Money Laundering and Terrorist Financing Risks

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Questions and Answers

What is one potential consequence of reputational risk for a financial organization?

  • Increase in profitable loans
  • Reduction in funding costs
  • Loss of public confidence (correct)
  • Enhanced growth in deposits

Which of the following is classified as an operational risk?

  • Increased borrowing costs (correct)
  • Loss of market value
  • Fraudulent activities by customers
  • Asset seizures

What legal risk might a financial organization face due to money laundering?

  • Fines and penalties (correct)
  • Increased customer trust
  • Broadened customer base
  • Higher stock prices

What is one potential operational risk associated with losing correspondent banking services?

<p>Higher transaction fees (C)</p> Signup and view all the answers

Which consequence is directly linked to the reputational risk of an organization?

<p>Withdrawal of deposits (A)</p> Signup and view all the answers

What adverse consequence could lead to liquidity problems for a financial organization?

<p>Investigation costs (D)</p> Signup and view all the answers

Which drawback is associated with asset seizures as a result of money laundering?

<p>Loss of valuable resources (D)</p> Signup and view all the answers

What can be a direct effect of money laundering on the stock value of financial organizations?

<p>Reduction in stock value (C)</p> Signup and view all the answers

What is one of the primary missions of ACAMS?

<p>To promote standards for detecting and preventing money laundering (C)</p> Signup and view all the answers

Which of the following best describes the CAMS designation?

<p>A globally recognized credential for AML specialists (C)</p> Signup and view all the answers

How does ACAMS assist AML professionals in their careers?

<p>By providing a forum for collaboration and education (B)</p> Signup and view all the answers

What does ACAMS aim to uphold among practitioners?

<p>Proven and sound AML practices and procedures (B)</p> Signup and view all the answers

What is a significant benefit of obtaining the CAMS designation for AML professionals?

<p>Recognition as experts in the AML field (A)</p> Signup and view all the answers

Which of the following is NOT a function of ACAMS?

<p>Enforcing global AML laws (A)</p> Signup and view all the answers

What characteristic does ACAMS emphasize about the professionals in the AML field?

<p>Specialized knowledge in preventing financial crime (B)</p> Signup and view all the answers

Why is the CAMS credential considered valuable in the AML field?

<p>It is a testament to recognized expertise in AML practices (B)</p> Signup and view all the answers

What is the primary purpose of sanctions imposed by governing bodies?

<p>To protect the financial system from money laundering and terrorist financing (A)</p> Signup and view all the answers

Which body administers and enforces economic and trade sanctions in the United States?

<p>Office of Foreign Assets Control (OFAC) (A)</p> Signup and view all the answers

What are comprehensive sanctions?

<p>Sanctions that prohibit virtually all transactions with a specific country (C)</p> Signup and view all the answers

What is a potential consequence of failing to comply with sanctions?

<p>Involvement in criminal and civil penalties (A)</p> Signup and view all the answers

What type of sanctions focus on specific industries or individuals?

<p>Targeted sanctions (B)</p> Signup and view all the answers

How does money laundering impact government finances?

<p>It drives up government expenses due to increased enforcement costs (D)</p> Signup and view all the answers

What does FATF call for in relation to high-risk jurisdictions?

<p>Implementation of countermeasures like enhanced due diligence (D)</p> Signup and view all the answers

What challenges do financial organizations face that rely on proceeds from crime?

<p>Attracting legitimate clients and managing operations (B)</p> Signup and view all the answers

What is a potential consequence of unchecked money laundering related to the financial sector?

<p>Weakening of financial organizations (D)</p> Signup and view all the answers

How does unchecked money laundering impact the legitimate private sector?

<p>It undermines the legitimate private sector (D)</p> Signup and view all the answers

Which of the following aspects is directly linked to money laundering and corruption?

<p>Increased penetration of organized crime groups (A)</p> Signup and view all the answers

What is a likely effect of money laundering on a country's reputation?

<p>Reputation risk for the country (C)</p> Signup and view all the answers

How does money laundering typically affect economic policy decisions?

<p>It leads to loss of control over economic policy decisions (D)</p> Signup and view all the answers

What is a common characteristic of jurisdictions that are havens for money laundering?

<p>Limited regulatory capacity to monitor compliance (A)</p> Signup and view all the answers

What effect does money laundering have on foreign investments?

<p>It dampens effect on foreign investments (D)</p> Signup and view all the answers

Which risk is NOT commonly associated with the consequences of money laundering?

<p>Environmental risk (C)</p> Signup and view all the answers

What does the practice of nesting involve in correspondent banking?

<p>A correspondent acting for another bank without appropriate oversight (C)</p> Signup and view all the answers

Which event resulted in Deutsche Bank facing a significant penalty in July 2020?

<p>Compliance failures in its relationship with Jeffrey Epstein (D)</p> Signup and view all the answers

What was one of the main reasons Deutsche Bank failed to monitor its clients effectively?

