E-Money and Money Laundering Mitigation Quiz

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Questions and Answers

Which control is LEAST likely to be implemented by e-money institutions to mitigate money laundering?

  • Using geolocation data to monitor for unusual activity
  • Setting limits on transaction values and turnover
  • Allowing unlimited access to multiple purses, accounts, and cards (correct)
  • Implementing systems to detect patterns indicative of money laundering

What is a primary function of transaction monitoring systems in e-money institutions?

  • To facilitate faster transactions and payments for users.
  • To maintain records of user location and device history.
  • To identify customers with multiple accounts for marketing purposes.
  • To detect patterns and deviations indicative of money laundering. (correct)

Cooperation with which of the following is most beneficial for e-money institutions in mitigating money laundering?

  • Competitors in the e-money market.
  • Social media influencers.
  • The Central Bank only.
  • Merchants who accept e-money, and the central bank. (correct)

What is the primary role of an 'Administrator' within the virtual currency (VC) ecosystem?

<p>To issue VC for the users and redeem it. (A)</p> Signup and view all the answers

Which of the following best describes the role of an 'Exchanger' in the VC ecosystem?

<p>They act as an intermediary for exchanging VC for real currency. (C)</p> Signup and view all the answers

A 'User' in the virtual currency ecosystem is best defined as an individual who:

<p>Obtains virtual currency to purchase goods or services. (A)</p> Signup and view all the answers

Why is it important for e-money institutions to implement geographic restrictions on their e-money products?

<p>To restrict the use of e-money to specific regions, potentially limiting money laundering risks. (C)</p> Signup and view all the answers

Which is NOT a method used by payment service providers to identify suspicious customer activity?

<p>Checking user's email provider. (B)</p> Signup and view all the answers

According to the Basel Committee's January 2014 guidelines, which of the following is NOT a control banks should implement to manage risks related to money laundering and terrorist financing?

<p>Implementation of advanced AI in fraud detection systems. (C)</p> Signup and view all the answers

What are the four key elements of a KYC program according to the Basel Committee's KYC guidance?

<p>Customer identification, risk management, customer acceptance policy, and ongoing monitoring. (D)</p> Signup and view all the answers

According to the Basel Committee’s October 2004 paper, “Consolidated KYC Risk Management,” which of the following should be addressed in a global approach to KYC?

<p>Risk management, customer acceptance and identification policies, and ongoing monitoring of higher-risk accounts. (C)</p> Signup and view all the answers

What is a key expansion introduced by the European Union's regulations regarding the definition of financial institution, according to the provided context?

<p>It includes certain insurance intermediaries. (A)</p> Signup and view all the answers

What specific category is included under increased scrutiny?

<p>Trust and company service providers. (D)</p> Signup and view all the answers

What cash transaction threshold for dealers in goods triggers expanded scrutiny under EU regulations?

<p>15,000 euros. (B)</p> Signup and view all the answers

How did the European Union regulations impact the scope of financial institutions?

<p>The scope expanded to include certain insurance intermediaries. (A)</p> Signup and view all the answers

The Basel Committee emphasizes the importance of ongoing monitoring. What is one area, in terms of accounts, that is specifically noted for increased scrutiny?

<p>Higher risk accounts. (A)</p> Signup and view all the answers

What is the primary distinction between countries on the FATF 'black list' and 'grey list'?

<p>Black listed countries have not cooperated with FATF, while grey listed are actively engaging to address deficiencies. (B)</p> Signup and view all the answers

What does it signify when a jurisdiction is placed under 'increased monitoring' by the FATF?

<p>The jurisdiction has committed to resolving identified strategic AML/CFT deficiencies within an agreed timeline. (A)</p> Signup and view all the answers

Which of the following is a qualitative indicator that FATF takes under consideration when considering member applications?

<p>The impact the jurisdiction has on the global financial system. (C)</p> Signup and view all the answers

What is the FATF's stance on numbered accounts?

<p>They are acceptable, provided they adhere to the same KYC procedures as other accounts. (B)</p> Signup and view all the answers

In terms of AML/CFT, what does 'strategic deficiency' refer to?

<p>Significant shortcomings in a jurisdiction's framework to counter money laundering, terrorist financing, and proliferation financing. (D)</p> Signup and view all the answers

Which of these are a reason why a place becomes a member if the FATF?

<p>To enhance the FATF's geographic balance. (C)</p> Signup and view all the answers

What is a principal objective for a jurisdiction when under increased monitoring from FATF?

