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ACAMS Post Assessment Exam
What actions should MSBs take to prevent BSA violations? Develop and maintain an AML program commensurate with the risks posed by the MSB's location, size, nature, and volume of transactions Ensure customers can control what information they will provide to the MSB and how long the information will be maintained by the MSB Ensure the BSA/AML department reports directly to the owners and develop policies that promote profitability and customer anonymity Develop and maintain an AML program based on the size of the AML staff, financial resources available, and the MSBs overall risk profile - Correct Answer ✔️ ✔️ Develop and maintain an AML program commensurate with the risks posed by the MSB's location, size, nature, and volume of transactions Suzy, the AML compliance officer for a large financial organization, is asked by her board of directors to review how best to protect the confidentiality of STRs submitted by the organization and the confidential information contained therein. What are three things she should consider?
Ensure training of employees so that they do not inadvertently inform, or tip off, the targeted customer of the filing. Ensure that employees know how to retrieve STRs by the name of the customer quickly and efficiently. Ensure that procedures are in place to promptly and appropriately respond to requests for copies of filed STRs. Ensure strong record-keeping procedures to segregate information pertaining to STRs and to maintain their confidentiality. - Correct Answer ✔️ ✔️ Ensure training of employees so that they do not inadvertently inform, or tip off, the targeted customer of the filing. Ensure that procedures are in place to promptly and appropriately respond to requests for copies of filed STRs. Ensure strong record-keeping procedures to segregate information pertaining to STRs and to maintain their confidentiality. Why are designated officers responsible for reporting suspicious activity (SARs and STRs) to their FIU? The Wolfsberg Group guidelines suggest that they should be responsible
What should an organization do when they are served with a subpoena? Send the subpoena to all department heads for review and comment on the nature of the subpoena. Review the merits of the subpoena and prepare a legal challenge before producing any records. Send legal hold notices to the applicable parties and segregate and preserve the responsive records. Contact the sending party to determine the nature of the investigation and the reason for the requested records. - Correct Answer ✔️ ✔️ Send legal hold notices to the applicable parties and segregate and preserve the responsive records. When would a financial institution typically file a SAR? Whenever it is preparing to close an account Whenever it detects unusual or suspicious transactions Only when it is able to establish the existence of a criminal violation
Only when the board of directors approves the filing of the SAR - Correct Answer ✔️ ✔️ Whenever it detects unusual or suspicious transactions
Which of the following is part of open-source intelligence (OSINT)? Online search engine searches KYC file review Use of a vendor's proprietary database Review of a customer's transactions - Correct Answer ✔️ ✔️ Online search engine searches What legislation requires participants in the EU member state art markets to register with regulatory supervisors and undertake a risk-based approach to money laundering and terrorist financing threats? The Anti-Money Laundering Act of 2020 The EU 5th Money Laundering Directive The FATF 40 Recommendations The Responsible Art Market 2019 Guidelines - Correct Answer ✔️ ✔️ The EU 5th Money Laundering Directive
To what group of typologies does the black-market peso exchange (BMPE) scheme belong? Trade-based money laundering Sanctions evasion Bulk cash smuggling Structuring - Correct Answer ✔️ ✔ ️ Trade-based money laundering
Which element is often present in criminal activities involving cryptocurrencies? Cryptographically secured transactions, identifiable through a user's exchange account, cryptocurrency wallet address, and the central bank authority Use of cryptocurrency exchange services to hide transaction amounts and balances Discussions regarding criminality between the financial organization and cryptocurrency exchange Transactions take place in a matter of seconds, across exchanges and jurisdictions, often from cryptocurrency to fiat currency - Correct Answer ✔️
✔️ Transactions take place in a matter of seconds, across exchanges and jurisdictions, often from cryptocurrency to fiat currency Which of the following is a useful tool for detecting and assessing cross-border terrorist financing risks? Assessing the systemic vulnerabilities of other jurisdictions Avoiding the terrorism threat environment Engaging with foreign counterparts to detect and assess the risks Validating the existence of terrorist funding - Correct Answer ✔️ ✔ ️ Engaging with Foreign Counterparts to detect and assess the risks
Which of the following is true about terrorist financing? Communication regarding funding is solely via encrypted networks Virtual currency anonymity makes it nearly impossible for law enforcement to counter it Funding is exclusively via virtual currencies Criminals often disguise it as humanitarian activity - Correct Answer ✔️ ✔ ️ Criminals often disguise it as humanitarian activity
Answer ✔️ ✔️ Unlawful activity whose proceeds, if involved in the transaction, can give rise to prosecution for the crime of money laundering According to the FATF 40 Recommendations, designated nonfinancial businesses and professions include casinos, real estate agents and dealers in precious stones. money service businesses, gatekeepers and issuers of electronic money. dealers in precious metals, lawyers and commodity futures traders. life insurance companies, real estate agents and notaries. - Correct Answer ✔ ️ ✔️ casinos, real estate agents and dealers in precious stones.
