In reviewing recent activity, a compliance officer for a money transmitter that several customers are each remitting the same amount of money but much more frequently. How should the institution respond?

1. A. File a suspicious transaction report
2. B. Instruct the tellers not to process remittances for these customers in the future
3. C. Conduct further investigation to determine whether this is truly suspicious activity
4. D. Immediately contact the customers and ask them why they are remitting money more often

Correct Answer: C

A client is a wholesale auto business that operates as a used car lot. The client regularly ships vehicles internationally. In a four-month period, the client received wires totaling $ 1,250,000 from a dealer in Benin in West Africa. All wires originated from Benin and were in increments of $50,000.
Account debits made to the account were payable to various transport companies. All incoming checks reference various vehicles purchased. Dock shipping receipts produced by the client to support account activity identify the vehicles but cannot easily be tied to the wires receives.
What is the suspicious behavior?

1. A. The dock shipping receipts match the vehicles
2. B. Vehicles are regularly shipped internationally
3. C. Wires received are in large, even dollar amounts
4. D. Account debits are payable to transport companies

Correct Answer: C

A compliance officer at a small community bank has been asked to review existing customer onboarding policies and procedures to ensure they adequately address anti-money laundering risks. How should customer due diligence be implemented?

1. A. With an annual compliance review and approval of customers
2. B. With a one-time event conducted at initial customer onboarding
3. C. As an ongoing activity that may vary commensurate with the risk profile of the customer
4. D. As applicable to customers that pose higher money laundering or terrorist financing risk

Correct Answer: C

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?

1. A. A complete client list from the non-U.
2. B. bank
3. C. The identity of owners and percentage of ownership of the non-U.
4. D. bank
5. E. The structure and identity of the management team at the non-U.
6. F. bank
7. G. The details of the non-U.
8. H. bank’s anti-money laundering compliance training program

Correct Answer: C

What are two legal risks of having inadequate privacy policies and procedures? (Choose two.)

1. A. Diminished reputation
2. B. Industry of regulatory sanctions
3. C. Charges of deceptive business practices
4. D. Higher marketing and public relations costs

Correct Answer: AB