A bank holds accounts for several different gatekeeper clients such as attorneys accountants and company formation agents II is conducting a periodic review of these accounts and updating their risk ratings.
Which two accounts should the bank consider to be at highest risk? Choose 2 answers

• A. A company formation agent that establishes private investment companies primarily for clients in Africa and Asia
• B. An attorney whose practice specializes in cases involving maritime law in the international shipping industry
• C. An accountant at a private accounting firm whose clients are large multinational agricultural corporations
• D. A notary in Latin America who specializes in assisting clients from other countries with high-end real estate transactions

In an attempt to ensure the selection of his bid for a government project in a foreign country Mr. Jones decided to pay off a foreign official who had the ability to influence the process Mr. Jones created a shell company to conduct the transaction.
In exchange for this influence Mr. Jones created a series of invoices that made it appear as if his shell company owed money to Ihe foreign official Mr. Jones wired money from his bank account in the US to the shell company in the foreign jurisdiction for credit to the government official Unfortunately for Mr. Jones, the official did not keep his promise and Jones did not gel the bid.
When did money laundering FIRST occurs?

• A. When Mr. Jones created the shell company
• B. When Mr. Jones generated a series of false invoices
• C. When Mr. Jones wired the funds to the shell company
• D. When Mr. Jones transferred funds from the shell company to the public official

As the head of compliance (or a multinational bank you are reviewing new data security policies to keep customer data secure Your customer base includes many important political figures in your home country and any breach of security would lead to a significant loss of business.
To be safe you want a secure and stringent data security program.
Which is the BEST option to include in your data security program?

• A. Require customers and employees to use two-factor authentication to log in
• B. Require customerstoconfirm via email or phone any transaction that exceeds $10,000
• C. Require customers to answer security questions for all transactions
• D. Require all customers and employees to use the same standardized revised security protocols

James Thieferlon has stolen Linda Victim's ATM card and PIN James withdrew a total of $10,000 from Linda's checking account over several transactions using several ATM machines James then created lake invoices on hisbrother'scompany stationary to make it appear as though he provided S15,000 of IT goods for his brother's import/export company. From there, he presented the invoices to his bank and deposited the stolen S10,000 with the legitimate S5,000 he made from selling personal goods on the Internet.
Which step could be considered money laundering?

• A. Smurfing committed by withdrawing the stolen $10,000 from several ATMs in small values
• B. Creating false invoices for his brother's import/export company
• C. Depositing the money into his own bank account with the legitimate $5,000
• D. Not openly declaring the $5,000 as Interne! sales revenue to be able to claim different taxes on them

A law enforcement agent is investigating a properly within her jurisdiction that she believes may have been purchased with the proceeds of an online Fraud scheme. The property in question is a luxury condominium in a high-end residentialcommunity in a large urban area. It does not appear to be currently occupied and the agent suspects the properly might be used to integrate the fraudster s illicit profits.
After reviewing the case notes collected to date in the investigation the agent determines that the properly was purchased in the name of a shell company formed in another jurisdiction known for a high degree of corporate secrecy The agent is seeking to identity the beneficial owner of the properly to tie its purchase back to the proceeds of the fraud scheme.
Which is Ihe BEST next step in her investigation to find sources ol information that could identify the property's beneficial owner?

• A. Subpoena all financial institutions in the property s surrounding area to determine it any helped facilitate the sale of the property
• B. Subpoena the title insurance agency that assisted with reviewing and underwriting the transfer ol the property's title
• C. Conduct physical surveillance on the property and surrounding area to determine who is living in the location
• D. Submit a mutual legal assistance treaty (MLAT) request to the authorities ol the jurisdiction where the shell company is located to ask for their help in the case