AML - 3

The branch manager notices that a number of customers come in weekly and always use the same teller to process their deposits. The manager notices that the customers and the teller, who are from the same ethnic group, are speaking in a foreign language and every once in a while the customers from local ethnic restaurants will bring the teller lunch. The commercial customers that visit the teller generally deposit the same amount of cash each time they come in.
How should the branch manager respond to this activity?

• Transfer the teller to another branch

• Conduct further investigation before taking any other action

• Encourage the teller to bring in more business from the ethnic community

• • Suggest to the teller to send the customers to other tellers to avoid the opportunity for collusion

A law enforcement official calls a bank inquiring about a customer who is currently under investigation. The law enforcement official requests information about the customer.
How should the bank respond?

• Confirm the customer is either a current or former customer

• Inform the board of directors before responding to the request

• Provide the requested information to help aid in the investigation

• • Request a formal letter be submitted to verify the validity of the request

A bank compliance officer has implemented enhanced monitoring rules that have identified some unusual activity that may be indicative of human trafficking.
Which red flag should prompt additional transactional review?

• Wire transfer activity from countries with significant migrant populations

• Cash deposits that occur in cities where the customer resides and conducts business

• Cash deposits that occur in cities where the customer does not reside or conduct business

• • Cash deposits that occur in cities where the customer does not reside or conduct business followed by same-day withdrawals

A non-U.S. bank wants to open an account at Bank A, which is a U.S.-based bank.
Which information must Bank A obtain under the USA PATRIOT Act?

• A complete client list from the non-U.S. bank

• The identity of owners and percentage of ownership of the non-U.S. bank

• The structure and identity of the management team at the non-U.S. bank

• The details of the non-U.S. bank's anti-money laundering compliance training program

What is an essential element of Know Your Customer (KYC) standards according to the Basel Committee's Customer Due Diligence for Banks paper?

• Annual staff training

• A customer acceptance policy

• The same KYC requirements must be applied in all cases

• All completed KYC documents must be reviewed by a senior manager not involved in the account opening process

An institution has made the decision to exit a client relationship due to anti-money laundering concerns. Prior to starting the close out process, the institution receives a written request from a law enforcement agency to keep the account open. The client is the subject of an ongoing investigation and law enforcement wants the institution to continue to monitor the account and report any suspicious activity.
What is a primary consideration the institution should keep in mind when deciding whether to agree to this request?

• The anticipated cost of complying with the law enforcement request

• The number of suspicious transaction reports previously filed on the client

• The fact that the institution has a solid record in complying with law enforcement requests

• • Whether the institution can continue to meet its regulatory obligations with the accounts open

An immigrant residing in the United States opens a bank account that includes a debit card. Several months later, the transactional monitoring system identifies small deposits into the account followed by corresponding ATM withdrawals from a country bordering a conflict zone.
How should the bank respond?

• Block any further activity

• File a suspicious transaction report

• Initiate an investigation into the activity

• Contact the customer if the transaction activity continues

Which method do terrorist financiers use to move funds without leaving an audit trail?

• Extortion

• Cash couriers

• Casa de cambio

• Virtual currency

Why do governments and multi-national bodies impose economic sanctions?

• To impede kleptocracy

• To enforce foreign policy objectives

• To combat an imminent terrorist threat

• To prevent fraudulent international trade transactions

A bank has maintained an account for a European charity for several years. The charity provides clothing to persons in need in various countries with active terrorists' cells.
Which action by the charity indicates possible terrorist financing?

• The charity frequently withdraws cash from the bank

• The charity has branch locations located in various countries

• The charity receives cash donations primarily from European countries

• The charity maintains a bank account for non-business-related expenses