<p>Failure to recognize high-risk patterns in transactions (C)</p> Signup and view all the answers

What action did Deutsche Bank take after the Financial Crimes Enforcement Network mandated it?

<p>Exited relationships with non-compliant banks (D)</p> Signup and view all the answers

What is a significant risk associated with nested accounts in correspondent banking?

<p>Reduced compliance with anti-money laundering regulations (C)</p> Signup and view all the answers

How many suspicious transactions related to FBME Bank were flagged by Deutsche Bank after it identified the bank as high risk?

<p>826 suspicious transactions (C)</p> Signup and view all the answers

What recurring issue was highlighted regarding Danske Estonia in relation to Deutsche Bank?

<p>AML issues concerning nonresident accounts (B)</p> Signup and view all the answers

What was the consequence for Deutsche Bank related to its dealings with Danske Bank Estonia?

<p>Significant penalties due to money laundering connections (C)</p> Signup and view all the answers

What are the three stages of the money laundering cycle?

<p>Placement, Layering, Integration (D)</p> Signup and view all the answers

Which method is NOT typically associated with money laundering?

<p>Training funds (A)</p> Signup and view all the answers

Which financial institution is commonly associated with money laundering through electronic transfers?

<p>Banks (B)</p> Signup and view all the answers

What is a 'Politically Exposed Person' (PEP)?

<p>An individual holding a political office (B)</p> Signup and view all the answers

What does 'AML/CFT' stand for?

<p>Anti-Money Laundering/Countering the Financing of Terrorism (B)</p> Signup and view all the answers

Which organization is primarily responsible for setting international AML standards?

<p>Financial Action Task Force (FATF) (D)</p> Signup and view all the answers

Which of the following is a key component of a strong AML compliance program?

<p>Report Monitoring (C)</p> Signup and view all the answers

What is the primary reason for assessing AML/CFT risk?

<p>To identify potential money laundering activities (B)</p> Signup and view all the answers

Which method is commonly used for detecting terrorist financing?

<p>Monitoring social media activities (D)</p> Signup and view all the answers

Which case involves illicit finance through informal money transfer systems?

<p>NPOs and Terrorist Financing (A)</p> Signup and view all the answers

What type of accounts are often misused for money laundering in banking?

<p>Payable-Through Accounts (A)</p> Signup and view all the answers

Which payment product poses a significant risk for money laundering?

<p>Mobile Payment Services (B)</p> Signup and view all the answers

What is the primary function of 'shell companies' in illicit finance?

<p>To obscure true ownership and financial activities (B)</p> Signup and view all the answers

Flashcards

Money Laundering Impact

Unchecked money laundering negatively affects a country's economy, society, and reputation, often leading to corruption and criminal activity.

Organized Crime Attraction

A country seen as a money laundering haven attracts organized crime groups.

Weak Money Laundering Laws

Jurisdictions with limited predicate crimes, types of organizations covered, and enforcement mechanisms are easily exploited by money launderers.

Corruption from Money Laundering

Money laundering often fuels corruption as organized crime groups bribe officials and other stakeholders to bypass regulations.

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Corruption and Bribery

Corruption in public and private sectors is often connected to money laundering; involving bribery among government officials, legal professionals, financial institutions, and law enforcement.

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Money Laundering Economic Impacts

Potential economic consequences include decreased foreign investment, loss of tax revenue, instability, and risks to privatization efforts, along with reputational damage.

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Regulatory Capacity

Money laundering thrives in jurisdictions with insufficient regulatory capacity to supervise and monitor compliance with laws and regulations.

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Economic Instability

Money laundering causes distortions in the economy, leading to instability and potential risk of international sanctions, as well as reputational harm for a country.

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ACAMS's mission

To promote international standards for preventing and detecting money laundering and terrorist financing.

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ACAMS goal for AML professionals

Career enhancement through education, certification, and training.

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Money Laundering

The process of making illegally obtained money seem legitimate.

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CAMS designation

A credential recognizing AML expertise, internationally recognized.

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AML

Anti-money laundering.

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Terrorist Financing

Providing resources to support terrorist activities.

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Professional Standards for AML

Global standards for anti-financial crime practitioners.

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Networking for AML Professionals

Platforms to facilitate collaboration among AML/CFT professionals worldwide.

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Three Stages of Money Laundering

Placement, layering, and integration are the steps to make money look clean.

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Placement

The first stage in money laundering, where large sums of cash are broken down and positioned for further actions.

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Layering

The second stage in money laundering where funds are moved through multiple financial transactions to lose a paper trail.

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Integration

The final stage in money laundering, where the laundered money re-enters the financial system as legitimate funds.

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AML/CFT Compliance

Programs and measures taken to prevent money laundering and terrorist financing within an organization.

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Compliance Officer

A person responsible for ensuring an organization complies with AML/CFT regulations.

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Politically Exposed Person (PEP)

A person holding or having held a prominent public position.

