Alerts
Cases/SARs
Guidance
Score
ACAMS
100
What is the process for handling employee accounts?
See FIU Job Aid for Handling Employee Accounts: Refer the employee account with no unusual activity to ETIM Send an email to IASPViolations with the Subject line “FIU Team Employee Account Review”. Copy the FIU Team and Department Managers. Include the account number. State that an employee account was reviewed but no unusual activity was identified.
100
From where should subject demographic information listed in Part I of the SAR form be sourced?
For customers and authorized users, demographic information should be obtained from internal source systems. For non-customer subjects, demographic information should be obtained from internal source systems and LexisNexis or Clear.
100
What should be listed in a blueprint or case notes for our customer, Joe Smith, who has a criminal charge related to drug paraphernalia from 1994?
The blueprint/case notes should indicate that this charge is not relevant to our investigation due to the nature of the crime and age of the crime
100
What is the appropriate QMS score when alerted transactions are not included in the scope of review and are not addressed in the analysis?
Non-compliant
100
What is the acronym for the name of this 2001 law -"Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001
USA Patriot ACT
200
What do you do when an AB has blank demographic information in one system, but the information is populated in another system?
There is no longer a requirement to address the blank demographic information as a discrepancy. It is still a best practice for the blank information to be forwarded to Marcus Elliott for record keeping, but this will not be documented as a QC Defect (Noncomp or CompEdit).
200
For Cases or SARs, Is it required to capture all phone numbers from Atlas or just the default phone number from the home screen?
If the phone number is mentioned in the narrative or case notes, there should be a screenshot to corroborate it. If there is no mention of the phone number and no screenshot this is okay
200
Who is your favorite QC manager?
You better pick your manager!
200
What is the appropriate QMS score when internal discrepancies are not mentioned by the associate or investigator and are not reported to Marcus?
Compliant with Edits
200
This financial institution, featured in the recent Bryan Cranston movie "The Infiltrator" was heavily involved in laundering the drug proceeds of Pablo Escobar
Bank of Credit and Commerce International
300
How should alerts with confirmed marijuana-related businesses be dispositioned?
If it can be confirmed that a business is a marijuana business (registered or unregistered) the Alert/Case should be escalated and the owner accounts should be closed
300
What box should be checked for Balance Transfer Checks in Part II of the SAR form?
Bank/Cashier's Check
300
What are the factors for which a case becomes significant?
Dollar amount ($500K), negative news that poses a reputational risk, TF and other high-risk typologies, OFAC hits, customer is a PEP, Ten customers and/or ABs identified as subjects.
300
What is the appropriate QMS score when an internal discrepancy was addressed in the blueprint or case notes and an email was not forwarded to Marcus
This should be scored as a Comp-FYI
300
What are the four pillars of an adequate AML program?
(1) A system of internal controls to ensure ongoing compliance (2) Independent testing of BSA compliance (3) A specifically designated person or persons responsible for managing BSA compliance (4) Training for appropriate personnel.
400
What are the dirtstring requirements for trusts and trustees?
If the client is a trust, and the trustee name is within the trust, only the trustee name would require a google dirt-string. If the Trust name does not include the trustee name, then a Google dirt string should be conducted on the trust name as well as the trustee.
400
What must be true for a continuing activity review to result in a No SAR decision?
The continuing activity has stopped or the suspicion regarding the activity has been mitigated appropriately.
400
What does OFAC stand for?
The Office of Foreign Assets Control
400
What is the appropriate QMS score if the scope of review should begin on 2/2 and the associate began their review on 2/1?
This should be compliant. Expanding the scope by one day has no material impact on the alert review and poses no risk as all of the alerted transactions would still be reviewed.
400
This informal value transfer system dates back to 800 a.d. and works by allowing individuals to transfer money without the transfer of physical currency or a promissory
Hawala
500
A Canadian restaurant opens a branch in Scottsdale, Arizona. Business is slower in the summer than in the winter as the tourist rate increases in Arizona in the winter. If you banked this restaurant, which of the following would be a red flag for you? 1.) The restaurant performs several deposits per day, some via teller and some via ATM 2.) The restaurant sends and receives wires to a Canadian bank 3.) The restaurant has consistent deposits week over week 4.) The account receives ACH deposits from a company that furnishes ATMs to businesses
3.) The restaurant has consistent deposits week over week
500
Under what circumstances would a branch be listed in Part IV of the form?
This section will not be used unless the suspicious activity physically occurred at the Discover branch.
500
Which of the following statements are true about PEPs? A- PEPs provide access to third parties on whom the financial institution has not conducted sufficient due diligence B- PEPs have significantly greater exposure to the politically corrupt funds, including accepting bribes or misappropriating government funds. C- PEPs are foreign customers who inherently present additional risk as they are engaged in cross-border transactions. D- PEPs generally do not pose enhanced risks to an institution due to their political standing; rather, PEPS increase the prestige of an institution.
B- PEPs have significantly greater exposure to the politically corrupt funds, including accepting bribes or misappropriating government funds.
500
What is the appropriate QMS score if the Discover TIN is missing from the accounts section on Part I of the form?
Compliant with Edits
500
Which three of the following are reasons that Prepaid cards are attractive to money launderers 1- anonymity 2- available in large denominations 3- widely accepted at merchants 4- can be used at International ATMs
1- anonymity 2- available in large denominations 4- can be used at International ATMs