactions that appear suspicious or lack clear information regarding the purpose and source of funds. This helps mitigate risks associated with potential money laundering or terrorist financing activities (FinCEN, MSB Guidance).
Incorrect
Explanation: According to the Bank Secrecy Act (BSA) and Financial Crimes Enforcement Network (FinCEN) guidelines for MSBs, conducting enhanced due diligence (EDD) is necessary for transactions that appear suspicious or lack clear information regarding the purpose and source of funds. This helps mitigate risks associated with potential money laundering or terrorist financing activities (FinCEN, MSB Guidance).
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Question 14 of 30
14. Question
XYZ Insurance Company receives a policy premium payment of $100,000 in cash from a customer. The customer insists on making cash payments regularly due to personal preferences. What action should XYZ Insurance Company take?
Correct
According to the USA PATRIOT Act and regulations by the U.S. Department of the Treasury, insurance companies must conduct customer due diligence (CDD) for cash transactions exceeding $10,000 and file a SAR for suspicious activities, including large cash payments that are inconsistent with the customer’s known profile or risk factors (31 CFR 1020.220).
Incorrect
According to the USA PATRIOT Act and regulations by the U.S. Department of the Treasury, insurance companies must conduct customer due diligence (CDD) for cash transactions exceeding $10,000 and file a SAR for suspicious activities, including large cash payments that are inconsistent with the customer’s known profile or risk factors (31 CFR 1020.220).
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Question 15 of 30
15. Question
Jackson Securities, a broker-dealer, offers trading services for high-risk securities. They receive a large deposit from a customer with unclear sources of funds and a complex ownership structure involving multiple entities. What is the appropriate action for Jackson Securities?
Correct
According to the Financial Industry Regulatory Authority (FINRA) and Securities and Exchange Commission (SEC) regulations, broker-dealers must conduct enhanced due diligence (EDD) on transactions involving high-risk securities and complex ownership structures. This helps ensure compliance with AML requirements and mitigates risks associated with money laundering or securities fraud (FINRA Rule 3310).
Incorrect
According to the Financial Industry Regulatory Authority (FINRA) and Securities and Exchange Commission (SEC) regulations, broker-dealers must conduct enhanced due diligence (EDD) on transactions involving high-risk securities and complex ownership structures. This helps ensure compliance with AML requirements and mitigates risks associated with money laundering or securities fraud (FINRA Rule 3310).
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Question 16 of 30
16. Question
Global Investments Inc. deals in a variety of securities, including complex financial instruments with high liquidity. They receive a significant investment from a new client based in a high-risk jurisdiction known for weak AML controls. What steps should Global Investments Inc. take?
Correct
According to FATF recommendations and global AML standards, financial institutions dealing in complex securities should conduct thorough customer due diligence (CDD), especially for clients from high-risk jurisdictions. This includes verifying the client’s background, funding sources, and assessing the potential risks associated with the transaction (FATF, Recommendation 10).
Incorrect
According to FATF recommendations and global AML standards, financial institutions dealing in complex securities should conduct thorough customer due diligence (CDD), especially for clients from high-risk jurisdictions. This includes verifying the client’s background, funding sources, and assessing the potential risks associated with the transaction (FATF, Recommendation 10).
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Question 17 of 30
17. Question
Blackstone Investments manages portfolios that include high-risk securities traded on international markets. They receive a substantial investment from a politically exposed person (PEP) without a clear explanation of the source of funds. What should Blackstone Investments do?
Correct
According to the Wolfsberg Group’s guidelines and FATF recommendations, financial institutions must conduct enhanced due diligence (EDD) on transactions involving PEPs and high-risk securities. This helps mitigate risks associated with potential money laundering, corruption, or abuse of entrusted power (Wolfsberg Group, PEP Guidance).
Incorrect
According to the Wolfsberg Group’s guidelines and FATF recommendations, financial institutions must conduct enhanced due diligence (EDD) on transactions involving PEPs and high-risk securities. This helps mitigate risks associated with potential money laundering, corruption, or abuse of entrusted power (Wolfsberg Group, PEP Guidance).
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Question 18 of 30
18. Question
Everest Investments uses third-party service providers for managing client accounts and processing transactions. They notice discrepancies in account statements and suspect unauthorized activities involving multiple layers of transactions. What is the appropriate action for Everest Investments?
Correct
According to the Basel Committee on Banking Supervision (BCBS) guidelines and AML best practices, financial institutions should implement rigorous due diligence procedures for third-party service providers, especially when discrepancies or suspicious activities are detected. This helps mitigate risks associated with money laundering, fraud, or unauthorized transactions (BCBS, Third-Party Risk Management).
Incorrect
According to the Basel Committee on Banking Supervision (BCBS) guidelines and AML best practices, financial institutions should implement rigorous due diligence procedures for third-party service providers, especially when discrepancies or suspicious activities are detected. This helps mitigate risks associated with money laundering, fraud, or unauthorized transactions (BCBS, Third-Party Risk Management).
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Question 19 of 30
19. Question
Greenfield Consulting, a non-financial business, provides advisory services to international clients on investment opportunities. They receive substantial payments from clients without clear business purposes or identifiable sources of funds. What action should Greenfield Consulting take?
