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Chapter 4 Practice Question

The document contains questions related to anti-money laundering compliance, internal investigations, and interactions with law enforcement. Some key topics covered include when a financial institution should conduct an internal investigation, how to respond to requests from law enforcement, factors to consider in deciding whether to file a suspicious activity report, and best practices for cooperating with criminal investigations.

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0% found this document useful (0 votes)
2K views39 pages

Chapter 4 Practice Question

The document contains questions related to anti-money laundering compliance, internal investigations, and interactions with law enforcement. Some key topics covered include when a financial institution should conduct an internal investigation, how to respond to requests from law enforcement, factors to consider in deciding whether to file a suspicious activity report, and best practices for cooperating with criminal investigations.

Uploaded by

shahadat22
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as XLSX, PDF, TXT or read online on Scribd
  • Introduction to Internal Investigations
  • Transaction Monitoring Systems
  • Role of Compliance Officers
  • Responding to Law Enforcement Requests
  • Filing STRs and Legal Counsel
  • International Cooperation in AML
  • Information Sharing Protocols
  • Assessment: Compliance Scenarios
  • Answer Key

Question# Question

Which of the following alert is initiated an Investigation


proactively?

What are three developments that should cause a financial


institution to conduct an internalinvestigation?

When should a compliance officer recommend that a financial


institution conduct an internal investigation? Choose three out
of five.

Mr. Mehedi Hasan, an investigative officer of a Large


commercial bank. for identify the suspicious activities properly
in his bank, when should Mr. M Hasan conduct an internal
investigation. (choose three).

Mr. Mehedi Hasan, an investigative officer of a Large


commercial bank. for identify the suspicious activities properly
in his bank, when should Mr. M Hasan conduct an internal
investigation. (choose three).
What is the main objective of a Transaction Monitoring System.

When requested by law enforcement via legal process to


provide records or documentation,whatshould
theofficersoffinancial institutiondo?

A financial institution's monitoring system triggers an alert and


an internal investigation has confirmed the activity as
suspicious. Which of the following should an anti-money
laundering specialist do before submitting the suspicious
transaction report?

When a bank receives a subpoena for information about a


specific account, what two steps should the compliance officer
take?
Alaw enforcement representative calls up the compliance officer
and urgently requests information pertaining to a particular
account in connection with an on-going terrorist financing
investigation. Whatshould thecomplianceofficer do?

The compliance officer of a financial institution has just


received an extensive law enforcement subpoena focusing on
the potential inadequacy of the institution’s AML
[Link] thecompliance officer should do?

After reporting suspicious activity to the appropriate authorities


and they request additional follow up on the reports, which of
the following actions should an AML compliance officerdo?

Law enforcement submitted a request to a bank for information


regarding one of its customers. How should the bank respond
according to Financial Action Task Force Guidance?

Identify three methods that law enforcement may use to request


information from a financial institution during the course of a
criminal investigation.
When a financial institution is served with a search warrant by a
law enforcement agency, whatarethreethingsthattheemployees
oftheinstitutionshould do?

The compliance officer reads about a large potential fraud case


in the morning newspaper. When the officer gets to the bank,
the officer uncovers the fact that the potential fraud case
involves an important customer of the bank. After doing an
internal investigation, the officer determines that there is no
suspicious activity in the customer’s accounts. What should the
officer do next?

Mr. Arafat Khan is working at transaction Monitoring unit of


Compliance Division of a financial Institution. As a part of
regular review, the officer is conducting a review of the
automated transaction monitoring system. As a part of the
review, the officer considers the tuning practice which help to
setup parameter and threshold in the automated transaction
monitoring system of the financial institution. Which the three
issues should beconsidered inthetuningpractice?