<p>To quickly resolve the identified shortcomings in their AML/CFT framework. (B)</p> Signup and view all the answers

What is a characteristic of jurisdictions on the FATF 'grey list'?

<p>They are actively working with FATF to fix their deficiencies. (A)</p> Signup and view all the answers

Which of the following is NOT a transaction history factor that would lead a financial organization to modify a customer's risk rating?

<p>The customer has a long history of positive transactions with the organization. (A)</p> Signup and view all the answers

Which of the following is NOT considered a typical indicator of unusual activity?

<p>The customer has a positive credit history. (B)</p> Signup and view all the answers

Which of the following is NOT a source for identifying high-risk countries?

<p>The World Bank's ‘Doing Business’ report. (D)</p> Signup and view all the answers

Which of the following is NOT a type of risk factor associated with delivery channels?

<p>Large deposits made by a single customer over a short period. (D)</p> Signup and view all the answers

When would a financial institution typically file a Suspicious Activity Report (SAR)?

<p>When a customer has engaged in transactions that suggest potential money laundering or other financial crimes. (C)</p> Signup and view all the answers

What is the purpose of the FATF in relation to jurisdictions?

<p>To evaluate and identify jurisdictions with weak AML/CFT regimes (D)</p> Signup and view all the answers

Which geographical areas are considered higher-risk in the context of AML/CFT evaluations in the US?

<p>High-intensity drug trafficking areas and high-intensity financial crime areas (D)</p> Signup and view all the answers

What role do automated review systems play in AML/CFT programs?

<p>They assist in the identification of potential outliers and deviations (C)</p> Signup and view all the answers

Which of the following is NOT a component of internal controls in AML/CFT programs?

<p>Customer satisfaction surveys (A)</p> Signup and view all the answers

What is a key function of the compliance department in AML/CFT programs?

<p>Identifying potential outliers and deviations from normal policy (A)</p> Signup and view all the answers

What is the primary reason for conducting enhanced due diligence (EDD) on a customer?

<p>When the risk of money laundering or terrorist financing is higher (D)</p> Signup and view all the answers

Which of the following is NOT considered a customer risk factor for EDD?

<p>Customer’s favorite color (A)</p> Signup and view all the answers

What type of information is crucial when identifying individuals with control over an account during EDD?

<p>Identifying information, such as signatories or guarantors (C)</p> Signup and view all the answers

Which aspect is an example of country or geographic risk factors that may necessitate EDD?

<p>The crime rate in the customer's country (A)</p> Signup and view all the answers

When assessing business operations for a high-risk customer, which information is NOT typically included?

<p>The customer's branding strategy (B)</p> Signup and view all the answers

What type of transactions could indicate a higher risk for a customer during EDD?

<p>International transactions (D)</p> Signup and view all the answers

Which of the following information is NOT relevant to the customer's primary trade area?

<p>Anticipated volume of international sales (D)</p> Signup and view all the answers

What information is essential to explain changes in account activity during EDD?

<p>Clarifications of activities influencing the financial stability (B)</p> Signup and view all the answers

Flashcards

User (VC Ecosystem)

A person who uses virtual currency (VC) to buy goods or services.

Exchanger (VC Ecosystem)

A business that exchanges VC for real currency, funds, or other virtual currency.

Administrator (VC Ecosystem)

A business that issues VC and is responsible for redeeming it.

Storage Limits (e-money protection)

Restrictions placed on storing large amounts of virtual currency.

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Transaction Monitoring Systems (e-money protection)

Monitoring systems that identify unusual activity suggestive of money laundering.

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Multiple Account Identification (e-money protection)

Identifying individuals with multiple virtual currency accounts or cards.

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Geolocation and Device Data (e-money protection)

Using location data, device information, and IP addresses to verify user activity.

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Merchant Cooperation (e-money protection)

Collaborating with businesses that accept e-money to prevent money laundering.

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FATF's "Black List"

A list of countries or jurisdictions identified by the Financial Action Task Force on Money Laundering (FATF) as having significant deficiencies in their anti-money laundering and counter-terrorist financing (AML/CFT) regimes.

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FATF's "Grey List"

A list of countries or jurisdictions identified by the FATF as having strategic deficiencies in their AML/CFT regimes but are actively working to improve them.

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Increased Monitoring by FATF

Countries or jurisdictions on the "Grey List" are required to take specific actions to address the identified deficiencies within a set timeframe.

