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| Section | Weight | Objectives |
|---|---|---|
| Money Laundering and Terrorist Financing Concepts | 30% | - Definitions and stages of money laundering
|
| Detecting and Preventing Financial Crime | 20% | - Investigations and enforcement
|
| AML Compliance Framework | 25% | - Compliance program components
|
| Risk Management and Due Diligence | 25% | - Customer Due Diligence (CDD/KYC)
|
1. The chief compliance officer at a global bank that operates in the US, EU, and other countries is responsible for navigating the US and EU regulations related to anti-money laundering (AML) and sanctions as well as any local regulations in the countries where it operates. What should be the primary compliance concern of the bank?
A) US and EU regulations require the bank to build separate compliance teams, making it necessary to establish completely separate systems for US and EU operations
B) The EU's sanctions regime is stricter than that of the US Office of Foreign Assets Control (OFAC), so the bank must prioritize compliance with EU regulations over US laws and train the staff in Europe accordingly
C) Balancing compliance with the US BSA and OFAC sanctions while ensuring adherence to EU AML directives and the GDPR, which complicates cross-border data sharing
D) US anti-money laundering regulations are stricter than the EU AML Directives, making it easier for the global bank to be compliant in the EU
2. A trade finance customer repeatedly imports goods at prices significantly above market value.
Which typology may this indicate?
A) Mortgage fraud
B) Trade-based money laundering
C) Smurfing
D) Cyber extortion
3. The United Nations Security Council's sanctions are intended to be:
A) Designed to maintain and restore international peace and security
B) Encompassing and broad, including the use of force if necessary
C) Indefinite to produce economic benefit for a group of states
D) Punitive to influence foreign governments to change their behavior
4. A financial institution's (FI's) policy is to apply enhanced due diligence (EDD) for every new client to ensure the effectiveness of the program. How should a consultant advise the FI's management team?
A) Suggest the FI needs to implement a risk-based approach for EDD.
B) Suggest the management team ask the regulator for advice on EDD measures.
C) Suggest EDD for 50% of the clients is appropriate.
D) Suggest the management team select the clients that are chosen for EDD.
5. Upon learning of a potential weakness through an organization's enterprise-wide sanctions risk assessment relating to a low number of sanctions screening alerts generated compared to the business size and operations identified, which action would best ensure the risk area is properly managed and remediated to the best possible extent?
A) Reviewing the fuzzy logic currently adopted in the screening system
B) Revisiting the post-transaction monitoring system parameters and thresholds
C) Reviewing the enterprise-wide risk assessment methodology
D) Enhancing staff training on the documentation of justification on closed alerts
Solutions:
| Question # 1 Answer: C | Question # 2 Answer: B | Question # 3 Answer: A | Question # 4 Answer: A | Question # 5 Answer: B |
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