| Topic 1 | Topic 2 | Topic 3 | Topic 4 | AML Program |
|---|---|---|---|---|
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What are the 3 stages of money laundering?
Placement, layering, and integration.
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Financial institutions must complete and file electronically this report with FinCEN whenever a customer engages in transactions are determined to be suspicious.
Suspicious Activity Report (SAR)
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What is HIDTA?
High Intensity Drug Trafficking Area
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Banks are required to file SARs on suspicious activity involving $_____ or more in total suspicious activity.
$5,000.00
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What is the 1st pillar of an AML program?
Development of policies, procedures, and internal controls.
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What is deliberate ignorance and failure to follow up in the face of information that suggests probable money laundering or illicit activity.
Willful blindness
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What acronym means natural persons who are or have been entrusted with prominent public functions and the immediate families, or individuals known to be close associates of such persons?
PEP (Politically Exposed Person)
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What is HIFCA?
High Intensity Financial Crimes Area
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Removing a name, entity, or country from a wire that was initially rejected in order to enable that wire to be completed is commonly known as ______
Wire Stripping
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What is the 2nd pillar of an AML program?
Designation of a compliance officer.
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This federal agency created the e-filing system allowing financial institutions to electronically file Currency Transaction Reports (CTR) and Suspicious Activity Reports (SAR).
FinCEN
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This report is filed on all cash transactions conducted by customers in a single day greater than or equal to $10,000.01.
Currency Transaction Report (CTR)
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This act was passed in 1970 and requires financial institutions in the United States to assist US government agencies in detecting and preventing money laundering.
Bank Secrecy Act (BSA) also known as Currency and Foreign Transactions Reporting Act
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Releasing confidential SAR information may have many consequences including monetary fines as well as _______.
Jail
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What is the 3rd pillar of an AML program?
An ongoing training program for employees.
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The role of this agency is to administer and encforce economic and trade sanctions against individuals, entities, and foreign governments considered to be at odds to US policy.
Office of Foreign Assets Control (OFAC)
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List some red flags for structuring activity.
$7,500.00 to $10,000.00 in short time periods.
Multiple branches on same day/short time frames. |
Provide some examples of high risk customers.
PEPS, cash intensive businesses, NGO/charities, political organizations, NRAs (depending on country)
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What are the three types of OFAC sanctions
Comprehensive/country wide
Capital markets-related or sectoral sanctions List based sanctions |
What is the 4th pillar of an AML program?
Independent testing, audits, and reviews to evaluate programs.
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This manual sets the standard for AML/BSA compliance procedures and testing for US financial institutions.
FFIEC (Federal Financial Institutions Examination Council)
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List 3 (of many) red flags for suspicious activity.
1. Pass through activity.
2. Activity doesn’t make sense for customer business/profile. 3. Refuses to answer source of funds. |
Marijuana, which is legal some local and stateside jurisdictions, remains ____ at the federal level. As a result, many banks classify these types of businesses are
Illegal
Prohibited |
Name 3 countries or jurisdictions subject to sanctions.
Many. Iran, North Korea, Syria, Cuba, Crimea, North Sudan. Venezuela (energy/finance/gold/gov entities) and others.
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What is the 5th pillar of an AML program (recently added in 2018).
Customer Due Diligence (CDD) and CIP (Customer Identification Programs). Financial institutions must know and update customer’s information and beneficial ownership.
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