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Strategic Importance for FATF Membership

The FATF considers a country or jurisdiction strategically important based on its economic size (like GDP), population, and its impact on the global financial system.

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Additional Considerations for FATF Membership

The FATF considers the level of adherence to financial sector standards and whether the country can contribute to enhancing the geographic balance of the FATF.

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Numbered Accounts and KYC Procedures

Numbered accounts should not be prohibited, but they should be subjected to the same rigorous Know Your Customer (KYC) procedures as other customer accounts.

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What controls should banks implement according to Basel Committee's guidelines on money laundering and terrorism financing?

Banks should implement controls related to risk analysis and governance, three lines of defense, customer due diligence and acceptance, transaction monitoring systems and ongoing monitoring, management of information, and reporting of suspicious transactions and asset freezing.

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What are the four key elements of a KYC program according to Basel Committee's KYC guidance?

The four key elements of a KYC program are customer identification, risk management, customer acceptance policy, and ongoing monitoring.

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What elements should be addressed in a global approach to KYC?

The elements of a global approach to KYC should include risk management, customer acceptance and identification policies, and ongoing monitoring of higher-risk accounts.

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How does the EU's Fourth AML Directive expand its scope?

The scope of the EU's Fourth Anti-Money Laundering Directive includes a broader definition of financial institutions, such as trust and company service providers, dealers trading in goods who trade in cash over 15,000 euros, and certain insurance intermediaries.

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What are 'Risk analysis and governance'?

These are the various measures taken to identify and assess the risks associated with money laundering and terrorism financing across all areas of a bank's operations.

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What are 'Three lines of defense'?

This concept emphasizes a layered approach with different departments working together to manage risk, with independent oversight.

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What is 'Customer due diligence and acceptance'?

This process aims to understand the customer's identity, financial activities, and potential risks.

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What are 'Transaction monitoring systems and ongoing monitoring'?

These systems and processes are used to monitor transactions for suspicious patterns or activities that could indicate money laundering or terrorism financing.

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How does FATF and the US evaluate AML/CFT regimes?

FATF identifies countries or jurisdictions with weak AML/CFT regimes and issues country-specific reports, while the US evaluates certain domestic jurisdictions based on their location in high-risk areas like HIDTAs and HIFCAs.

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What are some examples of internal controls in AML/CFT programs?

Internal controls are vital for AML/CFT programs; they include management reports, automated review systems, multiple reviewers, and technology that helps identify potential outliers and deviations.

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What are examples of internal controls in AML/CFT programs?

Management reports, automated review systems, and multiple reviewers are internal controls used to monitor AML/CFT programs.

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How does technology help with AML/CFT programs?

Technology plays a crucial role in effective AML/CFT programs by enabling monitoring, analysis, and identification of potential financial crime.

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What is the role of the alert compliance department?

The alert compliance department in a financial organization is responsible for identifying outlier activity that may require further review.

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Customer Risk Rating Updates

When a bank establishes a relationship with a customer, it should regularly assess the risk they pose. As the relationship evolves, the bank should review and update the customer's risk rating. Factors like changes in business activities, financial status, or geographic location can influence this evaluation.

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High-Risk Transaction Channels

Transactions involving private banking, anonymous transactions, and payments from unidentified individuals are considered high-risk as they increase the potential for money laundering or terrorist financing.

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Unusual Activity Red Flags

Unusual financial activities that trigger alerts or investigations, such as suspicious activity reports (SARs), law enforcement inquiries, violations of economic sanctions, or abnormal transaction volumes, are red flags for potential financial crimes.

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High-Risk Country Identification

High-risk countries are those identified as having weak anti-money laundering (AML) controls, a high level of corruption, or known connections to terrorism. Sources like Transparency International's Corruption Perceptions Index and the US State Department's International Narcotics Control Strategy Report can be used to identify these countries.

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High-Risk Countries

Countries with weak AML regulations, high levels of corruption, and known connections to terrorist activities are considered high risk because they offer opportunities for money laundering and terrorist financing.

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When should EDD be done?

EDD is required when there's a higher risk of money laundering or terrorist financing. It involves analyzing specific factors like customer behavior, geographic location, and transaction details.

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What are customer risk factors?

Customer risk factors include analyzing the customer's source of funds, occupation, and financial history. This helps assess their likelihood of engaging in illicit activities.

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What are country or geographic risk factors?

