ACAMS General Practice 3

Question 1

Under the FinCEN Customer Due Diligence rule, which of the following must be identified for legal entity customers opening accounts at covered financial institutions?

Accepted Answer

Beneficial owners who own 25% or more and a single person with significant control

Answer

FinCEN's CDD rule requires identifying beneficial owners at a 25% ownership threshold plus one control person with significant managerial authority.

Question 2

Which red flag is most associated with trade-based money laundering (TBML)?

Accepted Answer

Over- or under-invoicing of goods and services in international trade transactions

Answer

TBML often involves manipulating trade invoice values to transfer value across borders, making over- or under-invoicing a key red flag.

Question 3

An AML officer discovers that a compliance program has not been updated since 2019 and lacks risk-based controls. What is the most immediate priority?

Accepted Answer

Conduct a gap analysis and present findings to senior management for remediation

Answer

Conducting a gap analysis and escalating to senior management is the appropriate first step to begin systematic remediation of compliance program deficiencies.

Question 4

Under OFAC regulations, what does 'blocking' a transaction mean?

Accepted Answer

Freezing assets or funds associated with sanctioned parties so they cannot be moved

Answer

Blocking under OFAC means freezing assets or transactions involving sanctioned persons or entities so they cannot be transferred, withdrawn, or used.

Question 5

Which of the following is the most effective method for identifying money laundering in correspondent banking relationships?

Accepted Answer

Conducting due diligence on the respondent bank's AML program and monitoring nested accounts

Answer

Correspondent banks must assess the respondent bank's AML controls and monitor for nested accounts where third parties gain indirect access to the correspondent's services.

(ACAMS) Association of Certified Anti-Money Laundering Specialists Practice Test

(ACAMS) Association of Certified Anti-Money Laundering Specialists Practice Test

ACAMS General Practice 3