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In a large US bank, an individual leads a team in charge of overseeing the governance and effectiveness of the bank's transaction monitoring approach.
Which strategies should the team implement? (Select Two.)
A. Periodic and ad hoc cooperation with the legal team to appropriately investigate and monitor the transactions of subjects of subpoenas or government inquiries
B. Periodic review of suspicious activity reports (SARs) filed with FinCEN to determine whether any should be withdrawn
C. Periodic review of client profiles to ensure that the most up-to-date information is on file for high-risk clients in line with the bank's internal policies and procedures
D. Periodic review of the transaction monitoring scenarios and their productivity to ensure that appropriate AML typologies are reflected
Answer: C,D
Explanation:
Effective oversight of transaction monitoring includes:
* Periodic review of client profiles to ensure up-to-date information for high-risk clients (B):"Reviewing and updating customer profiles is essential to ensure that monitoring scenarios are based on current risk data."(CAMS 6th Edition, Transaction Monitoring and Customer Due Diligence)
* Periodic review of transaction monitoring scenarios and productivity to ensure appropriate AML typologies are reflected (D):"Firms should periodically review the parameters and output of transaction monitoring systems to ensure they continue to identify relevant ML/TF risks and typologies."(CAMS
6th Edition, Monitoring and Surveillance)
Incorrect Options:
* A: Cooperation with the legal team is important, but not a core strategy for monitoring governance.
* C: SARs filed with FinCEN should not be withdrawn unless new evidence requires it; review should focus on process, not withdrawal.
References:
CAMS 6th Edition, Transaction Monitoring
FFIEC BSA/AML Manual, Transaction Monitoring Section
NEW QUESTION # 147
Which of the following can be considered a reliable, independent source document, data, or information?
A. Information obtained directly from a government-managed registry
B. Information provided by a prospective customer
C. Information obtained from an open-source database
D. Photocopy of a copy of a government-issued identity document
Answer: A
Explanation:
Information obtained directly from a government-managed registry is considered a reliable, independent source because it is authoritative, verified, and maintained by an official source, reducing the risk of inaccuracies or manipulation.
NEW QUESTION # 148
Challenges in the implementation of new technologies for AML/CFT include: (Select Four.)
A. enhanced due diligence (EDD) policies.
B. complexity.
C. the Travel Rule.
D. regulatory.
E. data quality.
F. data privacy.
Answer: B,C,E,F
Explanation:
Key challenges in adopting new AML/CFT technologies are:
* A: Data privacy-new tech often requires processing more personal data, raising privacy/regulatory concerns.
* C: The Travel Rule-meeting global standards for information sharing in payments is a technology challenge.
* D: Data quality-effective systems rely on accurate, comprehensive, timely data.
* E: Complexity-integrating and managing new technology can increase operational complexity.
(CAMS 6th Edition, Technology in AML/CFT; FATF Guidance on Digital ID and Fintech) References:
CAMS 6th Edition, AML/CFT Technology and Implementation Challenges
FATF, "Opportunities and Challenges of New Technologies for AML/CFT" (2021)
NEW QUESTION # 149
What key element contributes to the effectiveness of AML training programs'?
A. In-person training sessions
B. Comprehensive content with engaging delivery methods
C. Comprehensive curriculum delivered by senior management
D. Generalized content designed to apply to a broad audience
Answer: B
Explanation:
The effectiveness of AML training programs depends on comprehensive content that covers relevant regulatory, risk, and procedural topics, combined with engaging delivery methods that promote retention and practical application by participants.
NEW QUESTION # 150
Unusual wire transfer transactions can include: (Choose two.)
A. an incoming wire transfer followed by the loan payment to a third party that is a business associate of the client.
B. an incoming third-party wire transfer followed by the purchase of real estate in the client's name.
C. wire transfers in different currencies between accounts held at different banks for the same client.
D. multiple wire transfers sent to counterparties associated with the client as per KYC documentation.
Answer: B,C
Explanation:
Unusual wire transfer transactions may include transfers in different currencies between accounts at different banks for the same client, which can be used to obscure fund flows, and incoming third-party transfers followed by real estate purchases, which may indicate layering and integration stages of money laundering.
These patterns deviate from typical financial behavior and warrant closer scrutiny.
NEW QUESTION # 151
......
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