1.
FAILURE TO REPORT SUSPICIOUS ACTIVITIES CAN RESULT IN PENALTIES OR LEGAL ACTION AGAINST YOU AND YOUR COMPANY.
Correct Answer
A. TRUE
Explanation
Failure to report suspicious activities can result in penalties or legal action against you and your company. This means that if you fail to report any suspicious activities that you come across, you and your company may face consequences such as fines or legal proceedings. It is important to be vigilant and report any suspicious activities to the appropriate authorities to ensure compliance with the law and to maintain the integrity and security of your company.
2.
MONEY LAUNDERING IS THE PROCESS BY WHICH THE PROCEEDS OF CRIMINAL ACTIVITY ARE INTRODUCED INTO LEGITIMATE MAINSTREAM OF FINANCIAL COMMERCE.
Correct Answer
A. TRUE
Explanation
Money laundering is indeed the process by which the proceeds of criminal activity are introduced into the legitimate mainstream of financial commerce. This involves disguising the illegal origins of the money and making it appear as if it came from legitimate sources. Money laundering is a serious crime that allows criminals to enjoy the profits from their illegal activities while evading detection and prosecution. It is a global issue that undermines the integrity of financial systems and facilitates further criminal activities.
3.
THE PATRIOT ACT STRENGTHENED SEVERAL ANTI-MONEY LAUNDERING LAWS.
Correct Answer
A. TRUE
Explanation
The Patriot Act, which was enacted in response to the 9/11 terrorist attacks, indeed strengthened several anti-money laundering laws. The act expanded the ability of law enforcement agencies to track and investigate money laundering activities, particularly those related to terrorism financing. It introduced stricter regulations for financial institutions, requiring them to implement robust anti-money laundering programs and report suspicious transactions. The aim was to enhance the government's ability to detect and prevent money laundering, ultimately disrupting the flow of funds to criminal and terrorist organizations.
4.
SECTION 352 OF THE PATRIOT ACT REQUIRES ALL MSB'S TO IMPLEMENT ANTI-MONEY LAUNDERING PROGRAMS THAT INCLUDE
Correct Answer
E. ALL OF THE ABOVE
Explanation
Section 352 of the Patriot Act requires all MSBs (Money Services Businesses) to implement anti-money laundering programs that include written policies and procedures, appointment of a compliance officer, ongoing employee training program, and the independent review function. This means that MSBs are legally obligated to have written guidelines and protocols in place to prevent money laundering, designate a compliance officer to oversee these efforts, provide training to employees to ensure compliance, and regularly assess and review the effectiveness of their anti-money laundering measures. Therefore, the correct answer is "ALL OF THE ABOVE".
5.
AS A MANAGER/OR COMPLIANCE OFFICER, IT IS PART OF YOUR JOB TO
Correct Answer
D. ALL OF THE ABOVE
Explanation
As a manager or compliance officer, it is part of your job to maintain your company's AML (Anti-Money Laundering) program. This involves implementing and overseeing policies and procedures to prevent money laundering and terrorist financing. Additionally, you are responsible for ensuring that proper reports are filed and records are maintained in accordance with regulatory requirements. You must also ensure that employees are trained and aware of their obligation to report any suspicious activities they come across. Therefore, the correct answer is "ALL OF THE ABOVE".
6.
THE PATRIOT ACT DOES NOT REQUIRE WHICH OF THE FOLLOWING AS PART OF AN APPROPRIATE AML PROGRAM?
Correct Answer
D. MANDATORY DRUG SCREENING
Explanation
The correct answer is MANDATORY DRUG SCREENING. The Patriot Act does not require mandatory drug screening as part of an appropriate anti-money laundering (AML) program. The Act focuses on preventing money laundering and terrorist financing activities, and it requires financial institutions to establish and maintain an AML program that includes appointment of a compliance officer, written policies and procedures, and independent review of the program. However, drug screening is not directly related to these AML requirements.
7.
