1.
Which of the following acts is not considered to be a money laundering offence?
Correct Answer
C. Dealing with any assets, not knowing the property is proceeds of a crime
Explanation
Dealing with any assets, not knowing the property is proceeds of a crime is not considered to be a money laundering offense because money laundering involves knowingly dealing with assets that are known or believed to be the proceeds of a crime. In this case, the person is unaware that the property is derived from criminal activities, therefore it does not meet the criteria for money laundering.
2.
Which of the following is a regulatory requirement of Corporate Service Provider employees?
Correct Answer
A. Reporting a suspicious transaction
Explanation
A regulatory requirement of Corporate Service Provider employees is to report a suspicious transaction. This means that if an employee suspects any transaction to be potentially involved in criminal activities or money laundering, they are obligated to report it to the appropriate authorities. This requirement ensures that Corporate Service Providers are actively involved in preventing illegal activities and maintaining the integrity of the financial system.
3.
When should a Suspicious Transaction Report (STR) be made to the Authorities when you deal with your customer?
Correct Answer
B. Whenever there are suspicious activity indicators and the transaction with the customer remains suspicious, after all the information has been reviewed and attempt to clarify the issues with the customer has failed
Explanation
An STR should be made to the authorities when there are suspicious activity indicators and the transaction with the customer remains suspicious, even after reviewing all the information and attempting to clarify the issues with the customer. This ensures that any potential illegal activities or money laundering schemes are reported and investigated by the authorities. Simply having suspicious activity indicators alone may not be enough to trigger an STR, as further investigation and attempts to clarify the issues are necessary to confirm the suspicions.
4.
Which of the following is not normally required for Customer Due Diligence (CDD)?
Correct Answer
A. Know the spouse of the customer
Explanation
Customer Due Diligence (CDD) is a process that financial institutions undertake to verify the identity of their customers and assess the potential risks associated with their business relationship. This involves gathering information about the customer, such as their name, address, and identification documents. Knowing the customer is an essential part of CDD as it helps in understanding their background and assessing the risks involved. However, knowing the spouse of the customer is not normally required for CDD as it is not directly relevant to the identification and risk assessment process.
5.
A walk-in customer, Mr. Roberts, came to our company and asked to set up a limited company, Company A. He asked this to be done quickly because he will be returning to the UAE soon. He provided the name of his wife as another shareholder of the company to be set up. He claimed that he would supply copies of both his and the wife’s passport at a later stage.What is the most appropriate course of action?
Correct Answer
B. Proceed with the business and conduct CDD on Mr. Roberts and his wife
Explanation
You need to conduct “CDD” when establishing business relationship with your customers. If after CDD is conducted and you found it suspicious, then you should make a STR to the Competent Authorities (in Cyprus: MOKAS / in BVI: FIU).
6.
Following upon Q.6, you interviewed Mr. Roberts with a view to conducting Customer Due Diligence (CDD). He stated that he was a company director in the UAE (with no further details provided) and claimed that he had not had his passport or picture ID with him. His wife was busy in the UAE and could not travel to Cyprus to sign the documents for setting up the company. Mr. Roberts stated that a “Power of Attorney” will be sent to your office by courier tomorrow so that he is properly authorised to act for his wife. He requested that action be taken now to set up a company in Cyprus.What should you do?
Correct Answer
A. Ask Mr. Roberts to be patient and come back tomorrow with the proof of ID of himself and his wife as well as documentary proof of his directorship in the UAE company
Explanation
You should continue to conduct “CDD” with a view to getting more information on Mr. Roberts. It may be a bit too early to say that the case is so suspicious that a STR should be made.
7.
Following upon Q.7, Mr. Roberts told you that he came from the UAE and would stay in Cyprus for a few days only. He claimed that he wanted to deposit the funds of a declared dividend he obtained in the UAE and invest in real estate in Cyprus.As he is too busy to open a bank account, he requested to deposit the money in cash into the bank account of our company so that the money could be transferred to the bank account of Company A for property investment.What should you do?
Correct Answer
B. Make a STR as the circumstances are suspicious
Explanation
The circumstances (e.g. dividend in the form of cash; request the money to go through our company's account) are suspicious enough to warrant a STR to be made to the Competent Authority.
8.
Mr Roberts now has succeeded in opening a bank account and transferring funds into this account. Further to Q.8, Mr. Roberts sent you a letter from the UAE saying that as the Cyprus property market seemed to go down, he had decided to change his investment plan. He requested your company to transfer the money to his friend's bank accounts in the UAE.What is the best course of action?
Correct Answer
C. Make a STR to the Competent Authorities to explain the suspicion you have in this case
Explanation
Make a report to the Competent Authority so that the case can be referred to the appropriate law enforcement agency for follow up action. Following the case study of Mr Roberts from the beginning, the money laundering scheme was to (1) take cash - supposedly from company dividends (2) to place it in a Cyprus company bank account, and (3) to transfer it out to a "friend's account" in the UAE.
9.
Mr. Smith came to your office and asked to set up a trust for charitable purposes. The aim is to help poor children in Africa with their education. After the trust is formed, donations were received from overseas countries and money was sent to various African countries for building schools. A few months later, Mr. Smith instructed you to transfer US$100,000 to a personal bank account opened in a country known to be of a terrorist concern / under sanctions. Mr. Smith said that the money is to buy material to build schools in Africa.What should you do?
Correct Answer
C. Make a STR because the transaction relates to a country under terrorist concern / sanctions
Explanation
The transaction may be related to terrorist activities. A report should be made to the Competent Authority.
10.
One of the important steps of money laundering is:
Correct Answer
B. Placement; layering
Explanation
Money laundering is a process of making illegally obtained money appear legitimate. The first step in this process is placement, where the illicit funds are introduced into the financial system. This can be done by depositing the money into bank accounts or making cash purchases. The second step is layering, which involves disguising the source of the funds through complex transactions and transfers. This can include moving the money between different accounts, countries, or investments to make it difficult to trace. Therefore, the correct answer is "Placement; layering".