An organization's automated surveillance system identifies large


fluctuations in customer activity. As a result of an audit, the
compliance officer is informed that the system is not generating
alerts when activity is consistently abnormal over a long period
of time. Currently the organization is evaluating new alert
scenarios in anattempttoaddress this problem. Which
typeofscenario is helpful in mitigatingthis weakness?
Mr. Arafat Khan is working at the transaction Monitoring unit
of the Compliance Division of a financial institution. M khan
received a claim from the investigation unit that a huge number
of alerts are generated from the transaction monitoring systems.
The investigation unit has not enough personnel to evaluate
such alerts. M. Khan is instructed by CAMLCO to set up a new
threshold considering the above situation. Which
ofthefollowingissue should consider intuning practice?

How should a financial institution respond to a verbal request


from a law enforcement agency to keep an account open to
assistin an investigation?

A customer has held an account at a local credit institution for


10 years. The account has received deposits twice weekly for
the same amount and has never shown signs of suspect
behavior. Monitoring software indicated that in the past few
months the account has received several large deposits that were
not in line with the account history. When asked, the customer
states she recently sold a piece of property, which is supported
withaproofofsale. Whatshould thecompliance officer do next?

A law enforcement agency is reviewing a suspicions transaction


report (STR) filed by a financial institution for suspicious
activity on a client's account. Subsequently, the agency requests
further information. Which supporting documentation might the
law enforcement agency request from the institution tofacilitate
its investigation?

Findings from a regulatory examination report states that the job


descriptions of personnel outside of the compliance department
do not include references to anti-money laundering
responsibilities. Which action should the firm take?

The board of directors receives notice from the primary


regulator of the bank that potentially suspicious activity has
been identified and the bank president appears to be involved.
The Board asks the compliance officer for advice. Which action
should thecomplianceofficer takewheninformed?
A local law enforcement officer notifies the bank compliance
officer that he is working on an insurance fraud scheme that
appeal’s to be running transactions using the account of a bank
employee. The law enforcement officer refers to a kiting
suspicions transaction report filed by the compliance officer and
requests further information. What action should the compliance
officer take?

Which location provides a law enforcement investigator the best


opportunity for a productive investigative interview of a
suspect?

At a community bank, the compliance officer identifies unusual


activity on a customer, who with his personal and company
accounts, is the bank’ largest depositor. The customer's
companies have significant balances on their outstanding loans.
The compliance officer notices that there is a lot of unusual
movement of money between the customer's individual and
business accounts. After filing a suspicious transaction report
(STR), the compliance officer gets a call from law enforcement
indicating that they want the bank to keep the account open
while they conduct an investigation into the customer. How
should the compliance officer escalate this information tothe
board of directors?

A local law enforcement officer, who is conducting a criminal


investigation, requests informationabout [Link]
twoactions shouldthebank take? Choose2answers

A director of a financial institution was convicted of laundering


money as part of a Ponzi scheme and terminated. As a result of
internal investigation evidence proved that an employee assisted
in the illegal activity. Which action should the institution take?
In reviewing recent transaction activity, a compliance officer for
a money transmitter notices that several customers are each
remitting the same amount of money but much
[Link] theinstitutionrespond?

In conducting a criminal investigation, what are three things that


the law enforcementinvestigator should do?

A law enforcement representative calls up the compliance


officer and urgently requests information pertaining to a
particular account in connection with an on-going terrorist
financing investigation. What should the compliance officer do?

After reporting suspicious activity to the appropriate authorities


and they request additional follow up on the reports, which of
the following actions should an AML compliance officerdo?

After receiving an STR, the relevant law enforcement agency


requests permission to interview the bank personnel who are
familiar with the underlying transaction. What should the
compliance officer recommend?
What are three factors a prosecutor should take into
consideration in deciding whether to bring criminal charges
against a financial institution?

The compliance officer is trying to put together a set of


procedures for handling the decision of whether or not to file an
STR. What should the compliance officer recommend to be part
of these procedures?

Typically, when should a financial institution file an STR?

What are three developments that should cause a financial


institution to conduct an internal investigation?
What is an advantage of having an outside counsel perform an
internal investigation on behalf of the financial institution?

Whatarethreeoftherecommendedways torespondtoalaw
enforcementinquiry?

What three steps should be taken when there is a criminal


investigation that is targetingthebank itself?

