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Questions and Answers
Which international body identifies countries with weak AML/CFT regimes?
Which international body identifies countries with weak AML/CFT regimes?
What does the acronym HIDTA stand for in the context of US financial crime evaluations?
What does the acronym HIDTA stand for in the context of US financial crime evaluations?
In AML/CFT programs, which of the following is NOT typically utilized as an internal control?
In AML/CFT programs, which of the following is NOT typically utilized as an internal control?
What is the purpose of internal technology or tools within a financial organization's AML/CFT program?
What is the purpose of internal technology or tools within a financial organization's AML/CFT program?
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Besides policies and procedures, what is another key component of AML/CFT programs?
Besides policies and procedures, what is another key component of AML/CFT programs?
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Which of the following is indicative of suspicious funds activity?
Which of the following is indicative of suspicious funds activity?
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What risk factor is most associated with remote deposit capture (RDC)?
What risk factor is most associated with remote deposit capture (RDC)?
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Which of the following scenarios associated with payable through accounts (PTAs) poses a high money laundering risk?
Which of the following scenarios associated with payable through accounts (PTAs) poses a high money laundering risk?
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What is a key characteristic of suspicious transfers involving multiple accounts?
What is a key characteristic of suspicious transfers involving multiple accounts?
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Which of these scenarios would be most likely to raise concerns about money laundering?
Which of these scenarios would be most likely to raise concerns about money laundering?
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Why are payable through accounts (PTAs) with foreign institutions in offshore centers considered high-risk for money laundering?
Why are payable through accounts (PTAs) with foreign institutions in offshore centers considered high-risk for money laundering?
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What kind of accounts could indicate a risk of money-laundering due to lack of CDD?
What kind of accounts could indicate a risk of money-laundering due to lack of CDD?
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Which is the most important reason why RDC increases the risk of fraud?
Which is the most important reason why RDC increases the risk of fraud?
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What are the three key measures that a due diligence program for correspondent banks, as mandated by Section 312 of the USA PATRIOT Act, must address?
What are the three key measures that a due diligence program for correspondent banks, as mandated by Section 312 of the USA PATRIOT Act, must address?
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According to FATF, what is the threshold amount that should generally trigger AML scrutiny for occasional customers?
According to FATF, what is the threshold amount that should generally trigger AML scrutiny for occasional customers?
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What is the FATF-designated threshold for casinos, including Internet casinos, for AML scrutiny?
What is the FATF-designated threshold for casinos, including Internet casinos, for AML scrutiny?
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When should dealers in precious metals, according to FATF, be subject to AML scrutiny due to a cash transaction?
When should dealers in precious metals, according to FATF, be subject to AML scrutiny due to a cash transaction?
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What does FATF recommend regarding the reporting of suspicious financial activity?
What does FATF recommend regarding the reporting of suspicious financial activity?
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According to FATF, what kind of protection should financial organizations and their employees have when reporting suspicious activities?
According to FATF, what kind of protection should financial organizations and their employees have when reporting suspicious activities?
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Which statement best describes FATF recommendations on disclosing that a suspicious activity report (SAR) has been filed?
Which statement best describes FATF recommendations on disclosing that a suspicious activity report (SAR) has been filed?
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According to the provided information, which party would be primarily responsible to define what is considered "suspicous activity" in a financial organization?
According to the provided information, which party would be primarily responsible to define what is considered "suspicous activity" in a financial organization?
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What primary factor dictates the necessary sophistication of an organization's compliance function?
What primary factor dictates the necessary sophistication of an organization's compliance function?
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Why do different organizations require distinct compliance structures?
Why do different organizations require distinct compliance structures?
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Which of these skills is most critical to the effectiveness of an AML/CFT compliance officer?
Which of these skills is most critical to the effectiveness of an AML/CFT compliance officer?
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Why is the ability of a compliance officer to articulate information to senior and executive management so crucial?
Why is the ability of a compliance officer to articulate information to senior and executive management so crucial?
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According to the provided material, which aspect of an organization is NOT a key factor in establishing the sophistication of its compliance function?