Correct
According to FATF recommendations and national AML regulations, non-financial businesses providing advisory services must conduct due diligence on clients, including verifying business backgrounds and sources of funds. This helps prevent potential money laundering activities and ensures compliance with AML/CFT requirements (FATF, Recommendation 22).
Incorrect
According to FATF recommendations and national AML regulations, non-financial businesses providing advisory services must conduct due diligence on clients, including verifying business backgrounds and sources of funds. This helps prevent potential money laundering activities and ensures compliance with AML/CFT requirements (FATF, Recommendation 22).
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Question 20 of 30
20. Question
ArtWorks Gallery specializes in selling high-value art pieces to international collectors. They receive a large payment in cash from a new client who refuses to disclose personal information or the origin of the funds. What should ArtWorks Gallery do?
Correct
According to FATF guidelines and national AML/CFT regulations, dealers in high-value items must conduct customer due diligence (CDD) for cash transactions exceeding specified thresholds and file SARs for suspicious activities. This helps mitigate risks associated with money laundering through high-value item sales (FATF, Recommendation 24).
Incorrect
According to FATF guidelines and national AML/CFT regulations, dealers in high-value items must conduct customer due diligence (CDD) for cash transactions exceeding specified thresholds and file SARs for suspicious activities. This helps mitigate risks associated with money laundering through high-value item sales (FATF, Recommendation 24).
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Question 21 of 30
21. Question
Sunlight Travel Agency organizes luxury tours for high-net-worth clients. They receive a payment in cash for a high-value tour package from a client with no prior booking history. What steps should Sunlight Travel Agency take?
Correct
According to international AML/CFT standards and local regulations, travel agencies should conduct enhanced due diligence (EDD) on transactions involving high-value tour packages and clients without prior booking history. This helps mitigate risks associated with potential money laundering or terrorist financing activities (FATF, Recommendation 32).
Incorrect
According to international AML/CFT standards and local regulations, travel agencies should conduct enhanced due diligence (EDD) on transactions involving high-value tour packages and clients without prior booking history. This helps mitigate risks associated with potential money laundering or terrorist financing activities (FATF, Recommendation 32).
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Question 22 of 30
22. Question
Zenith Bet operates an online gambling platform. They notice that a new user has been making substantial deposits, gambling very little, and then withdrawing the funds shortly after. What steps should Zenith Bet take in response to this activity?
Correct
According to the FATF’s guidelines for the gambling sector, online gambling platforms should conduct enhanced due diligence (EDD) on users who display suspicious behavior, such as making large deposits with minimal gambling activity. This helps ensure compliance with AML regulations and mitigates risks of money laundering (FATF, Guidance for Casinos and Online Gambling Operators).
Incorrect
According to the FATF’s guidelines for the gambling sector, online gambling platforms should conduct enhanced due diligence (EDD) on users who display suspicious behavior, such as making large deposits with minimal gambling activity. This helps ensure compliance with AML regulations and mitigates risks of money laundering (FATF, Guidance for Casinos and Online Gambling Operators).
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Question 23 of 30
23. Question
Urban Realty is a real estate agency that has recently facilitated the sale of multiple high-value properties to a foreign investor. The payments were made through a complex network of offshore accounts. What should Urban Realty do to comply with AML regulations?
Correct
According to FATF recommendations and the USA PATRIOT Act, real estate agencies must conduct enhanced due diligence (EDD) on high-value transactions involving complex payment networks, especially when dealing with foreign investors. This ensures compliance with AML/CFT regulations and helps prevent money laundering through real estate (FATF, Recommendation 22).
Incorrect
According to FATF recommendations and the USA PATRIOT Act, real estate agencies must conduct enhanced due diligence (EDD) on high-value transactions involving complex payment networks, especially when dealing with foreign investors. This ensures compliance with AML/CFT regulations and helps prevent money laundering through real estate (FATF, Recommendation 22).
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Question 24 of 30
24. Question
Hope Foundation, a charitable organization, receives a large anonymous donation through a series of small transactions from various accounts. The donor’s identity remains unclear despite multiple attempts to obtain information. What should Hope Foundation do?
Correct
According to FATF and national AML regulations, charitable organizations must conduct enhanced due diligence (EDD) on large donations, especially those made through complex networks or anonymous sources. This helps prevent the misuse of charitable organizations for money laundering or terrorist financing (FATF, Recommendation 8).
Incorrect
According to FATF and national AML regulations, charitable organizations must conduct enhanced due diligence (EDD) on large donations, especially those made through complex networks or anonymous sources. This helps prevent the misuse of charitable organizations for money laundering or terrorist financing (FATF, Recommendation 8).
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Question 25 of 30
25. Question
Nova Crypto Exchange facilitates trading of various cryptocurrencies. A new user frequently deposits large amounts of cryptocurrency and quickly converts them to fiat currency, then withdraws the funds to different bank accounts. What action should Nova Crypto Exchange take?