EMPLOYEE TRAINING PROGRAMS SHOULD
Correct Answer
E. ALL OF THE ABOVE
Explanation
The correct answer is "ALL OF THE ABOVE". This means that employee training programs should include all existing and new employees, be ongoing and updated to include new changes in the law and industry, be specific to the employee's duties and the services provided by the MSB, and be documented and confirmed by appropriate testing. In other words, the training programs should cover all employees, be regularly updated, tailored to their specific roles, and have proper documentation and testing procedures.
8.
OFAC REGULATIONS APPLY ONLY TO BANKS
Correct Answer
B. FALSE
Explanation
OFAC (Office of Foreign Assets Control) regulations do not apply only to banks. OFAC regulations apply to all US individuals, companies, and organizations, including banks, that engage in transactions involving sanctioned countries, entities, or individuals. These regulations are designed to prevent money laundering, terrorism financing, and other illicit activities. Therefore, the statement that OFAC regulations apply only to banks is incorrect.
9.
WHAT ACT IS AIMED AT THE PROVIDING STRONGER SURVEILLANCE POWERS, STRENGTHENING CRIMINIAL LAWS AGAINST TERRORISM, AND COMBATING MONEY LAUNDERING?
Correct Answer
D. USA PATRIOT ACT
Explanation
The USA PATRIOT Act is aimed at providing stronger surveillance powers, strengthening criminal laws against terrorism, and combating money laundering. This act was enacted in response to the 9/11 terrorist attacks and it expanded the powers of law enforcement agencies to monitor and prevent terrorist activities. It also enhanced the ability to track and seize assets related to terrorism and money laundering. The act has been controversial due to concerns about privacy and civil liberties, but it remains an important tool in the fight against terrorism and financial crimes.
10.
THE BANK SECRECY ACT REQUIRES FINANCIAL INSTITUTIONS TO
Correct Answer
D. A & C
Explanation
The Bank Secrecy Act requires financial institutions to report suspicious activities and file currency transaction reports with the IRS. This means that if a financial institution notices any suspicious activity, such as large cash deposits or withdrawals, they are obligated to report it to the appropriate authorities. Additionally, they must also file currency transaction reports with the IRS for any transactions involving a certain amount of currency. Therefore, the correct answer is A & C.
11.
IF A REGULAR CUSTOMER CONDUCTS A CASH TRANSACTION INVOLVING MORE THAN $10,000, YOUR COMPANY IS NOT REQUIRED TO FILE A CTR
Correct Answer
B. FALSE
Explanation
The correct answer is FALSE. If a regular customer conducts a cash transaction involving more than $10,000, your company is required to file a Currency Transaction Report (CTR) with the Financial Crimes Enforcement Network (FinCEN). This is a requirement under the Bank Secrecy Act (BSA) to help prevent money laundering and other illegal financial activities. Failing to file a CTR when required can result in penalties and legal consequences for the company.
12.
LAUNDERERS MIGHT ATTEMPT A SERIES OF SMALL CURRENCY TRANSACTIONS OVER TIME BECAUSE
Correct Answer
A. A PROVISION OF THE BANK SECRECY ACT REQUIRES THE FILING OF A CTR FOR TRANSACTIONS EXCEEDING $10,000
Explanation
The Bank Secrecy Act requires financial institutions to file a Currency Transaction Report (CTR) for transactions that exceed $10,000. This provision is in place to monitor and detect any suspicious or illegal activities, such as money laundering. By conducting a series of small currency transactions over time, launderers can avoid triggering the threshold for filing a CTR and potentially evade detection. Therefore, the correct answer is that launderers might attempt a series of small currency transactions over time because of this provision of the Bank Secrecy Act.
13.
YOUR AML PROGRAM MUST COVER THE BANK SECRECY ACTS REQUIREMENT THAT FINANCIAL INSTITUTIONS FILE A ________________________ FOR CERTAIN TRANSACTIONS OVER $10,000
Correct Answer
A. CURRENCY TRANSACTION REPORT
Explanation
The correct answer is "CURRENCY TRANSACTION REPORT". Financial institutions are required by the Bank Secrecy Act to file a Currency Transaction Report (CTR) for certain transactions over $10,000. This report helps to detect and prevent money laundering and other illegal activities by tracking large cash transactions. The CTR includes information about the transaction, such as the date, amount, and parties involved, and is submitted to the Financial Crimes Enforcement Network (FinCEN).