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Structuring

Breaking down large cash deposits into smaller transactions to avoid detection.

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Microstructuring

A smaller-scale application of structuring.

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Correspondent Banking

Arrangement between banks in different jurisdictions to process transactions for each other.

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Trade-Based Money Laundering (TBML)

Using international trade transactions to launder money.

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Hawala

Informal network for transferring money.

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Virtual Currency

Digital form of currency, such as cryptocurrency, not regulated by central banks.

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International Sanctions

Actions taken by governing bodies (e.g., US, UN, EU) to restrict economic and financial transactions with specific countries, entities, or individuals as a response to security threats.

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Comprehensive Sanctions

Broad sanctions prohibiting virtually all transactions with a specific country.

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Targeted Sanctions

Sanctions focused on specific industries, entities, or individuals.

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OFAC (Office of Foreign Assets Control)

US government agency enforcing economic and trade sanctions.

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SDN List

List of individuals, entities, or groups subject to US sanctions.

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Social Costs of Money Laundering

Significant societal costs arising from money laundering, including increased government spending on law enforcement and the treatment of addiction.

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High-Risk Jurisdictions

Countries with significant deficiencies in anti-money laundering/counter-terrorism financing regulations.

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Reputational Risk

Damage to an organization's image due to negative publicity regarding its practices or associations, leading to decreased trust from customers, depositors, and investors.

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Liquidity Problems

An organization's inability to easily access enough funds to meet its financial obligations due to withdrawal of deposits or limited access to reliable funding sources.

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Operational Risk

Potential for financial loss caused by internal failures, ineffective processes, or external events that disrupt operations, such as losing correspondent banking services or facing increased borrowing costs.

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Legal Risk

Exposure to lawsuits, fines, penalties, and potential closure due to illegal activities, including investigations by regulators or law enforcement.

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Loss of Profitable Business

Reduced profits from losing high-quality borrowers, investors, or customers due to reputational damage or decreased trust stemming from money laundering activities.

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Termination of Correspondent Banking Facilities

Loss of banking services provided by another bank, which is essential for international transactions and can significantly disrupt an organization's operations.

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Investigation Costs and Fines

Financial burdens resulting from investigations by regulatory bodies or law enforcement due to potential money laundering activities, including penalties and legal fees.

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Asset Seizures

Government confiscation of assets belonging to an individual or organization suspected of involvement in money laundering, leading to financial losses and potential business disruption.

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Nested Accounts

A situation where a respondent bank is also a correspondent to a third bank, creating layers of relationships.

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Why is Correspondent Banking Risky?

Correspondent banks may have limited information about a respondent's customers and their anti-financial crime controls, increasing the risk of money laundering.

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Deutsche Bank Case

Deutsche Bank faced a $150 million penalty for failing to monitor its high-risk correspondent relationships with Danske Bank Estonia and FBME Bank, which led to billions in suspicious transactions.

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What was the Red Flag?

Deutsche Bank had internal warnings about FBME and Danske from the start, but didn't take action.

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Danske Bank Estonia

A high-risk correspondent relationship of Deutsche Bank, facilitating suspicious transactions linked to money laundering by Russian oligarchs.

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Ultimate Beneficial Owner (UBO)

The individual(s) who ultimately own or control a company, even if their name isn't on official documentation.

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Financial Crimes Enforcement Network (FinCEN)

A US agency that combats financial crimes, including money laundering and terrorist financing.

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Study Notes

Money Laundering and Terrorist Financing Risks

  • Money laundering undermines legitimate businesses, weakens financial institutions, and deters foreign investment.
  • It leads to economic distortion, loss of tax revenue, and risks of international sanctions.
  • Social costs include increased crime, corruption, and government expense.
  • Countries with weak money laundering laws and enforcement attract criminals.
  • Corruption often triggers money laundering, corrupting various sectors.
  • International sanctions can be imposed for failure to comply with AML/CFT standards.

Risks Associated with Money Laundering

  • Reputational risk: Damage to an organization's image from money laundering scandals.
  • Operational risk: Losses from inadequate processes, personnel, or systems; reduced/terminated banking services.
  • Legal risk: Lawsuits, penalties, unenforceable contracts, and fines.
  • Concentration risk: The risk that the concentration of financial activity could be misused.

Case Study: Correspondent Banking and Money Laundering

  • In 2020, Deutsche Bank received a US$150 million penalty for AML violations.
  • Concerns regarding Deutsche Bank’s relationships with Danske Bank Estonia and FBME Bank and their high-risk ratings were ignored.
  • Numerous suspicious transactions, including those associated with Russian oligarchs, were processed through Deutsche Bank's accounts.
  • Internal compliance controls raised red flags, but no immediate action was taken.
  • Deutsche Bank eventually ceased relationships with FBME after FinCEN mandated such action.
  • Deutsche Bank was alerted to AML issues related to non-resident accounts at Danske Bank, but the risk was not adequately addressed.

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