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 may be held accountable and face consequences such as fines or legal action. It is important to be vigilant and report any suspicious activities to the appropriate authorities to ensure the safety and security of your company and the community.
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 the process of making illegally obtained money appear legal by passing it through a complex sequence of banking transfers or commercial transactions. This allows the proceeds of criminal activity to enter the legitimate financial system undetected. Therefore, the statement that money laundering is the process by which the proceeds of criminal activity are introduced into the legitimate mainstream of financial commerce is true.
3.
THE PATRIOT ACT STRENGTHENED SEVERAL ANTI-MONEY LAUNDERING LAWS.
Correct Answer
A. TRUE
Explanation
The Patriot Act, enacted in response to the 9/11 terrorist attacks, did indeed strengthen several anti-money laundering laws. One of the main goals of the act was to enhance the ability of law enforcement agencies to detect and prevent money laundering activities, which are often linked to terrorist financing. The act introduced various measures, such as stricter reporting requirements for financial institutions, increased coordination and information sharing among government agencies, and the establishment of the Financial Crimes Enforcement Network (FinCEN) to combat money laundering effectively. Therefore, the statement is true.
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 mandates that all Money Services Businesses (MSBs) must have anti-money laundering programs in place. These programs should include written policies and procedures to guide the business's operations, the appointment of a compliance officer to oversee and ensure compliance with these policies, an ongoing employee training program to educate employees about money laundering risks and prevention measures, and an independent review function to assess the effectiveness of the anti-money laundering program. Therefore, the correct answer is "ALL OF THE ABOVE" as all of these elements are required by Section 352 of the Patriot Act.
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 and detect money laundering and other illegal activities within the company. Additionally, you are responsible for ensuring that proper reports are filed and records are maintained in compliance with regulatory requirements. Lastly, you must 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, which is a U.S. law aimed at combating terrorism and money laundering, does not specifically require mandatory drug screening as part of an appropriate Anti-Money Laundering (AML) program. However, it does require financial institutions to appoint a compliance officer, establish written policies and procedures, and conduct independent reviews of their AML programs to ensure compliance with the law.
7.
EMPLOYEE TRAINING PROGRAMS SHOULD
Correct Answer
E. ALL OF THE ABOVE
Explanation
The correct answer is "ALL OF THE ABOVE". This is because the question asks for the characteristics that employee training programs should have, and all of the listed options are valid and necessary. Employee training programs should include all existing and new employees to ensure consistency and fairness. They should be ongoing and updated to keep up with changes in the law and industry. They should also be specific to the employees' duties and the services provided by the MSB (Money Services Business). Lastly, documenting the training and confirming it through appropriate testing helps to ensure that the employees have understood and retained the necessary knowledge and skills.
8.
OFAC REGULATIONS APPLY ONLY TO BANKS
Correct Answer
B. FALSE
Explanation
OFAC regulations do not apply only to banks. The Office of Foreign Assets Control (OFAC) is a U.S. government agency that administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals. These regulations apply to all U.S. individuals and entities, including banks, as well as foreign individuals and entities that engage in transactions involving U.S. jurisdiction or U.S. persons. Therefore, the statement that OFAC regulations apply only to banks is false.
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 passed in response to the 9/11 terrorist attacks and is intended to enhance the ability of law enforcement agencies to prevent and investigate acts of terrorism. It grants expanded powers to government agencies, such as the ability to monitor communications, access financial records, and track suspected terrorists. The act also includes provisions to combat money laundering, making it harder for terrorists to finance their activities.
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 observes any suspicious activity, such as potential money laundering or terrorist financing, they are obligated to report it to the appropriate authorities. Additionally, financial institutions must also keep records of all transactions to ensure transparency and accountability. 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 given statement is false. If a regular customer conducts a cash transaction involving more than $10,000, the company is required to file a Currency Transaction Report (CTR). This is a legal requirement under the Bank Secrecy Act (BSA) to prevent money laundering and other financial crimes. Failing to file a CTR 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 correct answer is that a provision of the Bank Secrecy Act requires the filing of a CTR (Currency Transaction Report) for transactions exceeding $10,000. This means that if launderers were to conduct large currency transactions, they would be more likely to attract attention and scrutiny from authorities. By conducting a series of smaller transactions over time, launderers can avoid triggering the reporting requirement and potentially evade detection. This strategy helps them to hide the illicit origin of the funds and make it harder for law enforcement to track their activities.
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. A CTR is a form that must be submitted to the Financial Crimes Enforcement Network (FinCEN) to report cash transactions that exceed the specified threshold. This report helps to monitor and detect potential money laundering or other illicit activities involving large sums of money.
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
The statement is false because according to the Bank Secrecy Act, any transaction involving more than $10,000 in cash requires the filing of a Currency Transaction Report (CTR). In this case, the customer is bringing in $12,000 in currency, which exceeds the threshold, and therefore a CTR would be required.
15.
