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1. 一位審查貿易融資交易的分析師注意到,相同規格和數量的商品價格在 12 個月內上漲了 25%。分析師應該採取什麼行動?
A) 製作一份調查報告,找到證據來證實分析師的懷疑並提交 SAR/STR。
B) 為客戶產生更新的盡職調查記錄,以便加強監控。
C) 產生描述明顯的貿易洗錢行為的 SAR/STR 並提交給金融調查部門 (FIU)。
D) 製作一份調查報告,考慮客戶活動和可能合法影響交易成本的因素。
2. 銀行內部誰負有最終責任,確保銀行擁有全面有效的銀行保密法/反洗錢 (BSA/AML) 計劃以及合理設計的監督框架,以確保遵守適用的法規?
A) 高階管理層
B) BSA/AML 合規官
C) 董事會
D) 業務線經理
3. 來自高風險國家(根據歐盟高風險管轄區名單)的富人的代理人聯繫歐盟國家的公證人,透過離岸公司處理最近在拍賣會上獲得的資產。代理人持有另一個歐盟國家律師事務所的授權委託書。轉讓價格明顯低於拍賣價,但代理商拒絕解釋差異原因。
公證人應該考慮哪些危險訊號? (選兩個。)
A) 該授權書是由交易發生地點以外的另一個歐盟國家的律師事務所簽發的。
B) 透過拍賣所得的資產被放到離岸公司的名下。
C) 代理人代表居住在高風險管轄區的個人行事。
D) 代理商要求以低於最近收購的價格處置資產。
4. 下列何者是非政府組織 (NGO) 打擊洗錢的常用策略?
A) 幫助金融情報機構(FIU)分析可疑活動報告(SAR)
B) 向政府提供財政援助以加強其反洗錢工作
C) 直接在法庭上起訴洗錢者
D) 提高對洗錢問題及其後果的認識
5. 金融實體因違反反洗錢法可能面臨哪些聲譽風險後果?
A) 罰款
B) 監控行為的審核成本增加
C) 扣押資產
D) 失去知名客戶
Solutions:
| Question # 1 Answer: D | Question # 2 Answer: C | Question # 3 Answer: C,D | Question # 4 Answer: D | Question # 5 Answer: A |
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