According to the provided material, which aspect of an organization is NOT a key factor in establishing the sophistication of its compliance function?
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What is the main reason why a generic compliance approach should not be used?
What is the main reason why a generic compliance approach should not be used?
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Which of the following is not specifically mentioned in this document as a vital communication skill for a compliance officer?
Which of the following is not specifically mentioned in this document as a vital communication skill for a compliance officer?
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A compliance officer should be able to communicate effectively with all levels of an organization, which of the following was specifically named in the content?
A compliance officer should be able to communicate effectively with all levels of an organization, which of the following was specifically named in the content?
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According to FATF Recommendation 10, when should a bank verify a customer's identity?
According to FATF Recommendation 10, when should a bank verify a customer's identity?
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What is the most effective way for a global financial organization to ensure consistent customer due diligence across all its operations?
What is the most effective way for a global financial organization to ensure consistent customer due diligence across all its operations?
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What is the full name of the sanctions list maintained by the Office of Foreign Assets Control (OFAC)?
What is the full name of the sanctions list maintained by the Office of Foreign Assets Control (OFAC)?
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Which action would be non-compliant with the spirit of the content provided?
Which action would be non-compliant with the spirit of the content provided?
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How often should financial organization's policies be communicated to staff?
How often should financial organization's policies be communicated to staff?
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What is the primary purpose of a financial organization's global compliance policy?
What is the primary purpose of a financial organization's global compliance policy?
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According to the content, what is required to ensure adherence to customer due diligence policies?
According to the content, what is required to ensure adherence to customer due diligence policies?
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What should a bank do if it is unable to verify the identity of a customer?
What should a bank do if it is unable to verify the identity of a customer?
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What is the primary characteristic of a bearer check?
What is the primary characteristic of a bearer check?
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Under what circumstances is a financial organization typically obligated to verify the identity of the presenter of a bearer check?
Under what circumstances is a financial organization typically obligated to verify the identity of the presenter of a bearer check?
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Which of the below best describes the role of a Financial Intelligence Unit (FIU)?
Which of the below best describes the role of a Financial Intelligence Unit (FIU)?
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What type of report does an FIU primarily receive?
What type of report does an FIU primarily receive?
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What is the purpose of FIUs disseminating intelligence to foreign entities?
What is the purpose of FIUs disseminating intelligence to foreign entities?
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Which of the following is NOT a primary focus of the Financial Action Task Force (FATF)?
Which of the following is NOT a primary focus of the Financial Action Task Force (FATF)?
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What is a key task of the FATF regarding its member states?
What is a key task of the FATF regarding its member states?
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Which of the following best describes the scope of FATF's objectives?
Which of the following best describes the scope of FATF's objectives?
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Flashcards
Remote Deposit Capture (RDC)
Remote Deposit Capture (RDC)
A banking feature allowing customers to deposit checks electronically by scanning them and transmitting the images to their bank.
RDC Fraud Risk
RDC Fraud Risk
The risk that RDC technology can mask fraudulent activity due to reduced human oversight.
Payable Through Account (PTA)
Payable Through Account (PTA)
A banking arrangement where a bank (respondent) uses another bank's (correspondent) account to facilitate transactions on behalf of its clients.
Money Laundering Risks with PTAs
Money Laundering Risks with PTAs
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Suspicious Foreign Client Activity
Suspicious Foreign Client Activity
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Suspicious Check and Money Order Activity
Suspicious Check and Money Order Activity
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Unexplained or Unusual Funds Activity
Unexplained or Unusual Funds Activity
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Funds Transfer Activity Between Different Accounts
Funds Transfer Activity Between Different Accounts
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What is a bearer check?
What is a bearer check?
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What are FIUs?
What are FIUs?
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What are the three main tasks of the FATF?
What are the three main tasks of the FATF?
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Internal Controls for AML/CFT
Internal Controls for AML/CFT
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Examples of Internal Controls
Examples of Internal Controls
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Compliance Department's Role
Compliance Department's Role
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FATF's Role in AML
FATF's Role in AML
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Higher-Risk Areas for AML
Higher-Risk Areas for AML
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When should customer identity be verified?
When should customer identity be verified?