When a financial institution is responding to a formal criminal


investigation by a law enforcement agency, what is the primary
purpose of requiring information going through a central point
within the institution?
When should a financial institution consider retaining an
experienced outside counsel toassist it?

What are three practical tips in interviewing employees with


regard to an unusual or suspicious transaction that they have
witnessed?

What are three initial things that a law enforcement investigator


should consider in following up on a SAR submitted by a
financial institution?

The compliance officer of a financial institution has just


received an extensive law enforcement subpoena focusing on
the potential inadequacy of the institution’s AML
[Link] thecompliance officer should do?
What are three factors with regard to how and when to report a
SAR to the senior management and/or the Board of Directors of
a financial institution?

Mr. Rayhan, the AML compliance officer for a large financial


institution, uncovers a serious case of potential money
laundering being conducting through a number of related
accounts. What are three factors she should consider in deciding
whether or nottoclose theaccounts?

Rick is the AML compliance officer for a small bank that has
had AML difficulties and that is operating under a deferred
prosecution agreement with the federal government. The FBI
approaches Rick and requests that the bank maintain an account
that the FBI is examining so that the FBI can monitor
continuing activity. What two things should Rickdo?

Identify three methods that law enforcement may use to request


information from afinancial institution during thecourse of
acriminal investigation.

An account officer who maintains an excellent relationship with


the finance manager for a correspondent bank customer learns
that many records for the correspondent bank have been
requested by law enforcement. In the interest of maintaining a
good relationship with the customer, the account officer sets up
a meeting to discuss the legal request with the customer. The
account officer intends to discuss points related tothe
investigation during the meeting. What should an anti-money
laundering specialist recommend?
What are three initial things that a financial institution should do
in responding to red flags which indicate that a customer is
laundering money through his or her accounts?

What are some useful tools or methods in conducting an internal


AML investigation? ChooseThree

What is most valuable when using the internet as an


investigative source?

Aclient who owns a swimming pool company requests to open


15 accounts at a bank, each with a debit card for its swimming
pool technicians. When asked about the purpose of each
account, the client explains that each technician needs a separate
checking account to purchase pool chemicals. Which available
source could be used in the bank's internal investigation on this
client's activities?

What are the three classic gateways for international


cooperation and sharing?

What facilitates law enforcement agent obtaining evidence from


authorities in a foreign country relating to criminal activity?
Why is the Mutual Legal Assistance Treaty (MLAT) a gateway
for international cooperation?

Commission regotorie would be used in which gateway to


obtain information from another country?

What might limit a compliance officer’s ability to respond to a


foreign law enforcement official's request to provide
information with regard to an anti-money
launderinginvestigation?

Which two mechanisms should be implemented to assist with


cross-border money laundering investigations?
What is the Right of Reciprocity in the field of international
cooperation against moneylaundering?

Among the Principles for Information Exchange Between


Financial Intelligence Units for Money Laundering Cases,
issued by the Egmont Group on June 13, 2001, we find which of
the following?

With regard to exchanges of information between FIUs of


different countries, what are three controlling principles?

Why is the Mutual Legal Assistance Treaty (MLAT) a gateway


for international cooperation?
Which statement is true related with IMoLIN, International
Money Laundering InformationNetwork

What is a 'commission rogatoire'?

How do FIUs (financial intelligence units) share information


internationally? Choosetwo

What are the principles from the Egmont group related to


information sharing? Choose Two

In which ways does a government Financial Intelligence Unit


interact with public and private sectors? Choose two

Which factors assist amoney laundering investigation that


involves multiple countries?
Which action should an FIU consider taking when it has
information that might be useful to another FIU?
MCQ My Answer Correct Answer

A. Regulatory recommendations or official findings. [Link]


media information. C. Referrals from
customer-facing employees regarding potential Suspicious
Activities. D. Transaction monitoring
rules designed to detect potential Suspicious Activities.

A. When the institution receives a grand jury subpoena with regard


to transactions that have occurred within several accounts at the
institution.
B. When several employees of the institution alert senior
management or the compliance officer that there are
somesuspicious transactions within an account.
C. When the institution’s auditor identifies various shortcomings in
the institution’s AMLpolicies and procedures.
D. When a small local business starts engaging in overseas activity
involving numerous, unexplained wiretransfers.