14.
A CUSTOMER BRINGS IN $12,000 IN CURRENCY AT ONE TIME AND REQUESTS THREE SEPERATE MONEY ORDERS OF $4,000 EACH. A CTR IS NOT REQUIRED.
Correct Answer
B. FALSE
Explanation
A CTR (Currency Transaction Report) is required when a customer conducts a cash transaction of $10,000 or more in one day. In this case, the customer brings in $12,000 in currency and requests three separate money orders of $4,000 each. Since the total transaction amount is $12,000, which exceeds the $10,000 threshold, a CTR is required. Therefore, the correct answer is FALSE.
15.
AN EXAMPLE OF SMURFING IS:
Correct Answer
B. A DRUG DEALER ASKING A STRANGER TO BUY A MONEY ORDER WITH DRUG MONEY
Explanation
Smurfing refers to the practice of breaking down large financial transactions into smaller, less suspicious transactions to avoid detection by authorities. In this example, a drug dealer is engaging in smurfing by asking a stranger to buy a money order with drug money. This allows the drug dealer to disguise the illicit origin of the funds and make it harder for law enforcement to track the money trail.
16.
A CUSTOMER BUYS MONEY ORDERS FOR $5,999 CASH ON MONDAY, $9,000 CASH ON WEDNESDAY, $9,500 CASH ON THURSDAY, AND $8,000 CASH ON FRIDAY. THIS DESERVES MORE INVESTIGATION AS A POTENTIAL CASE OF STRUCTURING.
Correct Answer
A. TRUE
Explanation
The given statement is true because the customer is making multiple transactions of money orders with cash amounts just below the $10,000 threshold. This behavior is suspicious and may indicate an attempt to avoid reporting requirements and hide the true source of the funds, which is known as structuring. Structuring is illegal and is often associated with money laundering or other illicit activities. Therefore, this situation warrants further investigation to determine the nature and purpose of these transactions.
17.
WHICH OF THE FOLLOWING TRANSACTIONS REQUIRE A RECORD TO BE MADE?
Correct Answer
D. ALL OF THE ABOVE
Explanation
All of the given transactions require a record to be made because they involve exchanging different amounts of money or currencies. Keeping a record is important to track the exchange of funds and ensure accuracy in the transaction.
18.
IF A CUSTOMER IS RECEIVING A WIRE TRANSFER OF $6,000, THE MSB IS NOT REQUIRED TO TAKE ID AD RECORD THE CUSTOMERS INFORMATION.
Correct Answer
B. FALSE
Explanation
The correct answer is FALSE. According to regulations, when a customer is receiving a wire transfer of $3,000 or more, the Money Services Business (MSB) is required to take identification and record the customer's information. This is done to comply with anti-money laundering and counter-terrorism financing laws, which aim to prevent illegal activities such as money laundering and terrorist financing. Therefore, in this scenario, the MSB would be required to take ID and record the customer's information for the $6,000 wire transfer.
19.
FOR THE MONEY LAUNDERING PROCESS TO BE A SUCCESS, TRANSACTIONS SUCH AS CURRENCY EXCHANGE, WIRE TRANSFERS, AND MONEY ORDERS NEED TO BE COMPLIMENTED WITHOUT ANY PAPER TRAIL.
Correct Answer
B. FALSE
Explanation
The statement is false because for the money laundering process to be successful, transactions such as currency exchange, wire transfers, and money orders need to be conducted with a paper trail. A paper trail refers to a record of the transaction that can be traced and audited, making it difficult for illegal activities like money laundering to go unnoticed. Without a paper trail, it would be easier for authorities to detect and investigate suspicious transactions, ultimately making it harder for money laundering to be successful.
20.
YOUR MSB AND ANY OF ITS EMPLOYEES ARE LIABLE FOR _________ PENALTIES RANGING FROM FINES OF $250,000 AND IMPRISONMENT OF FIVE YEARS, UP TO FINES OF $5000,000 AND IMPRISONMENT OF 10 YEARS.