What is nesting? When a respondent bank is providing upstream correspondent services to other financial institutions When a respondent bank is providing downstream correspondent services to other financial institutions When a bank has many common customers with other local banks
When customers have accounts with many local banks - Correct Answer ✔️ ✔️ When a respondent bank is providing downstream correspondent services to other financial institutions Organizations are fined by regulators only when a financial crime has occurred. True False - Correct Answer ✔️ ✔️ False
Which method of payment is preferred by criminals operating on the darknet? Bitcoin Euro US dollar Payment-in-kind - Correct Answer ✔️ ✔️ Bitcoin
When can the US government file a civil forfeiture complaint? A defendant has plead guilty and admitted to laundering funds from a specified unlawful activity
E-cash is not attractive to the money launderer because it cannot be completely anonymous and does not allow for large amounts to be transported quickly and easily. - Correct Answer ✔️ ✔ ️ Systemic weaknesses in free trade zones include inadequate AML/CFT safeguards, minimal oversight by local authorities and weak procedures to inspect goods. What is the right of reciprocity in the field of international cooperation against money laundering? The legal principle that financial institutions that have referred customers to other financial institutions can share information about these customers with the other institutions A rule of the Basel Committee allowing properly regulated financial institutes of another member state of the Basel Committee to do business without additional supervision to the degree that the other state grants the same right The right of each FATF member country to delegate prosecution of a case of money laundering to another member that is already investigating the same case
A rule in the law of a country allowing its authorities to cooperate with authorities of other countries to the degree that their law allows them to do the same - Correct Answer ✔ ️ ✔️ A rule in the law of a country allowing its authorities to cooperate with authorities of other countries to the degree that their law allows them to do the same Which three statements are true about the Fourth EU Directive on Money Laundering? It updates European Community legislation to be further in line with the Financial Action Task Force (FATF) 40 Recommendations. It repeats the definition of a politically exposed person in previous directives. It repeats the customer due diligence requirements of the previous directives but adds more detail to the requirements by, for example, including a specific requirement to identify the beneficial owner and includes ongoing monitoring requirements. It includes new definitions for correspondent relationships and senior management. - Correct Answer ✔ ️ ✔️ It updates European Community
not approve the establishment or accept the continued operation of shell banks.
- Correct Answer ✔️ ✔ ️ not approve the establishment or accept the continued operation of shell banks. Which of the following best describes the alternative remittance system? The transfer of value between countries, outside of the legitimate banking system A nonelectronic data remittance system used in several foreign countries to report suspicious activities Old-fashioned reporting requirements commonly used in non-cooperative countries and territories The transfer of funds between two or more financial institutions using concentration accounts - Correct Answer ✔️ ✔️ The transfer of value between countries, outside of the legitimate banking system n the 4th EU directive, to what level has the threshold decreased for inclusion of natural or legal persons trading in goods and making/receiving cash payments? $5,000 euros.
$10,000 euros. $15,000 euros. $20,000 euros. - Correct Answer ✔️ ✔ ️ $10,000 euros.
After receiving a SAR regarding a customer account, the relevant law enforcement agency requests permission to interview the bank personnel who are familiar with the underlying transaction. What action should the compliance officer take? The officer, in consultation with bank counsel, should cooperate, to the extent possible, and give permission for the relevant interviews to take place. The officer should deny permission for any such interviews without the creation of a grand jury or a formal court-ordered investigation. The officer should only allow those employees who are comfortable to be interviewed by law enforcement. The officer should allow the employees to be interviewed only if they are given immunity by law enforcement. - Correct Answer ✔️ ✔ ️ The officer, in consultation with bank counsel, should cooperate, to the extent possible, and give permission for the relevant interviews to take place.
A quantitative approach will generate better results than a qualitative approach. It allows the institution to focus on selling products that have a better return on investment. - Correct Answer ✔️ ✔️ Institutions can best use their limited resources to focus on matters where the money laundering risks are highest. Which of the following statements is true? Correspondent banking is most vulnerable to money laundering when the correspondent account is maintained for foreign financial institutions that are banks. not used to provide services directly to third parties. maintained for a foreign bank that does not have a physical presence in any country. maintained for a foreign private bank that is publicly traded and is a qualified intermediary. - Correct Answer ✔️ ✔️ maintained for a foreign bank that does not have a physical presence in any country. Which is an economic impact of money laundering on countries? Draws attention away from fraud and corruption crimes
Allows the private sector to grow without regulations Provides opportunities for economic growth Undermines the legitimate financial system and markets - Correct Answer ✔ ️ ✔️ Undermines the legitimate financial system and markets Which of the following is a necessary policy for correspondent banking to ensure a robust AML/CFT framework? Empower respondent banks to terminate relationships with high-risk correspondent customers. Adequately monitor respondent banks and their AML/CFT framework. Provide practical guidance to staff on how to verify the correspondent's ultimate beneficial owners. Instruct respondents to escalate red flags to the correspondent's compliance officer before taking action. - Correct Answer ✔️ ✔️ Adequately monitor respondent banks and their AML/CFT framework. How do PTAs expose correspondent banks to money laundering risk?