A. When there is a suspicion that an employee is conspiring with a


long-term customer to launder money through the bank.
B. When a series of customers open separate accounts at different
branches, but with the same contact information.
C. When the bank’s regulatory agency gives the bank low marks
with regard to its AML compliance efforts.
D. When a long term employee decides to take only intermittent
vacation days, but not two weeks in a row, per bank policy.
E. When three employees are appointedin Compliance but not
specific Rules.

A. When he received alert from transaction monitoring system B.


When he receives a governmental subpoena
C. When he receives a customer Identification Document
D. When he receives an adverse regulatory opinion against a valued
customer
E. When he learned about his customer from CDD

A. When he received alert from transaction monitoring system


B. When he receives a search Warrant
C. When he receives a customer Identification Document
D. When he receives an positive regulatory observation against a
customer
E. When he receives a referral from customer-facing employees
regarding potential suspicious activities
A. To identify the customer’s customer. B. To
identify abnormal business transaction C. To
identify business documents
D. To identify predicate Offence

A. Provide all records and documents the officer believes would be


pertinent to the law enforcement agent’s investigation.
B. Refuse to provide any records or documents until the agent
narrows the scope of the request down towhat he or she actually
needs
C. Not act on the legal process until the bank officer has contact
with the agent and learns what the agent is investigating
D. If there is no basis for contesting the request, provide what is
requested

A. Secure documents related to the suspicious circumstances and


the decision to report.
B. Check with other financial institutions in accordance with the
relevant law.
C. Add information related to the suspicious activity to the
customer's accountopening file.
D. Contact the customer for further information without disclosing
the suspicion.

A. The compliance officer should ensure that the staff research and
collect all documents responsive to the subpoena.
B. The compliance officer should insist on law enforcement
explaining why the subpoena was issued and what law enforcement
is looking for.
C. The compliance officer should ensure that an independent review
is conducted of the account and the transactions in the account.
D. The compliance officer should only comply with the subpoena
after first getting approval from the bank’s legal counsel.
A. Get permission from the Board of Directors to hand the material
over to law enforcement.
B. Hand the material over to law enforcement immediately because
of the urgent nature of the request
C. Request the law enforcement representative provide a court order
or grand jury subpoena unless the bank has already filed an STR on
the matter D. Get
permission from the bank’s legal counsel before handing the
material over to law enforcement.

A. He should advise the employees to maintain the confidentiality


of all SARs.
B. He should notify the Board of Directors and senior management
of the financial institution of the subpoena and its focus on the
institution.
C. He should consider advising the institution to retain outside
counsel who is experienced in this area.
D. He should consider providing law enforcement with the results
of any internal investigation conducted by the institution.
E. He should consider advising the institution to retain inside
counsel who is experienced in general.

A. Inform the customer that his/her activity has been reported as


suspicious and the authorities are asking about him/her.
B. Indicate to the authorities that you have fulfilled your regulatory
duty by referring the matter to them.
C. Give the authorities everything they request.
D. Cooperate fully with the authorities, as permitted by law.

A. Provide all informationrequestedtosupporttheinvestigation.


B. Ensure that the request will not violate any local privacy
regulations orlegislation.
C. Ensure the information is necessary to the investigation before
responding totherequest
D. Contact the customer informing me person of the investigation to
ensure thebank provides correct information.

A. Obtaining and issuing a Grand Jury subpoena.


B. Telling the AML officer to hand over all account statements of
the targeted suspect
C. Asking for documentation that supports a SAR that has been
filed.
D. Telling the AML officer to hand over all account records of the
targeted suspect
E. Serving a search warrant.
A. They should not release any documents until the institution’s
outside counsel arrives on the scene.
B. They should try to obtain the materials that the law enforcement
agents takefromtheinstitution.
C. They should cooperate fully with the law enforcement agents and
remain calm and polite
D. They should review the warrant to determine its scope.
E. They should try to obtain an inventory of the materials that the
law enforcementagents take fromtheinstitution.