Correct Answer
D. CRMINAL
Explanation
The correct answer is "CRMINAL". The sentence states that MSB and its employees are liable for penalties ranging from fines of $250,000 and imprisonment of five years, up to fines of $500,000 and imprisonment of 10 years. This indicates that the penalties mentioned are related to criminal offenses.
21.
YOU AND YOUR MSB CAN RECEIVE CIVIL AND MONETARY PENALTIES IF YOU UNKNOWINGLY ASSIST MONEY LAUNDERERS.
Correct Answer
A. TRUE
Explanation
If you unknowingly assist money launderers, both you and your MSB (Money Services Business) can receive civil and monetary penalties. This means that even if you are not intentionally involved in money laundering activities, you can still be held accountable for your actions and face legal consequences. It is important to be vigilant and take necessary measures to prevent any unintentional assistance to money launderers.
22.
YOUR AML PROGRAM SHOULD WARN EMPLOYEES AGAINST DISCLOSING ANY CUSTOMERS SOCIAL SECURITY NUMBER, DRIVERS LICENSE NUMBER, ADDRESS, OR DATE OF BIRTH DATE BECAUSE IT COULD BE USED TO HELP IDENTITY THEFT.
Correct Answer
A. TRUE
Explanation
The statement is true because disclosing personal information such as social security number, driver's license number, address, or date of birth can potentially aid identity theft. These pieces of information are often used by criminals to impersonate individuals and carry out fraudulent activities. An effective AML (Anti-Money Laundering) program should educate and warn employees about the risks associated with disclosing such sensitive information to protect both the customers and the organization from identity theft.
23.
A CUSTOMER COMES IN FOUR DAYS IN A ROW, EACH TIME REQUESTING A WIRE TRANSFER OF $2,900. YOU DO NOT NEED TO REPORT THIS AS A SUSPICIOUS ACTIVITY.
Correct Answer
B. FALSE
Explanation
The statement is false because a customer coming in four days in a row and requesting a wire transfer of the same amount each time could be considered suspicious activity. This pattern could indicate potential money laundering or fraudulent activity, and it would be advisable to report it to the appropriate authorities or follow the company's protocols for reporting suspicious transactions.
24.
WHICH OF THESE ACTIVITIES MIGHT REQUIRE A SUSPICIOUS ACTIVITY REPORT?
Correct Answer
E. ALL OF THE ABOVE
Explanation
All of the above activities might require a suspicious activity report because they all indicate potential suspicious behavior that could be related to money laundering, fraud, or other illegal activities. The customer canceling a transaction and requesting a second transaction for a lower amount in order to avoid providing ID raises suspicions of attempting to hide their identity or engage in illicit activities. The customer requesting an unusually high dollar transaction without a clear reason or source of cash suggests potential money laundering. The nervous customer asking unusual questions about record keeping could be trying to gather information for fraudulent purposes. Lastly, the customer attempting to bribe a teller is a clear indication of illegal activity.
25.
JOHN WANTS TO MAKE A $3,500 WIRE TRANSFER. AS IDENTIFICATION, HE PRESENTS HIS VISA CREDIT CARD. THIS IS SATISFACTORY IDENTIFICATION.
Correct Answer
B. FALSE
Explanation
The statement is false because presenting a Visa credit card is not satisfactory identification for making a wire transfer. In order to make a wire transfer, John would typically need to provide his identification documents such as a government-issued ID or a passport. A credit card alone is not considered sufficient identification for such transactions.
26.
WHICH OF THE FOLLOWING ARE EXAMPLES OF WILLFUL BLINDNESS?
Correct Answer
E. ALL OF THE ABOVE
Explanation
The given correct answer is "ALL OF THE ABOVE" because all of the listed examples demonstrate willful blindness. Willful blindness refers to the act of intentionally ignoring or avoiding knowledge of illegal or suspicious activities in order to evade legal responsibility. All of the listed scenarios involve actions that go against regulations or policies, such as allowing a customer to use different names to purchase money orders, not recording customer identification for multiple money orders, completing a smaller transaction after a customer refuses to provide ID for a larger transaction, and cashing a check for someone who is not the payee.