Podcast
Questions and Answers
Which of the following is NOT a direct consequence of money laundering?
Which of the following is NOT a direct consequence of money laundering?
What type of risk is most closely associated with public perception of an organization's ethics and practices?
What type of risk is most closely associated with public perception of an organization's ethics and practices?
A bank that has become involved in a money laundering scandal is most likely to experience what?
A bank that has become involved in a money laundering scandal is most likely to experience what?
If a bank suffers from inadequate internal processes, what type of risk is the most likely result?
If a bank suffers from inadequate internal processes, what type of risk is the most likely result?
Signup and view all the answers
What is a potential consequence of legal risk related to money laundering for a financial institution?
What is a potential consequence of legal risk related to money laundering for a financial institution?
Signup and view all the answers
Which action by a depositor could cause liquidity problems for a bank involved in money laundering?
Which action by a depositor could cause liquidity problems for a bank involved in money laundering?
Signup and view all the answers
What could cause an organization to face increased borrowing or funding costs?
What could cause an organization to face increased borrowing or funding costs?
Signup and view all the answers
Which of the following is a potential outcome when customers become victims of financial crime related to money laundering?
Which of the following is a potential outcome when customers become victims of financial crime related to money laundering?
Signup and view all the answers
Who is ultimately responsible for misconduct within an organization's AML/CFT regime?
Who is ultimately responsible for misconduct within an organization's AML/CFT regime?
Signup and view all the answers
What does the New York State Department of Financial Services (DFS) require regulated organizations to maintain regarding transaction monitoring?
What does the New York State Department of Financial Services (DFS) require regulated organizations to maintain regarding transaction monitoring?
Signup and view all the answers
Which of these is NOT a specific requirement concerning the implementation of transaction monitoring systems by the DFS?
Which of these is NOT a specific requirement concerning the implementation of transaction monitoring systems by the DFS?
Signup and view all the answers
What must regulated organizations' boards or senior officers annually certify to the DFS?
What must regulated organizations' boards or senior officers annually certify to the DFS?
Signup and view all the answers
Which type of financial institution is NOT explicitly covered by the New York regulation?
Which type of financial institution is NOT explicitly covered by the New York regulation?
Signup and view all the answers
Why might a foreign bank be subjected to the New York AML law?
Why might a foreign bank be subjected to the New York AML law?
Signup and view all the answers
What was the consequence for Steven David Kinch for breaching his professional anti-money laundering obligations?
What was the consequence for Steven David Kinch for breaching his professional anti-money laundering obligations?
Signup and view all the answers
The New York DFS Final Rule requires transaction monitoring programs that are designed to monitor transactions:
The New York DFS Final Rule requires transaction monitoring programs that are designed to monitor transactions:
Signup and view all the answers
What defines an electronic funds transfer?
What defines an electronic funds transfer?
Signup and view all the answers
Which of these scenarios constitutes an electronic funds transfer?
Which of these scenarios constitutes an electronic funds transfer?
Signup and view all the answers
What is a common tactic used by money launderers when conducting electronic transfers?
What is a common tactic used by money launderers when conducting electronic transfers?
Signup and view all the answers
Which of the following poses a challenge for tracing illicit funds within electronic transfer systems?
Which of the following poses a challenge for tracing illicit funds within electronic transfer systems?
Signup and view all the answers
What is a typical method used by money launderers during the 'layering' phase of the laundering process using electronic transfers?
What is a typical method used by money launderers during the 'layering' phase of the laundering process using electronic transfers?
Signup and view all the answers
What is the purpose behind money launderers using varying amounts in electronic transfers?
What is the purpose behind money launderers using varying amounts in electronic transfers?
Signup and view all the answers
Why might a money launderer prefer to use reputable institutions for electronic fund transfers?
Why might a money launderer prefer to use reputable institutions for electronic fund transfers?
Signup and view all the answers
What is the role of transaction monitoring software in relation to electronic funds transfers?
What is the role of transaction monitoring software in relation to electronic funds transfers?
Signup and view all the answers
Which of these activities is most indicative of money laundering through electronic fund transfers?
Which of these activities is most indicative of money laundering through electronic fund transfers?
