ML
a. Customer Acceptance Policy
b. Customer identification Procedures;
c. Monitoring of Transactions
These are key elements of what?
Know Your Customer (KYC)
What is a remedy for aggrieved persons subject of the Targeted Financial Sanction?
Apply lifting of freeze order with the AMLC on Account of mistaken identity
What should you do in case of a target match is an existing account?
Freeze account without delay
Disclosing to the customer that an investigation is being contemplated on the customer’s account is considered as:
Tipping off
Ms. X, a valued client of ABC Savings Bank comes into the Branch for three (3) consecutive weeks and made deposits of large amount of case. This kind of transaction deviates from the client’s past and normal business practices.
Update Customer information and collect all supporting documents
If an AMLC agent phoned the covered person requesting for information and transaction records of a customer to help with an ongoing money laundering investigation, the covered person must:
Request that the AMLC agent should formalize the request by sending a letter request addressed to the Senior Management of the Bank.
Client A deposited to his bank account large amount of money obtained from unlawful activities. The next day, he withdrawn the same to make it appear came from legitimate source. The above activity is called?
Money Laundering
When will the Bank unfreeze the account subject to sanction freeze order?
Upon receipt of AMLC unfreeze order
What component is the most important element in the prevention of money laundering?
The People within the Covered Person
A walk-in customer, Mr. Lim visited the Strong Bank - ABC Branch. He handed to the Authorized Bank Personnel a bag of cash and asked that a company account be opened and the money be deposited into the company’s newly opened account. What is the most appropriate course of action by the Authorized Bank Personnel?
a. Refuse Mr. Li’s request as the circumstances is suspicious.
b. Proceed with the business and conduct due diligence (CDD) on Mr. Lim, the corporate vehicle and its beneficial owners prior to opening of account
c. Proceed with the business but get permission from the Bank’s Senior Management
b. Proceed with the business and conduct due diligence (CDD) on Mr. Lim, the corporate vehicle and its beneficial owners prior to opening of account
12. However, when Mr. Lim was asked to provide supporting document on trading business, the customer could not provide at the moment. What should you do if you cannot complete Customer Due Diligence?
a. Go on with the opening of account, without asking for the document
b. Do not open account, the customer must submit supporting document
c. Go on with opening, with promise of customer to submit document
b. Do not open account, the customer must submit supporting document
Strong Bank received a deposit of P600,000 from Mr. X in a single transaction. Is Strong Bank required to report the deposit to the AMLC?
a. Yes, since there is no probable cause that the money came from predicate crimes under AMLA
b. No, since Mr. X has not yet been accused of a crime enumerated under the AMLA
c. Yes, since the amount exceeded P500,000
d. No, since Mr. X has not yet been convicted of a crime enumerated under the AMLA
Yes, since the amount exceeded P500,000
a. Transactions having no conformity with the initial purpose of account opening;
b. Unreasonable behaviors of the relevant customer when conducting a transaction (nervous, rushed, unconfident, etc.)
c. Cash transactions conducted in an unusual amount; relatively small amount but with high frequency
The ff. are considered as what?
STR triggers
Mr. See, one of valued clients of the Bank, referred a prospective client MAHANGIN COMPANY. After conducting customer due diligence on said the company, you found out that one of their beneficial owners has a positive match in the Bank’s internal Sanction List – under SEC Advisory on illegal solicitation of investments. What is the most appropriate course of action?
a. Request for additional documents and proceed with the account opening
b. Do not proceed with the account opening and escalate to the AML Compliance Officer for filing of suspicious transaction report
c. Request for the Senior Management’s approval and proceed with the account opening
b. Do not proceed with the account opening and escalate to the AML Compliance Officer for filing of suspicious transaction report
States that no administrative, criminal or civil proceedings shall lie against any person for having made a covered transaction or suspicious transaction report in the regular performance of his duties and in good faith, whether or not such reporting results in any criminal prosecution under the AMLA or any other Philippine law.
Safe Harbor Provision