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How should a global financial organization implement customer due diligence?
How should a global financial organization implement customer due diligence?
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What is the OFAC sanctions list called?
What is the OFAC sanctions list called?
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What are the three components required by the USA PATRIOT Act for a Correspondent Bank due diligence program?
What are the three components required by the USA PATRIOT Act for a Correspondent Bank due diligence program?
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What are the FATF-designated thresholds that trigger AML scrutiny?
What are the FATF-designated thresholds that trigger AML scrutiny?
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What are the FATF’s Recommendations regarding suspicious activity reporting?
What are the FATF’s Recommendations regarding suspicious activity reporting?
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What are the main measures required for a Correspondent Bank due diligence program according to the USA PATRIOT Act?
What are the main measures required for a Correspondent Bank due diligence program according to the USA PATRIOT Act?
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What is a Correspondent Bank?
What is a Correspondent Bank?
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What is the FATF?
What is the FATF?
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What is Enhanced Due Diligence (EDD)?
What is Enhanced Due Diligence (EDD)?
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What is money laundering?
What is money laundering?
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What factors determine the sophistication of an organization's compliance function?
What factors determine the sophistication of an organization's compliance function?
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Why is good communication important for an organization's AML/CFT compliance officer?
Why is good communication important for an organization's AML/CFT compliance officer?
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How does a risk assessment impact an organization's compliance function?
How does a risk assessment impact an organization's compliance function?
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Is there a one-size-fits-all compliance program?
Is there a one-size-fits-all compliance program?
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Why is effective communication important for compliance management?
Why is effective communication important for compliance management?
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Why are risks important for compliance?
Why are risks important for compliance?
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What kinds of communication skills does a compliance officer need?
What kinds of communication skills does a compliance officer need?
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How do you ensure appropriate compliance program effectiveness?
How do you ensure appropriate compliance program effectiveness?
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Study Notes
Certified Anti-Money Laundering Specialist Flashcards
- ACAMS is an organization certifying anti-money laundering specialists
- Flashcards are a learning tool for the Certified Anti-Money Laundering Specialist program
- Instructions for assembling the flashcards are included (folding, cutting)
Money Laundering Stages
- Stage 1 (Placement): Criminal proceeds are disguised, for example by blending funds, using casino credit, or through currency transactions
- Stage 2 (Layering): Disguising the source of the funds by electronically moving them between countries, or by exchanging cash into other financial instruments, or by reselling goods.
- Stage 3 (Integration): The funds are reintegrated into the legitimate economy, often by purchasing high-value assets like property, artwork, jewelry, or luxury vehicles.
Yates Memo
- The Yates Memo reminds prosecutors that investigations into corporate misconduct should also focus on individuals, and corporate resolutions should not shield individuals from legal responsibility.
Electronic Transfers and Indicators of Money Laundering
- Examples include transfers to or from high-risk locations, large funds transfers with little explanation, repetitive transfers without a clear purpose, and unusual patterns in fund transfers.
Remote Deposit Capture (RDC)
- RDC allows customers to scan and transmit a check electronically for deposit.
- A risk associated with RDC is that it can make it harder to identify potential fraud, for example, manipulated checks deposited in multiple transactions
Payable Through Account (PTA) Risks
- Using PTAs with offshore institutions, or with correspondent banks failing to meet Know Your Customer (KYC) policies, may present significant risks.
- Using PTAs with banks in areas with weak bank supervision and licensing laws, are a high-risk
Concentration Accounts and Risks
- Money laundering risks with concentration accounts arise from the separation of customer identification information from financial transactions.
- This separation results in lost audit trails and opportunities for misuse or improper administration.
Politically Exposed Persons (PEPs)
- A politically exposed person (PEP) is a person who holds or has held a prominent public function domestically or by a foreign country or international organization
- Relatives and close associates of PEPs are also considered PEPs
Structuring
- Structuring is a money laundering technique that involves splitting large sums of cash into smaller deposits to avoid triggering reporting requirements.
- This is done to avoid detection by dividing transactions into smaller amounts that don’t exceed reporting thresholds.
