An investigator receives an alert documenting a series of transactions. A limited liability corporation (LLC) wired 59.000,000 USD to an overseas account associated with a state-run oil company. A second account associated with the state-run oil company wired 600,000,000 USD to the LLC. The LLC then wired money to other accounts, a money brokerage firm, and real estate purchases.
The investigator initiated an enhanced KYC investigation on the LLC. The financial institution opened the LLC account a couple of weeks prior to the series of transactions. The names associated with the LLC had changed multiple times since the account opened. A search of those names revealed relations with multiple LLCs. Public records about the LLCs did not show any identifiable business activities.
Open-source research identified mixed reports about the brokerage firm. The firm indicated it purchased mutual funds for its clients and dispensed returns to clients.
Media reports claimed the firm laundered money by holding for a fee before returning it to investors.
The investigator discovers that the bank has no records pertaining to ownership of the LLC. What would this mean for the bank and/or investigator?

• A. The bank may not be able to file a SAR/STR without the ownership data.
• B. The bank is out of compliance with CIP regulations.
• C. The bank is out of compliance with beneficial ownership regulations.
• D. The bank cannot respond to law enforcement requests without the ownership data.

A U.S. financial institution (Fl) receives a grand jury subpoena for a corporate client's account. The Fl should:

• A. request the client's consent for the disclosure of account information.
• B. file a SAR/STR.
• C. provide the client with a copy of the subpoena.
• D. review the corporate account's activity and transactions.

A SAR/STR regarding money-mule activity prompts law enforcement action. Under U.S. law, the alleged money mules can be prosecuted:

• A. unless they can prove they were not aware of the origin of the funds.
• B. only if they were aware of their role and actively participated.
• C. in a country only if funds were transferred between accounts maintained in the same country.
• D. even if they were unaware that money was transferred.

Why is a more robust supervisory approach needed by regulators when overseeing small- and medium-sized money service businesses (MSBs) compared to larger MSBs for combatting terrorist financing (TF)?

• A. Small- and medium-sized MSBs are more at risk of allowing transactions linked to TF due to the lack of skilled compliance resources.
• B. Small- and medium-sized MSBs need to be targeted to ensure that competition in the industry remains constant and uniform.
• C. Small- and medium-sized MSBs are more likely to falsify records to appear less risky in order to keep the banking relationship.
• D. Small- and medium-sized MSBs need to be robustly supervised so the regulator can maintain visibility in combatting TF.

An investigator at a corporate bank is conducting transaction monitoring alerts clearance.
KYC profile background: An entity customer, doing business offshore in Hong Kong, established a banking business relationship with the bank in 2017 for deposit and loan purposes. It acts as an offshore investment holding company. The customer declared that the ongoing source of funds to this account comes from group-related companies.
* X is the UBO. and owns 97% shares of this entity customer;
* Y is the authorized signatory of this entity customer. This entity customer was previously the subject of a SAR/STR.
KYC PROFILE
Customer Name: AAA International Company. Ltd
Customer ID: 123456
Account Opened: June 2017
Last KYC review date: 15 Nov 2020
Country and Year of Incorporation: The British Virgin Islands, May 2017 AML risk level: High Account opening and purpose: Deposits, Loans, and Trade Finance Anticipated account activities: 1 to 5 transactions per year and around 1 million per transaction amount During the investigation, the investigator reviewed remittance transactions activities for the period from Jul
2019 to Sep 2021 and noted the following transactions pattern:
TRANSACTION JOURNAL
Review dates: from July 2019 to Sept 2021
For Hong Kong Dollars (HKD) currency:
Incoming transactions: 2 inward remittances of around 1.88 million HKD in total from different third parties Outgoing transactions: 24 outward remittances of around 9 4 million HKD in total to different third parties For United States Dollars (USD) currency:
Incoming transactions: 13 inward remittances of around 3.3 million USD in total from different third parties Outgoing transactions: 10 outward remittances of around 9.4 million USD in total to different third parties.
RFI Information and Supporting documents:
According to the RFI reply received on 26 May 2021, the customer provided the bank with the information below:
1J All incoming funds received in HKD & USD currencies were monies lent from non-customers of the bank.
Copies of loan agreements had been provided as supporting documents. All of the loan agreements were in the same format and all the lenders are engaged in trading business.
2) Some loan agreements were signed among four parties, including among lenders. borrower (the bank's customer), guarantor, and guardian with supplemental agreements, which stated that the customer, as a borrower, who failed to repay the loan Which additional information would support escalating this account for closure?

• A. A follow-up request reveals that the account receives funds from loans, collects payments from group-related companies, and sends the payments to the lenders.
• B. A review of outward remittances reveals the same pattern of several simple steps for each transaction,
• C. The bank files SARs/STRs indicating that Y opened accounts for small companies located in close proximity to the bank.
• D. A review of X's personal bank account shows that X received wire transfers that aggregate the amounts transferred to the group-related companies.