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| Section | Weight | Objectives |
|---|---|---|
| Tools, Technologies and Investigations | 22% | - Technology and systems
|
| Building and Managing Anti-Financial Crime Compliance Programs | 28% | - Monitoring, reporting and record keeping
- Program framework and policies
- Customer due diligence and know-your-customer
|
| Understanding Risks and Methods of Financial Crime | 26% | - Money laundering stages and techniques
|
| Global Anti-Financial Crime Frameworks, Governance and Regulations | 24% | - Regional and national regulations
|
1. A bank is preparing for a regulatory exam after a previous regulatory exam identified weaknesses in the bank's AML program. Since the last exam, the bank has improved the written AML program, hired an experienced AML compliance officer, and has taken actions to demonstrate a strong culture of compliance. The bank is now focused on getting through their transaction monitoring case backlog and completing enhancements to its sanctions screening program.
Which of the following are correct? (Select Two.)
A) The bank may face the risk of regulatory orders to remediate its AML program despite addressing many of the previous concerns.
B) The regulatory agency may require the bank's board of directors to publicly share the actions taken to address the previous concerns in order to limit its reputational risk.
C) The bank is likely to face secondary sanctions from global financial institutions despite addressing many of the previous concerns.
D) The bank may face civil or criminal penalties if it is unable to demonstrate sustained improvement in addressing the previous concerns.
E) The bank is protected from reputational risk arising from any regulatory action because regulatory orders must remain confidential.
2. A compliance officer reviews an alert involving unusually high cryptocurrency transfers. What is the MOST important consideration?
A) Whether the customer prefers mobile applications
B) Whether the transfers occur during business hours
C) Whether blockchain technology eliminates AML risk
D) Whether customer activity aligns with expected profile and source of wealth
3. A compliance officer at a U.S. financial institution receives a grand jury subpoena requesting customer records related to an ongoing money laundering investigation involving a politically exposed person (PEP). What should the compliance officer do first?
A) File a Suspicious Activity Report (SAR) describing receipt of the subpoena
B) Notify the customer and seek consent
C) Immediately provide records to the grand jury
D) Consult with the institution's legal counsel to assess validity and determine the appropriate response
4. Which of the following are considered best practices for effective AML/CFT training programs?
(Select Three.)
A) Training should always be provided by an independent third party.
B) Training should cover practical examples, use case studies, and provide information on how to comply with policies.
C) Training should cover the consequences of not complying with policies and procedures.
D) Up-to-date records including logs of training and completion dates should be maintained.
E) Training should be broad, high level, and not role-specific in order to reach the largest audience.
5. Financial institutions (FIs) must use a risk-based approach in customer due diligence (CDD) measures for legal entity clients by:
A) Identifying a customer's identity using data and information from the internet and social media
B) Conducting ongoing analysis of the business relationship's profitability
C) Understanding and obtaining information about the competition the business relationship could face
D) Taking reasonable measures to verify the identity of the beneficial owner
Solutions:
| Question # 1 Answer: A,D | Question # 2 Answer: D | Question # 3 Answer: D | Question # 4 Answer: B,C,D | Question # 5 Answer: D |
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