Credit Cards in Money Laundering
- Credit cards are commonly used in the layering and integration stages of money laundering, often involving overpaying a balance and requesting a refund.
- Funds are then placed in accounts at offshore banks, before being accessed by credit and debit cards linked to said bank account.
Third Party Payment Processors (TPPP) Risks
- Multiple financial relationships allow money laundering to occur through the TPPP and hide the suspicious activity.
- Money laundering occurs when funds are sent directly to a financial institution in a foreign jurisdiction through an international ACH payment.
- High return rates from unauthorized transactions are a risk
Money Services Businesses (MSBs) for Money Laundering
- MSBs involved in money laundering can use money remitters and currency exchanges that provide access to criminal organizations.
- This process can launder dollars by exchanging them to local currency at a destination
Securities Industry Exposure to Money Laundering
- International nature, fast transactions, ease of creating cash from investments, high commissions, and use of nominees or trustees.
Casinos and Gambling-Associated Red Flags
- Casino credit to make cash transactions less obvious,
- Purchasing chips with funds that were made through illegal activities,
- Using casinos for banking-like financial services,
- Unusual transaction patterns
Gold and Money Laundering
- Gold's compact and easily transportable nature makes it vulnerable to money laundering.
Travel Agencies and Money Laundering
- Purchasing expensive tickets for others, structuring wire transfers in smaller amounts, or creating falsified tour documentation
Attorneys, Notaries, Accountants and Auditors
- Gatekeeping functions include creating, managing, and executing complex corporate dealings, performing financial transactions, giving financial advice and tax advice, creating litigations, setting up and managing charities
Real Estate and Money Laundering
- Real estate purchases to disguise the source of money or launder funds through renovation or improvement costs, often involving large sums of cash and property sales.
Trade-based Money Laundering Techniques
- Overinvoicing/Underinvoicing
- Overshipping/Short-shipping
- Ghost Shipping
- Multiple Invoicing
- Black Market Trades
Black Market Peso Exchange (BMPE)
- BMPE involves exchanging US dollars for pesos in unregulated transactions, often used to launder money.
Prepaid Cards and Money Laundering
- Anonymity in funding, high-value access limits, lack of surveillance or regulation, easy access to cash at ATMs globally, including from offshore issuers.
- This allows bulk cash smuggling to be a convenient tool for facilitating money laundering
E-Money Institutions and Money Laundering
- Robust oversight of outsourced functions, limits on storage values and transactions, monitoring systems that detect money laundering patterns
- Cooperation with merchants who accept e-money can help
- Geographical restrictions on the use and function of e-money products.
Willful Blindness (Money Laundering)
- Willful blindness is the “deliberate avoidance of knowledge of the facts” or “purposeful indifference.”
Correspondent Banking Risks
- Limited information about due diligence practices of other banks.
- Limited knowledge on the degree of supervision.
- Correspondents may be unaware of correspondent bank subsidiaries operations.
Concentration Accounts
- Concentration accounts are accounts used by banks for processing and settling multiple customer transactions on the same day.
Microstructuring
- Dividing large amounts of illicit cash into smaller deposits
High-Risk Insurance Products
- Products that easily absorb funds into policies (such as high-limit or underlying investment options).
- Products that can conceal cash deposits due to high upper limits
Art and Antique Dealers and Auctioneers
- Compliance with regulations like avoiding large cash transactions, using appropriate registration and identification methods, and reporting suspicious activity are necessary measures
- Verification of seller identities and addresses, refusal to handle suspicious items, and reporting suspicious activity to the Art Loss Register are ways to minimise risk.
Investment and Commodity Advising Industry Susceptibility to Money Laundering
- Withdrawal of assets into unrelated accounts in high-risk jurisdictions, multiple additions/withdrawals from accounts, clients requesting anonymity.
TCSP Services
- Formation of legal persons
- Acting as company director or secretary
- Providing business addresses and registered offices
- Acting as trust or nominee shareholder
Shell Companies and Money Laundering
- Converting illegal funds into assets that appear legitimate.
- Creating the appearance of a legitimate source of funds from a legitimate source.
