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The compliance officer for a private bank has been tasked with writing a policy on how the bank will deal with intermediaries.
Which two aspects should be included in the policy in respect of intermediaries to align it with the Wolfsberg Anti-Money Laundering Principles for Private Banking? (Choose two.)

1. A. When an intermediary introduces clients to the bank, it is not necessary for the bank to perform due diligence on the intermediary’s clients.
2. B. Where an intermediary introduces clients to the bank, the bank must obtain the same type of information with respect to an introduced client that would otherwise be obtained by the bank, absent the involvement of the intermediary.
3. C. Where an intermediary manages assets on behalf of a number of clients and is the account holder with the bank, but that intermediary does not conduct the same level of due diligence as the bank, it is necessary for the bank to undertake due diligence on the intermediary’s clients.
4. D. Where an intermediary manages assets on behalf of a number of clients and arranges for the opening of accounts for its clients with the bank, and that intermediary is a financial institution subject to similar regulations, it is necessary for the bank to perform due diligence on the intermediary’s clients.

Correct Answer: BD

Which method to launder money through deposit-taking institutions is closely associated with international trade?

1. A. Forming a shell company
2. B. Using Black Market Peso Exchange
3. C. Structuring cash deposits withdrawals
4. D. Investing in legitimate business with illicit funds

Correct Answer: B

What is the appropriate compliance control for identifying politically exposed persons (PEPs) according to the Basel Committee’s paper on Customer Due Diligence for Banks?

1. A. Determining that a local figure is a PEP
2. B. Reviewing when a relationship is established
3. C. Reviewing relationships at account opening and on a periodic basis
4. D. Requiring that the customer discloses that they are a PEP or an associate of a PEP

Correct Answer: C

A customer brings $15,000 worth of chips into a casino and plays various games. The customer redeems all the remaining chips and requests a wire transfer of the proceeds to an unrelated third party. What are two red flags that indicate money laundering? (Choose two.)

1. A. Customer redeeming all remaining chips
2. B. Playing various games before cashing out
3. C. Bringing $15,000 worth of chips into the casino
4. D. Requesting a wire transfer to an unrelated third party

Correct Answer: AD

A law enforcement agency is reviewing a suspicious transaction report (STR) filed by a financial institution for suspicious activity on a client’s account. Subsequently, the agency requests further information. Which supporting documentation might the law enforcement agency request from the institution to facilitate its investigation?

1. A. Previously filed STRs on the same customer
2. B. Account opening documents and account statements
3. C. Copies of promotional materials sent to the customer
4. D. A copy of the institution’s STR policy and procedures

Correct Answer: B