Signup and view all the answers
What is a key risk of remote deposit capture (RDC) in the context of money laundering?
What is a key risk of remote deposit capture (RDC) in the context of money laundering?
Signup and view all the answers
When money laundering is suspected using electronic fund transfers, what could raise suspicion?
When money laundering is suspected using electronic fund transfers, what could raise suspicion?
Signup and view all the answers
Which of these behaviors, related to RDC, can most likely indicate money laundering?
Which of these behaviors, related to RDC, can most likely indicate money laundering?
Signup and view all the answers
What situation regarding fund transfers would raise a red flag?
What situation regarding fund transfers would raise a red flag?
Signup and view all the answers
What can be a possible risk associated with correspondent banking when combined with RDC?
What can be a possible risk associated with correspondent banking when combined with RDC?
Signup and view all the answers
Which of the following patterns could suggest potential money laundering through electronic transfers?
Which of the following patterns could suggest potential money laundering through electronic transfers?
Signup and view all the answers
A money launderer may try to exploit RDC by...
A money launderer may try to exploit RDC by...
Signup and view all the answers
What is a primary risk associated with Remote Deposit Capture (RDC)?
What is a primary risk associated with Remote Deposit Capture (RDC)?
Signup and view all the answers
Which of the following is an important control to mitigate the risks associated with Remote Deposit Capture (RDC)?
Which of the following is an important control to mitigate the risks associated with Remote Deposit Capture (RDC)?
Signup and view all the answers
What is the role of a respondent bank in a correspondent banking relationship?
What is the role of a respondent bank in a correspondent banking relationship?
Signup and view all the answers
What is a key concern regarding correspondent banking relationships?
What is a key concern regarding correspondent banking relationships?
Signup and view all the answers
Which of the following is a critical step to take when fraud is detected via RDC?
Which of the following is a critical step to take when fraud is detected via RDC?
Signup and view all the answers
Why might a local bank choose to establish correspondent banking relationships?
Why might a local bank choose to establish correspondent banking relationships?
Signup and view all the answers
Which of the following is an example of a control that should be integrated with RDC processing?
Which of the following is an example of a control that should be integrated with RDC processing?
Signup and view all the answers
Large international banks often act as correspondents for thousands of other banks. What does this indicate?
Large international banks often act as correspondents for thousands of other banks. What does this indicate?
Signup and view all the answers
How do Payable-Through Accounts (PTAs) differ from typical correspondent accounts?
How do Payable-Through Accounts (PTAs) differ from typical correspondent accounts?
Signup and view all the answers
Which of the following entities can be a subaccount holder in a Payable-Through Account (PTA)?
Which of the following entities can be a subaccount holder in a Payable-Through Account (PTA)?
Signup and view all the answers
What is a key element of a PTA relationship that can threaten a correspondent bank’s AML/CFT defenses?
What is a key element of a PTA relationship that can threaten a correspondent bank’s AML/CFT defenses?
Signup and view all the answers
What is a significant risk associated with Payable-Through Accounts (PTAs) regarding the correspondent bank's customer due diligence (CDD)?
What is a significant risk associated with Payable-Through Accounts (PTAs) regarding the correspondent bank's customer due diligence (CDD)?
Signup and view all the answers
What could allowing subaccount holders with currency deposit and withdrawal privileges facilitate?
What could allowing subaccount holders with currency deposit and withdrawal privileges facilitate?
Signup and view all the answers
How might a PTA in conjunction with a subsidiary or representative office of a respondent bank be misused?
How might a PTA in conjunction with a subsidiary or representative office of a respondent bank be misused?
Signup and view all the answers
What made Payable-Through Accounts (PTAs) considered high risk?
What made Payable-Through Accounts (PTAs) considered high risk?
Signup and view all the answers
Why did the misuse of PTAs significantly decline?
Why did the misuse of PTAs significantly decline?
Signup and view all the answers
Flashcards
Reputational Risk
Reputational Risk
The potential loss of public trust and negative perception of an organization due to suspected involvement in money laundering activities.
Liquidity Risk
Liquidity Risk
The risk that a financial organization's ability to meet its short-term financial obligations could be threatened by unexpected withdrawals of funds due to money laundering concerns.
