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?

1. A. Provide all information requested to support the investigation
2. B. Ensure that the request will not violate any local privacy regulations or legislation
3. C. Ensure the information is necessary to the investigation before responding to the request
4. D. Contact the customer informing the person of the investigation to ensure the bank provides information

Correct Answer: C

A U.K. real estate agent has three foreign clients interested in purchasing an apartment building, valued at £30 million, in the outskirts of London as an investment property. The clients are not willing to have their names provided to the bank. The clients want to purchase to be made in the names of three private companies for privacy reasons. The plan is to wire the funds into an account held in the name of another private company at a bank in London.
Which red flag should stop the agent from discussing this potential purchase further?

1. A. The clients are foreign
2. B. The clients have the funds necessary to fund a £30 million purchase
3. C. The clients are not willing to have their names provided to the bank
4. D. The clients want to purchase to be made in the names of the private companies

Correct Answer: C

Who has the ultimate responsibility within a bank for ensuring that the bank has a comprehensive and effective Bank Secrecy Act / anti-money laundering (BSA/AML) program and oversight framework that is reasonably designed to ensure compliance with applicable regulations?

1. A. Senior management
2. B. Board of directors
3. C. Business line managers
4. D. BSA/AML compliance officer

Correct Answer: B

Which action does the Financial Action Task Force (FATF) recommend be taken against jurisdictions that have strategic deficiencies?

1. A. Conduct due diligence
2. B. Apply counter-measures
3. C. Add the jurisdiction to the United Nations’ list of sanctioned jurisdictions
4. D. Create an action plan to address the deficiencies without the support of the FATF

Correct Answer: B

A compliance officer at an insurance company has been reviewing the transaction activity of several clients. Which transaction is considered a red flag for potential money laundering?

1. A. A client paid the quarterly life insurance premium using money orders from two different banks.
2. B. A client from a high-risk jurisdiction recently purchased property insurance for a real-estate development.
3. C. A corporation owns several affiliates and recently opened separate group life insurance policies for each of the affiliates.
4. D. A client established a $100,000 charitable annuity with a non-profit organization that provides health and safety assistance internationally.

Correct Answer: D