A. The officer should notify the Board of Directors of the nature


and results of the internal investigation.
B. The officer should document the nature and results of the
internal investigation and keep the documentation in an appropriate
file.
C. The officer should file an STR in case that the customer’s
accounts could assist law enforcement in its formal criminal
investigation.
D. The officer should file an STR in order to justify the time spent
on the internal investigation and to not be second guessed by the
bank examiners.

A. EvaluatingtheoutputofExaminationofregulator B.
Conductingpropertrainingonriskassessment C.
Evaluatingtheoutputofmonitoringrules D.
Examiningspecificthresholds E.
Conductingaboveandbelow-the-linetesting

A. Peer B.
Income C. Below-
the-line
D. MappinG
A. Should setup a new parameter considering the financial sectors.
B. Should setup a new parameter considering his previous
experience in the financial sectors. C.
Conducting below-the-line testing to determine whether rule
adjustments are necessary. D.
Conducting above- the- line testing to determine whether rule
adjustments are necessary.

A. Agree to keep the account open.


B. Request a subpoena to maintain the account. C.
Request a letter on the agency's letterhead D.
Request a search warrant from the local court.

A. Investigate these unusual transactions further


B. Contact the local FIU for advice
C. File an STR with the competent authorities
D. Document reasons for not filing a STR

A. Previously filed STRs on the same customer.


B. Account opening documents and account statements C.
Copies of promotional materials sent to the customer. D. A
copy of the institution's STR policy and procedures.

A. Update all job descriptions to include anti-money laundering


responsibilities.
B. Respond that only compliance personnel have anti-money
laundering responsibilities.
C. Send an email to all staff stating that personnel must observe the
anti-money laundering policy. D. Reply
that a description of anti-money laundering responsibilities is
included in the annual training.

A. Destroy all records relating to the matter.


B. Insist on the president's immediate resignation.
C. Inform the bank’s legal counsel and follow their instructions D.
Inform the president of the regulator’s suspicions and ask for his
advice.
A. Inform the board of directors.
B. Call the employee and demand an explanation.
C. Allow access to the bank's documents immediately.
D. Provide the information to law enforcement in response to a
formal written request

A. The residence of the suspect.


B. The office or work location of the suspect.
C. A neutral location such as a coffee shop or restaurant.
D. An interview room in the offices of a law enforcement agency.

A. By providing a copy of the STR to the board.


B. By informing the regulator to bring it up with their next meeting
with the board.
C. By providing a high level summary of the activity and the
interactions with law enforcement. D. By
providing a copy of the letter from law enforcement asking the bank
to keep the account open.

A. Close the account immediately.


B. File a suspicious transaction report.
C. Monitor the account for suspicious activity D.
Review the money laundering risk posed by the account

A. Discipline the employee with no further action.


B. Discipline the employee and inform local authorities C.
Since the employee was not charged, no further action is required.
D. Require all employees to complete additional AML training.
A. File a suspicions transaction report. B.
Instruct the tellers not to process remittances for these customers in
the future. C. Conduct further
investigation to determine whether this is truly suspicious activity.
D. Immediately contact the
customers and ask them why they are remitting money more often.

A. The criminal investigator should make every effort to “follow


the money” in thetransaction
todeterminewhereitcamefromandwhereitwent.
B. The criminal investigator should identify the potential unlawful
activity involved, referredinsomecountries as the“specified
unlawfulactivity.”
C. The criminal investigator should document the underlying
activity and transactions potentiallyinvolved inthetransaction.
D. The criminal investigator should research all similar cases that
have occurred inrecenthistory intheimmediatearea.
[Link] criminal investigator should Contact with CFO who is
responsible for the Books of all account

A. Get permission from the Board of Directors to hand the material


over to law enforcement. B. Hand the
material over to law enforcement immediately because of the urgent
nature of the request. C. Request the law
enforcement representative provide a court order or grand jury
subpoena unless the bank has already filed an STR on the matter.
D. Get permission from the
bank’s legal counsel before handing the material over to law
enforcement