Correspondent Banking Risk
Correspondent Banking Risk
The risk that a financial institution may lose access to essential financial services, such as correspondent banking, because of suspicion of money laundering.
Investigation and Legal Risk
Investigation and Legal Risk
Signup and view all the flashcards
Asset Seizure Risk
Asset Seizure Risk
Signup and view all the flashcards
Loan Loss Risk
Loan Loss Risk
Signup and view all the flashcards
Reduced Stock Value
Reduced Stock Value
Signup and view all the flashcards
Loss of Profitable Business
Loss of Profitable Business
Signup and view all the flashcards
Transaction Monitoring
Transaction Monitoring
Signup and view all the flashcards
Risk-Based Monitoring
Risk-Based Monitoring
Signup and view all the flashcards
Model Performance Calibration
Model Performance Calibration
Signup and view all the flashcards
End-to-End Testing
End-to-End Testing
Signup and view all the flashcards
Senior Manager Accountability
Senior Manager Accountability
Signup and view all the flashcards
Annual Compliance Certification
Annual Compliance Certification
Signup and view all the flashcards
Suspicious Activity Reporting (SAR)
Suspicious Activity Reporting (SAR)
Signup and view all the flashcards
AML/CFT (Anti-Money Laundering / Combating the Financing of Terrorism)
AML/CFT (Anti-Money Laundering / Combating the Financing of Terrorism)
Signup and view all the flashcards
Electronic Funds Transfer
Electronic Funds Transfer
Signup and view all the flashcards
Electronic Funds Transfer System
Electronic Funds Transfer System
Signup and view all the flashcards
Money Laundering with Electronic Transfers
Money Laundering with Electronic Transfers
Signup and view all the flashcards
Layering in Money Laundering
Layering in Money Laundering
Signup and view all the flashcards
Unauthorized Electronic Transfers
Unauthorized Electronic Transfers
Signup and view all the flashcards
Money Laundering Techniques
Money Laundering Techniques
Signup and view all the flashcards
Transaction Monitoring Software
Transaction Monitoring Software
Signup and view all the flashcards
Vulnerabilities in Electronic Transfers
Vulnerabilities in Electronic Transfers
Signup and view all the flashcards
Funds Transfer to Secrecy Haven
Funds Transfer to Secrecy Haven
Signup and view all the flashcards
Large Incoming Transfer
Large Incoming Transfer
Signup and view all the flashcards
Small Incoming Transfers
Small Incoming Transfers
Signup and view all the flashcards
Rapid Transfers Out
Rapid Transfers Out
Signup and view all the flashcards
Unusual Funds Activity
Unusual Funds Activity
Signup and view all the flashcards
Unrelated Payments
Unrelated Payments
Signup and view all the flashcards
Same Person, Multiple Accounts
Same Person, Multiple Accounts
Signup and view all the flashcards
Remote Deposit Capture (RDC)
Remote Deposit Capture (RDC)
Signup and view all the flashcards
Correspondent Banking
Correspondent Banking
Signup and view all the flashcards
Respondent Bank
Respondent Bank
Signup and view all the flashcards
Correspondent Bank
Correspondent Bank
Signup and view all the flashcards
RDC Misuse for Sanctions Violations
RDC Misuse for Sanctions Violations
Signup and view all the flashcards
Fraud Risk with RDC
Fraud Risk with RDC
Signup and view all the flashcards
Anti-Money Laundering (AML) Controls
Anti-Money Laundering (AML) Controls
Signup and view all the flashcards
Integrating RDC into AML Controls
Integrating RDC into AML Controls
Signup and view all the flashcards
Payable-Through Account (PTA)
Payable-Through Account (PTA)
Signup and view all the flashcards
Currency Deposit and Withdrawal Privileges
Currency Deposit and Withdrawal Privileges
Signup and view all the flashcards
Offshore Financial Service Center
Offshore Financial Service Center
Signup and view all the flashcards
Customer Due Diligence (CDD)
Customer Due Diligence (CDD)
Signup and view all the flashcards
PTA Mimicking Branch Operations
PTA Mimicking Branch Operations
Signup and view all the flashcards
Subaccount Holder
Subaccount Holder
Signup and view all the flashcards
Study Notes
Adverse Consequences of Money Laundering
- Reputational Risk: Negative publicity damages an organization's reputation and public trust, leading to loss of clients (borrowers, depositors, investors). This reduces profitable loans and increases portfolio risk, potentially causing depositors to withdraw funds.
