Which two factors assist a money laundering investigation that involves multiple countries? (Choose two.)
Correct Answer: C,D
Question 308
A bank employee reviews wire transactions looking for indications of wire stripping. Which two actions should the employee take to complete appropriate bank procedures? (Choose two.)
Correct Answer: A,B
Wire stripping is a technique used by money launderers to remove or alter information that identifies the originator or beneficiary of a wire transfer, in order to avoid detection or tracing. To detect wire stripping, a bank employee should compare the wire transaction as it enters and after it leaves the bank, and look for any discrepancies or missing information in the fields related to the originator or beneficiary. The employee should also check for suspicious phrases usually used to conceal originator or beneficiary identity, such as "for further credit", "in favor of", "on behalf of", or "as instructed". References: CAMS Study Guide, 6th Edition, Chapter 3, Section 3.21 CAMS Study Guide, 6th Edition, Chapter 5, Section 5.31 ACAMS Chapter 3 Exam Questions, Question 792 FATF Guidance on Transparency and Beneficial Ownership, Section 3.23 Reference: https://www.lexology.com/library/detail.aspx?g=79732c5e-b4bf-456a-9604-712f44f5a930
Question 309
Who has the day-to-day responsibility of communicating and reinforcing the established anti-money laundering compliance culture and program?
Correct Answer: D
The compliance officer is the person who has the day-to-day responsibility of communicating and reinforcing the established anti-money laundering (AML) compliance culture and program within the organization. The compliance officer is also responsible for overseeing the implementation, maintenance, and improvement of the AML policies, procedures, controls, and training. The compliance officer should have sufficient authority, independence, and resources to perform their duties effectively and report to senior management and the board of directors on the status and effectiveness of the AML program. References: 1, Chapter 4: Designing and Implementing an AML Compliance Program 2, FFIEC BSA/AML Examination Manual, Compliance Program - Overview 3, FinCEN Advisory, Guidance on Promoting a Culture of Compliance
Question 310
Which are the two most common controls a financial institution (FI) uses to identify suspicious money-laundering activity? (Choose two.)
Correct Answer: B,E
Question 311
What are two aspects of the Wolfsberg Anti-Money Laundering (AML) Principles for Correspondent Banking? (Choose two.)
Correct Answer: A,C
According to the Wolfsberg Anti-Money Laundering (AML) Principles for Correspondent Banking, one of the key aspects of establishing and maintaining a correspondent relationship is to conduct a risk-based due diligence on the respondent bank, which includes obtaining approval from at least one person other than the person sponsoring the relationship12. This is to ensure that the correspondent bank has a clear understanding of the nature, purpose, and expected activity of the relationship, as well as the respondent bank's ownership, governance, AML policies, and customer base12. Another aspect of the Wolfsberg AML Principles is to recognize and assess the factors that may increase the risk inherent in a correspondent relationship, such as the involvement of politically exposed persons (PEPs), the presence of downstream (nested) correspondents, the geographic location of the respondent bank and its customers, and the types of products and services offered by the respondent bank12. These factors may require enhanced due diligence, monitoring, and reporting of suspicious activities by the correspondent bank, as well as the application of appropriate risk mitigation measures12. References: * 1: Wolfsberg Correspondent Banking Principles 20221 * 2: Wolfsberg Anti-Money Laundering Principles for Correspondent Banking2 Reference: https://www.wolfsberg-principles.com/sites/default/files/wb/pdfs/wolfsberg-standards/8.% 20Wolfsberg-Correspondent-Banking-Principles-2014.pdf