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1. A bank received a subpoena regarding one of its clients. The financial intelligence unit of the bank should review the subpoena and:
A) Adjust the client's risk score and close the case.
B) Close the client's account by informing the client of the subpoena.
C) Perform a transaction review and respond fully to the subpoena.
D) File a suspicious activity report (SAR), including the receipt of the subpoena in the SAR narrative.
2. Which control would be most effective as part of a risk-based approach (RBA) to managing AML/CFT risk for a bank established in the EU that also has a branch in a high-risk third country outside of the EU?
A) Automatically apply enhanced customer due diligence measures to all customers in the high-risk third-country branch regardless of risk level
B) Monitor every cross-border transaction in real time, flagging all for enhanced scrutiny due to the country risk level
C) Apply tailored due diligence measures, based on the level of risk posed by each customer following risk assessment
D) Fully rely on central beneficial owner registry records in the high-risk third country to determine the ultimate beneficial owners of all customers
3. A prospective client walks into an accounting firm wanting to incorporate a company. The accountant feels uncomfortable after the meeting. Which two of the accountant's observations warrant escalation to the compliance officer? (Select Two.)
A) The prospective client is unable to provide information about the beneficial owners
B) The prospective client exhibits confidence when speaking to the accountant when providing personal details
C) The prospective client is able to provide source of funds and source of wealth documents
D) The prospective client presents confusing details about the proposed business and has very little knowledge about the proposed business activity
E) The principal activities of the proposed company are importing and exporting new furniture
4. Which types of external data sources are expected to be used for screening customers as part of customer due diligence (CDD)? (Select Three.)
A) Customer feedback and online review platforms
B) Social media profiles to assess lifestyle and spending habits
C) Sanctions lists, including those issued by the Office of Foreign Assets Control (OFAC)
D) Registers of stolen or forged documents (where available)
E) Beneficial ownership registers and adverse media sources
5. A deficiency in the design of a bank's AML/CFT compliance program could result in placing individual accountability on which part of the regulated entity? (Select Two.)
A) The compliance department
B) Board of directors
C) Product oversight committee
D) Senior management
Solutions:
| Question # 1 Answer: C | Question # 2 Answer: C | Question # 3 Answer: A,D | Question # 4 Answer: C,D,E | Question # 5 Answer: B,D |
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