- Operational Risk: Inadequate internal processes, personnel, or systems can lead to losses, such as reduced or terminated correspondent banking services, increased costs for these services, and increased borrowing/funding costs.
- Legal Risk: Lawsuits, adverse judgments, unenforceable contracts, fines, penalties, increased expenses, and even organization closure are potential consequences. Legitimate customers can sue over financial crimes, regulators/law enforcement investigations increase costs/penalties, and fraudulent contracts can result. Senior management is accountable for AML/CFT regime misconduct.
- Loss of Profitable Business: Money laundering can directly impact profitability.
- Liquidity Problems: Fund withdrawals can create severe liquidity issues.
- Termination of Correspondent Banking Facilities: Banks can lose correspondent banking relationships due to involvement in money laundering.
- Investigation Costs and Fines: Substantial expenses are incurred during investigations and penalties for violations.
- Asset Seizures: Financial assets can be seized as a result of money laundering activities.
- Loan Losses: Poor-quality loans and increased risk can lead to loan defaults.
- Reduced Stock Value: Financial organizations' stock value can decline significantly in the wake of a money laundering scandal.
Electronic Funds Transfers and Money Laundering
- Electronic Transfers: Trillions of dollars are transferred daily via electronic systems like Fedwire, SWIFT, and CHIPS, making it easier to hide illicit transfers among legitimate transactions.
- Money Laundering Techniques: Money launderers use electronic transfers to hide the origin of funds by moving them between accounts, banks, and jurisdictions (layering). Unauthorized domestic/international transfers (e.g., ACH debits, stolen credit cards), using funds for merchandise resale, and varied transfer amounts are techniques used to avoid detection.
- Detection Challenges: Sophisticated algorithms and software do money laundering detection and alerting, but no system is foolproof.
- Indicators of Money Laundering: Funds transfers to/from high-risk locations without valid business reasons, large incoming transfers with unclear reasons, checks/money orders for multiple incoming small transfers, unexplained/repetitive funds activity, payments without legitimate contract/goods/services, and funds sent/received from the same person to different accounts.
Remote Deposit Capture (RDC) and Money Laundering
- Remote Deposit Capture (RDC): A product offered by banks, allowing customers to scan and electronically deposit checks. Mobile phone images are common. RDC lowers check processing costs.
- Money Laundering Risk: RDC reduces human review and identification of fraud (e.g., altered checks, multiple deposits of same item), making it possible to abuse RDC for money laundering, sanctions violations, and fraud.
- Risk Mitigation: Integration of RDC processing into other controls (monitoring, fraud prevention systems). Ensuring items are reviewed for sequential checks, volume incorporation into transaction monitoring, limits on RDC deposits for customers, offering RDC appropriately, and swift action at fraud detection are essential risk mitigation steps.
Correspondent Banking and Money Laundering
-
Correspondent Banking: One bank acts as an agent for another, often in a foreign country.
-
Payable-Through Accounts (PTA): High-risk accounts used in correspondent banking, allowing subaccount holders direct control over deposited funds; potential for use in money laundering, and sanctions evasion.
-
Risk Factors in PTAs: PTAs with banks in offshore financial service centers with weak oversight, usage where the correspondent bank views the respondent bank as the sole client without applying CDD policies to respondent bank clients, PTA arrangements for currency deposit/withdrawal privileges, and usage with subsidiaries/representative offices to offer similar services to a branch.
-
Risk Mitigation: Tightened controls within correspondent banking to limit PTA usage, including strict processes, procedures, due diligence requirements and associated disclosures.
Studying That Suits You
Use AI to generate personalized quizzes and flashcards to suit your learning preferences.
Related Documents
Description
This quiz explores the various adverse consequences of money laundering on organizations. It covers issues such as reputational, operational, legal risks, and the potential loss of profitable business. Understanding these implications is crucial for effective risk management and compliance in financial institutions.