A. Inform the customer that his/her activity has been reported as


suspicious and the authorities are asking about him/her
B. Indicate to the authorities that you have fulfilled your regulatory
duty by referring the matter to them. C. Give the
authorities everything they request. D. Cooperate
fully with the authorities, as permitted by law

A. The officer should confer with bank counsel as to whether to


request subpoenas from law enforcement. B. The
officer should deny permission for any such interviews without the
creation of a grand jury or a formal court ordered investigation.
C. The officer should only
allow those employees who are comfortable be interviewed by law
enforcement. D. The officer should allow the
employees to be interviewed only if they are given immunity by law
enforcement.
A. Whether the institution has a criminal history. B.
Whether the institution cooperated with the law enforcement
investigation C.
Whether the institution discovered and self-reported the potential
criminal violation. [Link] the
institution is a very large institution and its prosecution will make
good headlines for the law enforcement agency

A. The officer should recommend that the decision as to whether or


not to file an STR be centralized to ensure uniformity
B. The officer should recommend de-centralizing the decision in
order to speed up the process and to ensure that the decision is made
closest to where the activity occurred. C. The
officer should recommend that STRs only be filed once they have
been authorized by the Board of Directors of the bank.
D. The officer should
recommend that STRs only be filed once they have received a
thorough legal review.

A. Whenever they are preparing to close an account.


B. Whenever they detect unusual or suspicious transactions
C. Only when they are able to establish the existence of a criminal
violation
D. Only when the Board of Directors approves the filing of the
STR.

A. When the institution receives a grand jury subpoena with regard


to transactions that have occurred within several accounts at the
institution.
B. When several employees of the institution alert senior
management or the compliance officer that there are some
suspicious transactions within an account.
C. When the institution’s auditor identifies various shortcomings in
the institution’s AMLpolicies and procedures
D. When a small local business starts engaging in overseas activity
involving numerous, unexplained wiretransfers.
[Link] outside counsel can bring an impartial and legal perspective
to the review.
B. The outside counsel can intimidate the employees into
confessing complicity with the wrongdoers.
C. The outside counsel can create an attorney-client privilege not
just vis à vis the bank, but also in connection with each employee.
D. The outside
counsel will be able to convince the prosecutors not to take any
action against the institution.

A. Cooperate with the law enforcement inquiry as much as possible.


B. Respond to all formal requests for information as promptly and
thoroughly as possible, unless there is a valid objection that can and
should be made.
C. Ensure that all communication, written and oral, is funneled
through a centralized place
D. Guard against unwarranted publicity by resisting all inquiries
and requests whenever possible.

A. The senior management and the Board of Directors should be


notified and kept apprised of the progress of the investigation.
B. The bank should consider retaining experienced outside counsel
to assist the bank in responding to the investigation
C. The bank should immediately go to the media and explain why it
has done nothing wrong.
D. The relevant employees of the bank should be notified of the
existence of the investigation and should be given instructions as to
what todo and how toact.

A. To be able to ensure that nothing damaging to the financial


institution gets released.
B. To ensure that responses are timely and thorough and that
privileged material is not inadvertently handed over.
C. To ensure that the employees of the institution do not divulge
information that would breach the privacy rights of customers.
D. To ensure that there is one person who can adequately and
thoroughly apprise the Board of Directors of the progress of the
investigation.
[Link] the institution receives a subpoena from any law
enforcement agency.
B. When the institution itself appears to be the target of a criminal
investigation.
C. When law enforcement appears to be focused on the accounts of
a very good and long-standing customer of the institution.
D. When the banking agencies criticize the adequacy of the
institution’s AML monitoring procedures.

A. One should interview the employees as soon after the occurrence


as possible in order to ensure that their memories are fresh
B. One should try to put the employees at ease during the interview
and start with relatively easy, noncontroversial, questions before
getting into more sensitive matters.
C. One should use open-ended questions for the employees in order
to ensure that the questions do not dictate what the expected answer
is
D. One should control the interview as much as possible in order to
attempt to resolvethe matter quickly and uncover the wrongdoer.

