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| Section | Weight | Objectives |
|---|---|---|
| Topic 1: Tools, Technologies and Investigations | 22% | - Remediation and response
|
| Topic 2: Building and Managing Anti-Financial Crime Compliance Programs | 28% | - Customer due diligence and know-your-customer
- Monitoring, reporting and record keeping
- Program framework and policies
|
| Topic 3: Understanding Risks and Methods of Financial Crime | 26% | - Sanctions regimes and compliance risks
|
| Topic 4: Global Anti-Financial Crime Frameworks, Governance and Regulations | 24% | - Governance, accountability and ethics
|
Question 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 broad guidelines. Procedures are detailed Instructions for specific processes. Only procedures are mandatory for knowledge and adherence.
B. Policies are detailed instructions for specific processes Procedures are an overarching framework Both policies and procedures are mandatory for knowledge and adherence.
C. Policies are detailed instructions for specific processes. Procedures are an overarching framework. Neither policies nor procedures are mandatory for knowledge and adherence
D. Policies define the principles of an organization and influence the drafting of procedures.Procedures are detailed instructions for specific processes.
Question 2
According to the Financial Action Task Force (FATF) methodology, which situations would require a financial institution (FI) to consider filing a suspicious activity report?
A. A FI is unable to verify the relevant customer due diligence documents.
B. A beneficiary of a transaction is a politically exposed person.
C. A transaction involves funds exchanged from crypto to fiat currencies.
D. A FI identifies the payer is a dealer in precious metals or stones.
Question 3
A large international financial institution (FI) operates in both the United States and the European Union. A cross-border transaction involving a high-net-worth client with dual U.S. and French citizenship raises concerns due to a third-party intermediary in a high-risk jurisdiction.
Given that the transaction falls under the U.S. Bank Secrecy Act (BSA) and OFAC requirements, as well as the EU's 6th Anti-Money Laundering Directive (6AMLD) and European Banking Authority (EBA) regulations, what is the best approach for the compliance team to ensure compliance?
A. Implement a dual-compliance approach satisfying both U.S. and EU AFC regulations
B. Follow U.S. regulations only, as the transaction originates in the United States
C. Follow EU regulations only, as the beneficiary is based in France
D. Defer to the most stringent regulatory regime to streamline compliance
Question 4
A company is rapidly expanding into several international markets, including jurisdictions considered high risk in terms of regulatory oversight. The board has requested the Money Laundering Reporting Officer (MLRO) to review and adjust the company's anti-financial crime (AFC) compliance framework to align with the evolving regulatory landscape and expansion strategy. During this process, the MLRO identifies vulnerabilities, particularly in markets with AML deficiencies, and updates the framework to mitigate these risks. Which element of the AFC compliance program does this process describe?
A. Training and awareness
B. Transaction monitoring
C. Risk assessment
D. Governance arrangements
Question 5
An institution is looking to alter an existing threshold-based monitoring scenario because it is generating too many alerts that do not yield suspicious activity reports. Documentation submitted to the relevant committee for supporting this proposal should include details on: (Choose three.)
A. how many resources are spent on the less productive lower threshold and the associated costs.
B. approval by money-laundering reporting officer for the proposal.
C. historical analysis proving that the current scenario generates a disproportionate number of false positives.
D. minutes of meeting held with the regulator where agreement was obtained that the higher threshold was justified.
E. evidence that the increased residual risk arising from the change is within the bank's risk appetite.
F. the number of cases that will not be filed and the resources that can be freed up for other tasks.
Solutions:
| Question 1 Answer: D | Question 2 Answer: A | Question 3 Answer: A | Question 4 Answer: C | Question 5 Answer: A,C,E |
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