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NEW QUESTION 28
An institution has made the decision to exit a client relationship due to anti-money laundering concerns. Prior to starting the close out process, the institution receives a written request from a law enforcement agency to keep the account open. The client is the subject of an ongoing investigation and law enforcement wants the institution to continue to monitor the account and report any suspicious activity.
What is primary consideration the institution should keep in mind when deciding whether to agree to this request?

• A. The anticipated cost of complying with the law enforcement request
• B. The number of suspicious transaction reports previously filed on the client
• C. The fact that the institution has a solid record in complying with law enforcement requests
• D. Whether the institution can continue to meet its regulatory obligations with the accounts open

Answer: D

NEW QUESTION 29
What should senior management do in order to promote a culture of anti-money laundering compliance?

• A. They should attend all training sessions with front-line employment
• B. They should base employee compensation on the amount of suspicious activity they detect
• C. They should include compliance with AML procedures as condition of employment
• D. They should have close ties with the independent auditors of the AML program

Answer: C

NEW QUESTION 30
What was the topic the Wolfsberg Group's first guidance addressed?

• A. Merchant acquiring activities
• B. Enhanced due diligence for high risk customers
• C. Private banking
• D. AML training for financial institution staff

Answer: C

NEW QUESTION 31
In order to protect investigative materials from disclosure when conducting an internal Investigation of any employee of a financial institution, legal counsel of that financial should________?

• A. Not mark files or documents with privileged and Confidential: Attorney-Client Privilege and/or Work- Product. Those marks will only encourage law enforcement or opposing attorneys to seize those files
• B. Request formal company authorization to conduct the investigation. Such authorization should be granted, if possible, by the board of directors or audit committee
• C. Refuse to provide any records or documents to law enforcement because the bank has client privilege with its bank customers
• D. Let the bank hire any and all contract investigators to conduct the internal investigation. That way Legal is not a party to the action and may remain independent

Answer: B

NEW QUESTION 32
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