Which of the following is not a key component of a risk-based approach to AML?

• Identifying and assessing risks

• Applying enhanced due diligence to all customers equally

• Prioritizing resources based on identified risks

• Monitoring and adjusting risk profiles regularly

Answer explanation

Applying enhanced due diligence to all customers equally contradicts a risk-based approach, which focuses on tailoring due diligence based on the specific risks associated with each customer.

What is the primary purpose of the Suspicious Activity Report (SAR) that exchange house employees must file?

• To report large cash transactions over a certain threshold

• To provide regulators with information on tax evasion cases

• To alert authorities about suspected money laundering or terrorist financing

• To report operational risks within the accounting firm

Answer explanation

The primary purpose of the Suspicious Activity Report (SAR) is to alert authorities about suspected money laundering or terrorist financing, making it crucial for combating financial crimes.

Which of the following situations would not typically trigger a need to file a SAR?

• Multiple transactions below reporting thresholds that appear structured

• Unexplained third-party payments made to a client's account

• A client asks for advice on how to evade taxes

• A large one-off payment by a long-term client for a business loan repayment

Answer explanation

A large one-off payment by a long-term client for a business loan repayment typically does not raise suspicion, unlike the other options which indicate potential suspicious activity that would require a SAR.

Which of the following would most likely not be a red flag when reviewing a corporate structure?

• A complex ownership structure with multiple layers of shell companies

• A single beneficial owner with a history of low-risk business ventures

• A newly formed company with substantial incoming transactions

• Untraceable beneficial owners from offshore jurisdictions

Answer explanation

A single beneficial owner with a history of low-risk business ventures is less likely to raise concerns compared to complex structures or untraceable owners, making it a less significant red flag.

When assessing the risk of a customer based on their geographical location, which factor should be least relevant?

• The country’s level of corruption

• The country’s financial stability

• The country’s AML/CFT regulations

• The country’s tax laws

Answer explanation

The country’s tax laws are less relevant when assessing customer risk compared to corruption, financial stability, and AML/CFT regulations, which directly impact the risk of illicit activities.

If an exchange house employee discovers a client is involved in transactions linked to sanctioned individuals or entities, what is their primary obligation?

• Report the activity to the local tax authority

• File a report with the Financial Intelligence Unit (FIU)

• Terminate the client relationship immediately

• Notify the client of the issue and seek clarification

Answer explanation

The primary obligation of the accountant is to file a report with the Financial Intelligence Unit (FIU) when they discover transactions linked to sanctioned individuals or entities, as this is a legal requirement.

A “layering” stage in money laundering is primarily characterized by:

• Moving illicit funds into the financial system

• Separating illicit funds from their origins through complex transactions

• Introducing illicit funds into legitimate businesses

• Integrating illicit funds into the legitimate economy

Answer explanation

The layering stage in money laundering involves separating illicit funds from their origins through complex transactions, making it difficult to trace the money back to its illegal source.

Which of the following is not a recommended response when an exchange house employee detects possible money laundering activity?

• Conduct an internal review to verify suspicions

• Immediately inform the client of the discovery

• File a SAR with the relevant authority

• Maintain detailed documentation of the suspicious activity

Answer explanation

Informing the client immediately can compromise an investigation and alert them to potential scrutiny. Instead, accountants should conduct an internal review, file a SAR, and maintain documentation.

Which type of transaction is most commonly associated with smurfing in money laundering schemes?

• Transferring large sums of money through a single bank account

• Depositing multiple small amounts of cash into various bank accounts

• Transferring cryptocurrency to offshore accounts

• Using shell companies to purchase luxury assets

Answer explanation

Smurfing involves breaking down large amounts of money into smaller, less suspicious transactions. Depositing multiple small amounts into various bank accounts helps avoid detection, making this the most common method in money laundering.

Which of the following sectors are considered especially vulnerable to money laundering due to high levels of anonymity?

• Retail businesses

• Digital currency exchanges

• Construction companies

• Airlines and transportation services

Answer explanation

Digital currency exchanges are particularly vulnerable to money laundering due to their high levels of anonymity, making it easier for illicit activities to occur without detection.