A. Identifying the unlawful activity and any specified unlawful


activity.
B. Considering providing immunity to the target of the investigation
to get more information quickly.
C. Tracing the source and ownership of illegal money through all
appropriate accounts.
D. Determining whether to freeze or seize the accounts through
which the illegal money is flowing.

A. He should advisethe employees to maintain the confidentiality of


all SARs.
B. He should notify the Board of Directors and senior management
of the financial institution of the subpoena and its focus on the
institution.
C. He should consider advising the institution to retain outside
counsel who is experienced in this area.
D. He should consider providing law enforcement with the results
of any internal investigation conducted by the institution.
A. Whether the SARs filed are in excess of the previous year’s
filings
B. Whether the SAR raises significant issues, especially in terms of
reputational risk
C. Whether the SAR indicates any compliance deficiencies.
D. Whether the SAR is indicative of any significant AML trends.

A. Whether the account holder is a close associate of any of the


members of the Board of Directors.
B. Whether the alleged money laundering activity is occurring in all
of the accounts, or just some of the accounts.
C. The legal basis for closing the accounts.
D. The reputational risk to the institution if the accounts are
maintained.

A. Ask that request be submitted in writing.


B. Ensure that the request is from someone with appropriate
authority
C. Ask the Board of Directors to approve keeping the account open
after an internal investigation.
D. Keep the account open in order to not incur any further disfavor
with the federal government.

A. Obtaining and issuing a Grand Jury subpoena.


B. Serving a search warrant.
C. Asking for documentation that supports a SAR that has been
filed.
D. Telling the AML officer to hand over all account records of the
targeted suspect.

A. Discuss all the points being investigated by law enforcement to


ensure the correspondent bank is well prepared when approached
B. Let the account manager’s manager know what conversations
have taken place with the customer and document the account file
accordingly
C. Limit discussions about the investigation with the customer and
be satisfied that the account manager has provided proper notice to
the customer
D. Cancelled the meeting as he has already behaved inappropriately
by alerting to the investigation
A. Identifying and reviewing internal transactions engaged in by the
customer.
B. Performing an internet investigation focused on the customer,
including a review of court records.
C. Confronting the customer about the possible abuse of his or her
accounts D.
Comparing the income generated by the customer with comparable
businesses in the area.

A. Reviewing documents, particularly of relevant accounts


B. Interviewing CEO of the institution
C. Exploring leads through internet searches
D. Interviewing Customer of the institution E.
Interviewing knowledgeable employees of the institution

A. A team of AML investigators


B. A reference list of websites known to yield credible information
C. A combination of independent thinking and technical skills
D. A powerful search engine

A. Client’s credit bureau report.


B. Local law enforcement investigation report.
C. Interview swimming pool technicians and chemical suppliers.
D. Internet search showing how such businesses are typically
operated

A. Mutual Legal Assistance Treaties (MLATs).


B. Law enforcement use grand jury subpoenas.
C. Exchange of information between Financial Intelligence Units
(FIUs).
D. Exchange of information between supervisory agencies

A. Patriot Act Communications System


B. Mutual Legal Assistance Treaties (MLAT)
C. The World Wide Network of Information Sharing
D. MLAT Executive Agreement
A. They obtain intelligence that might lead to evidence
B. They receive reports of suspicious transactions from financial
institutions to disseminate to local Law enforcement and foreign
Flus
C. They provide a legal basis for transmitting evidence that can be
used for prosecution and judicial proceedings
D. They issue the Principle of Information Exchange Between
Financial intelligence Units (FlUs)

A. An FIU request under the Egmont principles


B. An MLAT request
C. A supervisory channel request with the Basel Committee
D. A FATF request

A. Privacyand data protection laws in the compliance officer's


country.
B. Whether there is a mutual legal assistance treaty between the
countries of the compliance officer and the law enforcement
official.
C. Whether the request has been processed by the foreign law
enforcement official's embassy inthe compliance officer's country.
D. Anti-money laundering laws that require the confidential
treatment of Suspicious Transaction Reports in the law enforcement
official's country.