AN EXAMPLE OF SMURFING IS:
Correct Answer
B. A DRUG DEALER ASKING A STRANGER TO BUY A MONEY ORDER WITH DRUG MONEY
Explanation
The correct answer is A DRUG DEALER ASKING A STRANGER TO BUY A MONEY ORDER WITH DRUG MONEY. Smurfing refers to the illegal practice of breaking down large sums of money into smaller, less suspicious amounts to avoid detection by authorities. In this scenario, the drug dealer is asking a stranger to buy a money order with drug money, which is a form of smurfing as it involves disguising the origin of the illicit funds by involving a third party.
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 customer's pattern of buying money orders with large amounts of cash on multiple consecutive days raises suspicion of structuring. Structuring involves intentionally making multiple transactions in smaller amounts to avoid reporting requirements and detection by authorities. In this case, the customer's consistent purchases of money orders with cash suggest an attempt to evade reporting requirements. Therefore, the statement "This deserves more investigation as a potential case of structuring" is true.
17.
WHICH OF THE FOLLOWING TRANSACTIONS REQUIRE A RECORD TO BE MADE?
Correct Answer
D. ALL OF THE ABOVE
Explanation
All of the above transactions require a record to be made because they involve exchanging different amounts of currency. In each transaction, there is a change in the type or value of the currency being exchanged, which needs to be documented for record-keeping purposes.
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 statement is false because according to the regulations set by the Financial Crimes Enforcement Network (FinCEN), Money Services Businesses (MSBs) are required to verify the identity of customers and record their information for any transaction involving $3,000 or more. Therefore, if a customer is receiving a wire transfer of $6,000, the MSB is indeed required to take ID and record the customer's information.
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 transactions that can be traced and audited. Without a paper trail, it becomes difficult to track the flow of money and identify any suspicious activities. Therefore, having a paper trail is crucial in detecting and preventing money laundering.
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. This is because the sentence is discussing penalties and imprisonment, which are associated with criminal offenses. The word "CRMINAL" is likely a typographical error and should be corrected to "CRIMINAL." Therefore, the correct answer is CRIMINAL.
21.
YOU AND YOUR MSB CAN RECEIVE CIVIL AND MONETARY PENALTIES IF YOU UNKNOWINGLY ASSIST MONEY LAUNDERERS.
Correct Answer
A. TRUE
Explanation
The statement is true because if you unknowingly assist money launderers, both you and your MSB (Money Services Business) can face civil and monetary penalties. Money laundering is a serious crime that involves disguising the origins of illegally obtained money. By unknowingly assisting money launderers, you could be inadvertently facilitating their illegal activities, which is punishable by law. Therefore, it is important to be vigilant and take necessary precautions to prevent unintentional involvement in money laundering activities.
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
This statement is true because disclosing personal information such as social security number, driver's license number, address, or date of birth can potentially lead to identity theft. These pieces of information are often used by identity thieves to impersonate individuals and commit fraudulent activities. By warning employees against disclosing such information, the AML program aims to protect customers from potential harm and prevent identity theft incidents.
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
This statement is false because the scenario described raises red flags for potential money laundering or fraudulent activity. The customer's repetitive behavior of requesting wire transfers of the same amount over multiple days can indicate an attempt to avoid detection or scrutiny. Financial institutions are required to report suspicious activities to the appropriate authorities to prevent illegal activities such as money laundering or fraud.
24.
WHICH OF THESE ACTIVITIES MIGHT REQUIRE A SUSPICIOUS ACTIVITY REPORT?
Correct Answer
E. ALL OF THE ABOVE
Explanation
All of the activities mentioned in the options can be considered suspicious and may require a suspicious activity report. A customer canceling a transaction and requesting a second transaction for a lesser amount to avoid providing identification raises concerns about potential illegal activities. Similarly, a customer requesting an unusually high dollar transaction without a valid explanation or source of cash can also be seen as suspicious. Additionally, a nervous customer asking unusual questions about record keeping and a customer attempting to bribe a teller are both red flags for suspicious behavior. Therefore, all of the mentioned activities can warrant a suspicious activity report.
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
Presenting a Visa credit card as identification for a wire transfer is not satisfactory. Credit cards are not typically accepted as valid identification for financial transactions, especially for large amounts like a $3,500 wire transfer. Proper identification for a wire transfer usually includes government-issued identification such as a driver's license or passport. Therefore, the statement is false.
26.
WHICH OF THE FOLLOWING ARE EXAMPLES OF WILLFUL BLINDNESS?
Correct Answer
E. ALL OF THE ABOVE
Explanation
The examples provided in the question all demonstrate instances of willful blindness. Willful blindness refers to the act of intentionally ignoring or avoiding knowledge of illegal or unethical activities in order to escape liability or consequences. Allowing a customer to purchase money orders under different names, selling multiple money orders without recording identification, 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 all involve deliberately turning a blind eye to potential wrongdoing. Therefore, all of the examples given are examples of willful blindness.