Country or geographic risk factors assess the overall risk associated with a specific country or region based on its regulatory environment, political stability, and corruption levels. This helps organizations understand potential money laundering threats.

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What are product, service, transaction, and delivery channel risk factors?

Product, service, transaction, and delivery channel risks focus on analyzing the specific products or services offered, the types of transactions involved, and the channels used for transactions. This helps identify potential loopholes for financial crime.

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What information is gathered during EDD?

Information obtained during EDD can include details about the source of funds, the customer's occupation, and their financial statements. This information helps assess the customer's financial profile and uncover any inconsistencies.

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Why is it important to explain changes in account activity?

Explaining changes in account activity helps understand the customer's financial behavior and identify any unusual patterns that might indicate money laundering. This involves analyzing transactions over time.

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Why is EDD important?

EDD is a crucial part of AML/CFT compliance. It helps identify and mitigate money laundering risks by collecting and analyzing relevant information about customers and their transactions.

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Describe the importance of EDD in AML/CFT.

EDD is a multi-faceted approach that involves analyzing various factors related to customers, transactions, and the overall operating environment. Its effectiveness hinges on a comprehensive understanding of potential risks and a robust system for gathering and analyzing relevant data.

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Study Notes

Certified Anti-Money Laundering Specialist Flashcards

  • ACAMS provides Certified Anti-Money Laundering Specialist flashcards for study.
  • Flashcards are designed for self-study and learning.
  • Instructions on how to assemble the flashcards are included.

Money Laundering Stages

  • Stage 1 (Placement): Criminal proceeds are disguised through transactions like cash deposits, currency exchange, and loans.
  • Stage 2 (Layering): Funds are moved through complex transactions and financial instruments to conceal their source. This includes electronic transfers, converting cash, investing in legitimate businesses, and using shell companies.
  • Stage 3 (Integration): Illicit money is reintegrated into the legitimate economy in the form of luxury items, real estate, or investments, obscuring its illegal origin.

Key Terms

  • Politically Exposed Person (PEP): A person holding or having held a prominent public office domestically or internationally. Their associates are also considered PEPs.
  • Structuring: Dividing large cash sums into smaller amounts to avoid currency transaction reporting requirements.
  • Money Laundering: The process of disguising the source of illicit funds to make them appear legitimate.
  • Remote Deposit Capture (RDC): A bank product that allows customers to scan checks electronically and transmit them for deposit.
  • Payable Through Account (PTA): An account used to facilitate transactions for foreign entities or other parties, thus potentially increasing money laundering risks.
  • Concentration Account: An internal account used in financial institutions to consolidate multiple transactions, increasing the risk for money laundering if not properly monitored.

Additional Information

  • Yates Memo: Prosecutors should focus on individuals involved in corporate misconduct, even if the case is settled on the corporate level. Individual perpetrators cannot gain protection from criminal or civil liabilities.
  • Money Laundering Risks in the Securities Industry: The industry's inherent nature (international transactions, ease of converting assets, and its use as a nominee), and lack of direct customer oversight makes it vulnerable to money laundering.
  • Money Laundering Risks in Money Services Businesses (MSBs): The highly transactional, cash-intensive nature of these businesses can make them susceptible to money laundering, as criminals can easily use them to move money between jurisdictions.
  • Money Laundering Risks in Third-Party Payment Processors (TPPPs): Multiple financial organization relationships, suspicious activity of the customer/s, and high return rates from unauthorized transactions.
  • Money Laundering Risks in Real Estate: Easy to hide ownership and value can be increased through renovations creating relatively stable reliable investment, making it attractive for money laundering.
  • Money Laundering and Casinos/Gambling: Casino credit, chip transactions, loans; financial services, unusual gaming activity.
  • Money Laundering in the Investment Industry: Multiple transfers to accounts in offshore accounts; investments in assets that will make it appear as normal.

Other Risks

  • Bearer Checks: Checks payable to whoever holds them, avoiding identification requirements.
  • Black Market Peso Exchange (BMPE): A scheme for laundering money using peso brokers to convert funds illegally gained in the US into legitimate currency in another country.
  • Prepaid Bank Cards: Vulnerable to money laundering due to anonymity and lack of customer oversight.

Reporting and Compliance

  • Financial Intelligence Units (FIUs): Agencies receiving and analyzing suspicious transaction reports to combat money laundering.
  • Indicators of Money Laundering: Unusual transaction patterns, frequent transfers to offshore accounts, unusual volumes of cash transactions, unexplained transactions.

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