Correct
According to FATF’s guidance on virtual assets, cryptocurrency exchanges must conduct enhanced due diligence (EDD) on transactions that involve large deposits and withdrawals, particularly when they are rapidly converted to fiat currency. This ensures compliance with AML/CFT regulations and mitigates risks associated with money laundering and terrorist financing (FATF, Virtual Assets Guidance).
Incorrect
According to FATF’s guidance on virtual assets, cryptocurrency exchanges must conduct enhanced due diligence (EDD) on transactions that involve large deposits and withdrawals, particularly when they are rapidly converted to fiat currency. This ensures compliance with AML/CFT regulations and mitigates risks associated with money laundering and terrorist financing (FATF, Virtual Assets Guidance).
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Question 26 of 30
26. Question
SafeCard Inc. issues prepaid cards and stored value products. They notice an unusual pattern where multiple prepaid cards are purchased using cash and then used to withdraw large amounts from ATMs in different locations. What steps should SafeCard Inc. take?
Correct
According to FinCEN’s guidance and AML regulations, issuers of prepaid cards and stored value products must conduct enhanced due diligence (EDD) on suspicious patterns of card usage, especially when large cash withdrawals are involved. This helps mitigate risks of money laundering and ensures compliance with AML/CFT requirements (FinCEN, Prepaid Access Rule).
Incorrect
According to FinCEN’s guidance and AML regulations, issuers of prepaid cards and stored value products must conduct enhanced due diligence (EDD) on suspicious patterns of card usage, especially when large cash withdrawals are involved. This helps mitigate risks of money laundering and ensures compliance with AML/CFT requirements (FinCEN, Prepaid Access Rule).
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Question 27 of 30
27. Question
Global Trade Ltd. is a trading company that imports and exports goods across several countries. They notice a significant increase in the volume and value of transactions with a new trading partner, but the goods involved are of low value. What should Global Trade Ltd. do in this situation?
Correct
According to FATF guidelines on trade-based money laundering (TBML), companies engaged in international trade must conduct enhanced due diligence (EDD) on transactions that exhibit red flags, such as significant discrepancies between the volume/value of goods and the actual trade activities. This helps prevent money laundering through trade (FATF, Best Practices Paper on Trade-Based Money Laundering).
Incorrect
According to FATF guidelines on trade-based money laundering (TBML), companies engaged in international trade must conduct enhanced due diligence (EDD) on transactions that exhibit red flags, such as significant discrepancies between the volume/value of goods and the actual trade activities. This helps prevent money laundering through trade (FATF, Best Practices Paper on Trade-Based Money Laundering).
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Question 28 of 30
28. Question
HighRoller Casino receives a series of large cash deposits from a new customer who engages in minimal gambling before requesting cash payouts. The customer’s behavior raises suspicions of potential money laundering. What should HighRoller Casino do?
Correct
According to FATF recommendations and local AML regulations, casinos and gaming establishments must conduct enhanced due diligence (EDD) on customers whose behavior raises suspicions of money laundering. This includes verifying the source of funds and the customer’s background to ensure compliance with AML requirements (FATF, Guidance for Casinos).
Incorrect
According to FATF recommendations and local AML regulations, casinos and gaming establishments must conduct enhanced due diligence (EDD) on customers whose behavior raises suspicions of money laundering. This includes verifying the source of funds and the customer’s background to ensure compliance with AML requirements (FATF, Guidance for Casinos).
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Question 29 of 30
29. Question
International Bank Ltd. establishes a new correspondent banking relationship with a foreign bank in a jurisdiction known for weak AML controls. They notice a high volume of wire transfers from the correspondent bank with minimal information on the beneficiaries. What steps should International Bank Ltd. take?
Correct
According to FATF recommendations and Basel Committee guidelines, banks must conduct enhanced due diligence (EDD) on correspondent banking relationships, especially with banks in jurisdictions known for weak AML controls. This includes monitoring transactions for suspicious activities and ensuring compliance with AML/CFT regulations (FATF, Recommendation 13).
Incorrect
According to FATF recommendations and Basel Committee guidelines, banks must conduct enhanced due diligence (EDD) on correspondent banking relationships, especially with banks in jurisdictions known for weak AML controls. This includes monitoring transactions for suspicious activities and ensuring compliance with AML/CFT regulations (FATF, Recommendation 13).
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Question 30 of 30
30. Question
Elite Art Gallery specializes in selling high-value art pieces to international buyers. They receive a request from a client to purchase an expensive painting with cryptocurrency. The client provides limited information about their identity and source of funds. What should Elite Art Gallery do?
Correct
According to FATF guidelines and AML/CFT regulations for high-value goods and art dealers, it is essential to conduct enhanced due diligence (EDD) on transactions involving significant amounts, especially when paid with cryptocurrency. This helps mitigate risks of money laundering and ensures compliance with AML requirements (FATF, Guidance for a Risk-Based Approach for Dealers in Precious Metals and Stones).
Incorrect
According to FATF guidelines and AML/CFT regulations for high-value goods and art dealers, it is essential to conduct enhanced due diligence (EDD) on transactions involving significant amounts, especially when paid with cryptocurrency. This helps mitigate risks of money laundering and ensures compliance with AML requirements (FATF, Guidance for a Risk-Based Approach for Dealers in Precious Metals and Stones).