A. Countries should request Interpol to provide the required


information.
B. Countries should ensure that information received is protected
from unauthorized disclosure.
C. Countries should establish mechanisms allowing financial
investigators to obtain and share information in respect of specific
investigations.
D. Countries should conduct separate investigations to ensure
information is not unintentionally disclosed without the appropriate
legal approval.
A. The legal principle that financial institutions that have referred
customers to other financial institutions can share information about
these customers with the other institutions.
B. 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.
C. The right of each FATF member country to delegate prosecution
of a case of money laundering to another member that is already
investigating the samecase. D. A rule in the law
of acountry allowingits authorities to cooperatewith authorities of
other countries to the degree that their law allows them todo the
same.

A. Information-sharing agreements must follow the model issued by


the Egmont Group.
B. Information which is shared under these agreements will be
exempt from the local privacy laws of the countries involved.
C. Information exchanged between FIUs may be used only for the
specific purpose for whichthe information was sought or provided.
D. The requesting FIU may make use of the information shared by a
disclosing FIU for administrative purposes without the prior consent
of the disclosing FIU.

A. That sharing between FIUs be permitted only if the central banks


are also a party tothe sharing.
B. That the sharing ofinformation should bedone as freely as
possible on the basis of reciprocity.
C. That the sharing should be on the basis of requests and also
spontaneously
D. That differences in the definition of offenses should not impede
the free exchange of information.

[Link] provide a legal basis for transmitting evidence that can be


used for prosecution and judicial proceedings
B. They receive reports of suspicious transactions from financial
institutions to disseminate to local Law enforcement and foreign
FIUs
C. They obtain intelligence that might lead to evidence
D. They issue the Information Exchange Between Financial
intelligence Units (FIUs)
A. It created and disseminated AML Standard
B. It was created by the USA
C. It acts as a clearing house of money laundering information
D. All of the above

A. A letter requesting cooperation from a foreign central authority


B. A gateway for international cooperation
C. Permission from a central authority that allows a foreign
investigation to occur
D. A letter of decline, where a central authority refuses a foreign
investigation

A. Using a commission rogatoire


B. Using a multilateral legal assistance treaty (MLAT)
C. Spontaneously D.
Using a memorandum of understanding

A. Free exchange of information, on the basis of reciprocity


B. Consent to dissimilate the information even if it is not within
AML/CFT provisions
C. Respect privacy and confidentiality
D. Information must share with every members of Egmont group

A. It governs the methods of investigation used by competent


authorities
B. It receives and analyzes disclosures filed by financial and non-
bank institutions
C. It disseminates information and the results of its analysis to
competent authorities
D. It does not disseminates information to competent authorities
because STR is confidential Report.

A. Law enforcement and other authorities should have access to


financial information that is pertinent to the investigation
B. Every country should share all their information with foreign law
enforcement and government authorities to facilitate rapid
investigations.
C. Law enforcement and other authorities should be allowed to
establish and utilize joint investigative teams with law enforcement
in other countries.
D. Law enforcement and other authorities should not expedite
information sharing between countries to ensure that all information
is provided at the same time to avoid premature conclusions.
A. In accordance with Wolfsberg guidelines, submit the information
to the other FIU in written form
B. Supply the information to the other FIU spontaneously as soon as
the relevance of sharing the information is identified
C. Take no action until contacted by the other FIU
D. Request approval from the Egmont Group prior to sharing the
information with the other FIU
D
ABD
ABD
ABD
ABE
B
D
A
AC
C
BCD
D
C
ACE
CDE
B
CDE
D
D
C
D
B
A
C
D
D
C
CD
B
A
ABC
C
D
A
ABC
A
B
ABD
A
ABC
ABD
C
B
ABC
ABC
BCD
BCD
BCD
AB
ABC
D
ABD
ADE
B
D
ACD
B
C
B
A
BD
D
C
BCD
A
C
A
CD
AC
BC
C
B

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