- Facilitating transactions that can be used for money laundering
- Concealing the ownership of funds
Trust Accounts and Money Laundering
- Converting illicit cash into less risky assets.
- Disguise criminal ownership of funds.
- Provide a link between methods of money laundering such as real estate or nominees, and transfers of criminal proceeds.
Bearer Instruments and Money Laundering
- Bearer instruments facilitate money laundering due to the lack of ownership registration and easier transfer/exchange processes
Terrorist Financing vs. Money Laundering
- Terrorist financing uses funds for illegal political purposes but may not originate from illegal proceeds, unlike money laundering which always involves illegal activity
Financial Institution Risk for Terrorist Financing
- Public perception (reputation)
- Operational risks
- Legal risks
- Risks relating to concentration
Private Banking Vulnerability to Money Laundering
- High profit potential
- Intense competition
- High level of confidentiality that creates trust
- Commission structures incentivize secretive interactions
- Culture of discretion and secrecy
- Importance of relationship managers as client advocates
Money Services Businesses (MSBs) and Customer Due Diligence (CDD)
- Confirming that the MSB has a sufficient AML/CFT plan which includes procedures, training and monitoring.
Free Look Period in the Insurance Industry
- A period of time after the policy is signed and the premium paid, where investors can back out without penalty.
Lawyer as Trustee and Money Laundering
- Using trust accounts to move illegal funds
- The trustee can conduct transactions and manage the client's affairs
Vehicles and Money Laundering
- Structuring cash deposits below reporting thresholds to avoid triggering obligations .
- Trade in multiple new or used vehicles to create layers of transactions .
- Accepting payments from various third parties in smaller amounts
Money Laundering and Macroeconomic Consequences
- Undermining the legitimate private sector.
- Weakening financial organizations .
- Dampening effect on foreign investments
- Loss of control of or errors in the economic policy decisions, leading to economic instability.
Bearer Checks
- Checks that are made out to the holder and not to an identified payee.
Financial Intelligence Units (FIUs)
- Organizations that analyze financial intelligence to identify and combat money laundering
Tasks of Financial Action Task Force (FATF)
- Spreading the anti-money laundering message
- Monitoring implementation of FATF recommendations
- Reviewing money laundering trends and countermeasures
Wolfsberg Group and FATF Requirements for High-Risk Customers
- Obtain the approval of senior management before opening or continuing a business relationship with high-risk customers.
- First payment to be channeled via a correspondent bank in the customer’s name.
International Standards and FATF Recommendations
- AML/CFT policies and coordination
- Money laundering and confiscation
- Terrorist financing and financing of proliferation
- Financial and non-financial institution prevention
- Transparency and beneficial ownership
- Powers and responsibilities
Risk-Based Approach for Money Laundering
- Financial organizations should start by identifying, assessing, and understanding the money laundering and terrorist financing risks they face.
- They should then take appropriate preventative measures according to the level of risk.
FATF Black and Grey Lists
- "Black listed" jurisdictions have severe AML deficiencies and are under intensified monitoring by the FATF
- "Grey listed" jurisdictions are actively cooperating with FATF to improve their AML programs
EU Directives and Numbered Accounts
- Numbered accounts are not prohibited by the Basel Committee but must comply with KYC checks just as any other customer account
EU Directives and Predicate Offenses
- Drug trafficking was the only predicate offense for money laundering initially
Revised Threshold for Reporting Suspicious Transactions Under 4th EU Directive
- €10,000
FATF-Style Regional Bodies
- Groups that support AML efforts in their regions
Permanent International Organization on Money Laundering
- Organization of American States (OAS) with the Inter-American Drug Abuse Control Commission
Egmont Group
- A forum for financial intelligence units to exchange information and improve cooperation to combat money laundering
Financial Action Task Force (FATF)
- An international organization that develops and promotes policies to combat money laundering
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Description
Test your knowledge on Anti-Money Laundering (AML) and Counter Financing of Terrorism (CFT) concepts. This quiz covers various aspects of AML/CFT programs, including internal controls, risk factors, and suspicious activity indicators. Enhance your understanding of financial crime evaluations and regulatory frameworks.