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| Section | Weight | Objectives |
|---|---|---|
| Tools, Technologies and Investigations | 22% | - Remediation and response
|
| Building and Managing Anti-Financial Crime Compliance Programs | 28% | - Customer due diligence and know-your-customer
- Audit, testing and continuous improvement |
| Understanding Risks and Methods of Financial Crime | 26% | - Financial crime risks and consequences
|
| Global Anti-Financial Crime Frameworks, Governance and Regulations | 24% | - International standards and bodies
|
1. An organization is developing a comprehensive anti-money laundering (AML) framework. Which of the following statements best describes the relationship between AML policies and procedures?
A) Policies are detailed instructions for specific processes. Procedures are an overarching framework. Neither policies nor procedures are mandatory for knowledge and adherence.
B) Policies define the principles of an organization and influence the drafting of procedures.
Procedures are detailed instructions for specific processes.
C) Policies are detailed instructions for specific processes. Procedures are an overarching framework. Both policies and procedures are mandatory for knowledge and adherence.
D) Policies are broad guidelines. Procedures are detailed instructions for specific processes. Only procedures are mandatory for knowledge and adherence.
2. 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 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.
B) The bank may face the risk of regulatory orders to remediate its AML program despite addressing many of the previous concerns.
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.
3. A financial institution is designing an enterprise-wide risk assessment (EWRA). According to the guidance issued by the Wolfsberg Group regarding a risk-based approach to identifying and managing money laundering risks, an effective approach should:
A) Include appropriate measures and controls to mitigate money laundering risks stemming from higher-risk customers, products, and geographies.
B) Use a framework provided by a third-party vendor and used by other FIs in the jurisdiction.
C) Focus on the inherent risk in the FI's product and service offerings and the controls to mitigate potential money laundering risks.
D) Focus on understanding the risks presented by new clients within the assessment period, and the controls to mitigate associated money laundering risks.
4. Red flags for potential money laundering in real estate include completing luxury real estate purchases. (Select Two.)
A) using the proceeds from selling a prior property or liquidating investments to make an all-cash purchase
B) using shell companies or trusts for privacy, lax planning, or asset protection.
C) using legal entities and intermediaries to protect the privacy of the purchasers.
D) using loans backed by cash or certificates of deposit.
E) in the names of unrelated thud patties.
5. A wealthy individual is using a complex corporate structure to facilitate illegal logging and then illegal mining of the resulting resources from that land. Which category of predicate crime is taking place?
A) Trade-based money laundering
B) Environmental crime
C) Corruption
D) Illicit resource trade
Solutions:
| Question # 1 Answer: B | Question # 2 Answer: B,D | Question # 3 Answer: A | Question # 4 Answer: C,E | Question # 5 Answer: B |
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