At a minimum, who should receive role-specific AML training? (Select Three.)
Answer : B, C, F
1. Information Technology Staff: These employees handle systems, databases, and software used for transaction monitoring, customer due diligence (CDD), and other AML processes. They need to understand how to configure and maintain AML systems, recognize suspicious patterns, and ensure data security.
2. Customer Facing Staff: Frontline employees, such as tellers, relationship managers, and customer service representatives, interact directly with customers. They play a crucial role in identifying red flags, conducting enhanced due diligence (EDD), and reporting suspicious activities. Training helps them recognize unusual behavior and follow proper procedures.
3. AML/Compliance Staff: These professionals are directly responsible for AML program management, policy development, and regulatory compliance. They need in-depth knowledge of AML laws, regulations, and best practices. Training ensures they stay updated and can effectively implement AML controls.
1. Financial Crime Academy: Ensuring Compliance - Building an Effective AML Training Program
2. ACAMS: AML Training - Preparing Auditors to Adequately Assess AML Programs
3. Financial Crime Academy: AML Training for High-Level Executives
4. Financial Crime Academy: Senior Management AML Training Workshops
Which scenario best justifies why a customer's account might be closed by a financial institution?
Answer : A
Financial institutions closely monitor customer accounts for suspicious activity related to money laundering, terrorist financing, or other illicit activities. If an account consistently triggers multiple suspicious activity reports (SARs), it raises red flags. These reports indicate unusual or potentially illegal transactions, such as large cash deposits, frequent transfers to high-risk jurisdictions, or patterns inconsistent with the customer's profile. To mitigate risk and comply with anti-money laundering (AML) regulations, the financial institution may decide to close the account. Regular SAR filings are essential for maintaining the integrity of the financial system and preventing illicit financial flows12.
1. ACAMS: Suspicious Activity Reports (SARs)
2. MoneyLaundering.com: Suspicious Activity Reports
Which is a purpose of imposing sanctions?
Answer : A, C
Economic sanctions are measures imposed by countries or international bodies to exert pressure on individuals, entities, or nations that engage in undesirable behavior or actions. Sanctions aim to restrict or prohibit certain economic activities with the targeted parties, such as trade, investments, or financial transactions. They serve various purposes, including achieving foreign policy and national security objectives and deterring undesired actions by countries or entities. Sanctions can be comprehensive (affecting an entire country) or targeted (specific businesses, groups, or individuals), with a recent trend toward minimizing harm to innocent civilians12.
1. Council on Foreign Relations: What Are Economic Sanctions?
2. [Tookitaki: A Complete Guide to Sanctions](https://www.tookitaki.com/compliance-hub/what
A high-profile, successful entrepreneur has been a client of a Swiss private bank for more than a decade. Recently, the entrepreneur launched a political career, with rather extremist
political views. On which grounds can the bank terminate the client's bank relationship? (Select Two.)
Answer : A, E
1. Tax Compliance: Banks have a responsibility to ensure that their clients comply with tax regulations. If a client fails to provide evidence of tax compliance or is unwilling to do so, the bank may terminate the relationship to avoid legal and regulatory risks.
2. Reputational Risk: High-profile clients with extremist political views can create reputational risks for the bank. If the client's political activities or views could harm the bank's reputation, the bank may choose to terminate the relationship.
1. ACAMS Certification Package, 6th Edition.
2. The right to terminate a banking relationship unilaterally.
3. A bank's right to terminate its relationship.
Which economic and social factors could create a dependency on illicit activities and money laundering? (Select Two.)
Answer : A, E
Wider exposure to organized crime and corruption: When individuals or communities are exposed to organized crime networks or corrupt practices, they may become more susceptible to engaging in illicit activities. Organized crime groups often exploit vulnerabilities, leading to money laundering.
Weaker development of economy and job opportunities: In regions with limited economic growth and scarce job prospects, individuals may turn to illicit activities as a means of survival. Poverty and lack of legitimate income sources can drive people toward money laundering.
1. World Bank Document: ''Illicit Activity and Money Laundering from an Economic Growth Perspective'' 1.
2. The Social Impact Of Money Laundering 2.
3. Money Laundering: History, Regulations, and Techniques 3.
4. The IMF and the Fight Against Illicit Financial Flows 4.
5. SSRN Paper: ''Illicit Activity and Money Laundering from an Economic Growth'' 5.
A customer puts high-denomination cash notes into a poker machine at a casino. Without placing any bets, the customer collected winnings in the form of a check from the casino.
Which money laundering threats could result from the customer's activities?
Answer : B
1. A. Micro-structuring cash:
The customer's behavior of putting high-denomination cash notes into a poker machine without placing bets and then collecting winnings in the form of a check resembles ''structuring'' or ''smurfing.'' Structuring involves breaking down large sums of money into smaller transactions to avoid detection. In this case, the customer may be attempting to legitimize illicit funds by converting them into casino winnings1.
2. B. Legitimizing illicit funds:
By using the poker machine to convert cash into a check, the customer is potentially legitimizing illicit funds. The casino winnings obtained through this process may appear legitimate, even though the initial source of the cash remains suspicious1.
A . Micro-structuring cash:
The customer's actions of repeatedly inserting high-denomination cash notes into the poker machine without placing bets and then collecting winnings in the form of a check resemble structuring. Structuring involves deliberately breaking down large amounts of cash into smaller transactions to avoid detection. Money launderers engage in structuring to obscure the origin of funds and make them appear legitimate. In this case, the customer's behavior raises red flags and warrants further investigation.
B . Legitimizing Illicit Funds:
By converting cash into casino winnings (in the form of a check), the customer may be attempting to legitimize illicit funds. The casino winnings obtained through this process could be used to create a veneer of legitimacy, even though the initial source of the cash remains suspicious. Casinos are attractive for money launderers due to the anonymity and fluidity of transactions, making it challenging to trace the origin of funds1.
The AML investigator is reviewing the transaction monitoring alerts and the customer's historical profile for the past two years. A review of the negative news search from a blog indicates
that the customer was previously part of a terrorist group. Which activities warrant further escalation? (Select Two.)
Answer : D, E
1. D. The account received a large cash deposit followed by systematic automated teller machine (ATM) withdrawals until the balance was nominal.
This pattern of behavior, known as ''structuring'' or ''smurfing,'' is often associated with money laundering. The large cash deposit followed by smaller withdrawals in a systematic manner raises red flags and requires further investigation.
2. E. The customer conducts multiple cash transactions on a regular basis which do not match the customer's occupation.
Conducting frequent cash transactions that do not align with the customer's stated occupation or income source is suspicious. It suggests potential attempts to hide the true origin of funds or evade reporting requirements1.
D . Large Cash Deposit Followed by ATM Withdrawals:
The large cash deposit followed by systematic ATM withdrawals is indicative of structuring, a common money laundering technique. Structuring involves breaking down large sums of money into smaller transactions to avoid detection. In this case, the customer's behavior warrants further scrutiny to determine the purpose behind these transactions.
E . Inconsistent Cash Transactions:
When a customer conducts multiple cash transactions that do not align with their stated occupation or income source, it raises suspicions. Such behavior may indicate an attempt to obscure the true origin of funds or evade reporting requirements. Investigating the reasons behind these inconsistent cash transactions is essential to assess potential money laundering risks1.