What are the roles of a government Financial Intelligence Unit (FIU)? (Select Three.)
Financial Intelligence Units (FIUs) serve as national centers for collecting, analyzing, and disseminating AML/CFT information.
Option B (Correct): FIUs analyze SARs and STRs to detect money laundering and terrorist financing risks.
Option D (Correct): FIUs disseminate financial intelligence to local and international law enforcement agencies and other FIUs.
Option E (Correct): FIUs receive SARs/STRs from financial institutions, which form the basis for their analysis.
Why Other Options Are Incorrect:
Option A (Incorrect): FIUs do not prosecute cases; they refer findings to law enforcement agencies.
Option C (Incorrect): FIUs share intelligence, but prosecution is handled by judicial authorities, not FIUs.
Best Practices for FIUs:
Enhance data-sharing agreements with domestic and international agencies.
Use AI and analytics tools to detect suspicious financial patterns.
Ensure secure handling of sensitive AML/CFT data.
FATF Recommendation 29 (FIU Role & Responsibilities)
Egmont Group Guidelines on FIU Information Sharing
EU 6th AML Directive (6AMLD) on Financial Intelligence Functions
A financial institution (FI) is fined for failure to implement an effective AML program. Which consequences could the regulator impose on the bank's Chief AML Officer? (Select Three.)
Civil and Criminal Prosecution, Fines, and Imprisonment: The Chief AML Officer may face legal action, including both civil and criminal proceedings. This could result in fines and even imprisonment if found guilty of negligence or misconduct related to anti-money laundering compliance.
Ban from Employment: Regulators have the authority to ban individuals from working in the financial services industry if they are deemed unfit due to AML-related failures. Such a ban can significantly impact the individual's career prospects.
Recommend Termination of Employment: While the regulator cannot directly terminate employment, they can recommend that the financial institution (FI) take appropriate action, including termination, based on the Chief AML Officer's performance.
Anti-Money Laundering Specialist (the 6th edition) resources.
ACAMS AML Glossary (definitions of terms related to AML).1
ACAMS AML Foundations Certificate (overview of AML concepts and responsibilities).2
ComplyAdvantage: 6th Money Laundering Directive (6AMLD) (details on AML regulations and penalties).3
A customer's registered business activity is a domestic carpet cleaning company. Besides domestic receipts, there are incoming weekly transactions from an international reputable
auction house starting at 15,000 USD and averaging 30,000 USD. The matching cash outgoings amount to 90% of the incoming deposits to non-related individuals. Which is most
concerning for potential money laundering?
The customer's business activity as a domestic carpet cleaning company is not inherently suspicious, as it aligns with their registered business. However, the significant weekly transactions from an international reputable antique auction house raise red flags.
The sudden increase in the customer's initial international receipt from $15,000 USD to an average of $30,000 USD per transaction per week is also noteworthy. Such a substantial change warrants further scrutiny.
The fact that 90% of the incoming deposits are matched by cash outgoings to non-related individuals could indicate layering or structuring activities associated with money laundering.
Overall, the combination of large international transactions, increased receipts, and cash outflows to unrelated parties from an antique auction house is the most concerning aspect.
Anti-Money Laundering Specialist (the 6th edition) resources.
ACAMS AML Glossary (definitions of terms related to AML).1
ACAMS AML Foundations Certificate (overview of AML concepts and responsibilities).2
ComplyAdvantage: 6th Money Laundering Directive (6AMLD) (details on AML regulations and penalties).3
Which is the most severe consequence for a financial institution if the regulator finds it is in breach of AML regulatory obligations?
Non-compliance with AML regulatory obligations can have severe consequences for financial institutions. Among these, the most severe consequence is the loss of license. When a financial institution fails to meet AML requirements, regulators may revoke its license to operate. Losing the license effectively shuts down the institution's ability to conduct business, impacting its existence and operations significantly12.
1. Unit21 AML: 8 AML Penalties, Fines, and Sanctions + Examples You Should Avoid
2. Financial Crime Academy: Ensuring Compliance: The Power Of AML Regulatory Reporting
Findings from a regulatory examination report states that the job descriptions of personnel outside of the
compliance department do not include references to anti-money laundering responsibilities.
Which action should the firm take?
The other options are not sufficient or correct, because:
C . Sending an email to all staff stating that personnel must observe the AML policy is not sufficient, because it does not specify what the AML policy entails, or how it applies to different roles and functions. An email is also not a permanent or formal way of communicating AML responsibilities, and it may not reach all staff members or be taken seriously.
D . Replying that a description of AML responsibilities is included in the annual training is not sufficient, because it does not address the issue of the job descriptions, which should reflect the AML responsibilities of each position. Moreover, annual training may not be frequent or comprehensive enough to cover all aspects of AML compliance, and it may not be tailored to the specific needs and risks of each role or department.
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