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1. Which activities would be considered money laundering red flags when reviewing the business operations of a money services business (MSB)? (Select Two.)
A) A customer completing frequent small-dollar international money transfers to their native country
B) A customer exchanging foreign currency from a higher-risk jurisdiction for domestic currency under the reporting threshold
C) Cash-intensive businesses, such as convenience stores or restaurants, making large cash deposits
D) A customer using multiple accounts under different names to conduct transactions
E) A customer being hesitant to provide beneficiary name or address information when sending international wire transfers
2. How should national and sectoral risk assessments influence an organization's risk-based approach and internal risk assessment?
A) They should only be referenced for high-risk clients as they are designed for worst-case scenarios
B) They should be referenced and integrated appropriately into an organization's risk assessment to tailor enhanced due diligence (EDD) procedures and allocate resources effectively
C) They are primarily intended for regulators and should not influence organizational risk assessments
D) They provide general guidance but do not need to be directly considered because internal risk factors are more important
3. Which techniques would be most efficient for a complex investigation of unusual patterns of activity involving multiple businesses, triggered by an automated monitoring system alert? (Select Two.)
A) Contact the account manager and ask for the reasons behind the patterns of activity highlighted in the AML alerts
B) Perform a control and ownership assessment of the businesses involved, using the information available in the client files
C) Review the information presented in the automated monitoring system's alert description and decline any future transactions
D) Contact local law enforcement and request that they assist in the analysis and investigation
E) Use social media platforms to connect with the businesses and request details about the account activity
4. An institution outsources part of its AML monitoring process to a third-party vendor. Who remains ultimately responsible for AML compliance?
A) The third-party vendor exclusively
B) The customer relationship manager alone
C) The financial institution's management
D) The regulator only
5. A financial institution is conducting an enterprise-wide risk assessment (EWRA) and has identified a high inherent risk of money laundering associated with its private banking division due to the clientele's high net worth and complex financial structures. However, the institution has implemented robust customer due diligence (CDD) and enhanced due diligence (EDD) procedures, along with sophisticated transaction monitoring systems. How would these controls impact the assessment of residual risk?
A) The residual risk would be eliminated entirely because the controls are sufficient to mitigate all potential risks
B) The residual risk would be significantly reduced due to the effectiveness of the controls in place
C) The residual risk would be moderately reduced, but further controls may be necessary to achieve an acceptable level
D) The residual risk would remain high due to the inherent nature of the private banking business
Solutions:
| Question # 1 Answer: D,E | Question # 2 Answer: B | Question # 3 Answer: A,B | Question # 4 Answer: C | Question # 5 Answer: B |
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