Questions

Question No 1:
What is an advantage of having an outside counsel perform an internal investigation on behalf of the financial institution?
A. The outside counsel can bring an impartial and legal perspective to the review.
B. The outside counsel can intimidate the employees into confessing complicity with the wrongdoers.
C. The outside counsel can create an attorney-client privilege not just vis vis the bank, but also in connection with each
employee.
D. The outside counsel will be able to convince the prosecutors not to take any action against the institution.
Answer: A

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Question No 2:
What are the three classic gateways for international cooperation and sharing?
A. Mutual Legal Assistance Treaties (MLATs).
B. Law enforcement use grand jury subpoenas.
C. Exchange of information between Financial Intelligence Units (FIUs).
D. Exchange of information between supervisory agencies.
Answer: A, C, D

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Question No 3:
What are three of the recommended ways to respond to a law enforcement inquiry?
A. Cooperate with the law enforcement inquiry as much as possible.
B. Respond to all formal requests for information as promptly and thoroughly as possible, unless there is a valid objection that
can and should be made.
C. Ensure that all communication, written and oral, is funneled through a centralized place.
D. Guard against unwarranted publicity by resisting all inquiries and requests whenever possible.
Answer: A, B, C

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Question No 4:
What three steps should be taken when there is a criminal investigation that is targeting the bank itself?
A. The senior management and the Board of Directors should be notified and kept apprised of the progress of the investigation.
B. The bank should consider retaining experienced outside counsel to assist the bank in responding to the investigation.
C. The bank should immediately go to the media and explain why it has done nothing wrong.
D. The relevant employees of the bank should be notified of the existence of the investigation and should be given instructions
as to what to do and how to act.
Answer: A, B, D

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Question No 5:
When a financial institution is responding to a formal criminal investigation by a law enforcement agency, what is the primary
purpose of requiring information going through a central point within the institution?
A. To be able to ensure that nothing damaging to the financial institution gets released.
B. To ensure that responses are timely and thorough and that privileged material is not inadvertently handed over.
C. To ensure that the employees of the institution do not divulge information that would breach the privacy rights of customers.
D. To ensure that there is one person who can adequately and thoroughly apprise the Board of Directors of the progress of the
investigation.
Answer: B

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Question No 6:
When a financial institution is served with a search warrant by a law enforcement agency, what are three things that the
employees of the institution should do?
A. They should not release any documents until the institution's outside counsel arrives on the scene.
B. They should cooperate fully with the law enforcement agents and remain calm and polite.
C. They should try to obtain an inventory of the materials that the law enforcement agents take from the institution.
D. They should review the warrant to determine its scope.
Answer: B, C, D

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Question No 7:
When should a financial institution consider retaining an experienced outside counsel to assist it?
A. Whenever the institution receives a subpoena from any law enforcement agency.
B. When the institution itself appears to be the target of a criminal investigation.
C. When law enforcement appears to be focused on the accounts of a very good and long-standing customer of the institution.
D. When the banking agencies criticize the adequacy of the institution's AML monitoring procedures.
Answer: B

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Question No 8:
When should a compliance officer recommend that a financial institution conduct an internal investigation? Choose three out
of four.
A. When there is a suspicion that an employee is conspiring with a long-term customer to launder money through the bank.
B. When a series of customers open separate accounts at different branches, but with the same contact information.
C. When the bank's regulatory agency gives the bank low marks with regard to its AML compliance efforts.
D. When a long term employee decides to take only intermittent vacation days, but not two weeks in a row, per bank policy.
Answer: A, B, D

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Question No 9:
What are three practical tips in interviewing employees with regard to an unusual or suspicious transaction that they have
witnessed?
A. One should interview the employees as soon after the occurrence as possible in order to ensure that their memories are
fresh.
B. One should try to put the employees at ease during the interview and start with relatively easy, non- controversial, questions
before getting into more sensitive matters.
C. One should use open-ended questions for the employees in order to ensure that the questions do not dictate what the
expected answer is.
D. One should control the interview as much as possible in order to attempt to resolve the matter quickly and uncover the
wrongdoer.

Answer: A, B, C

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Question No 10:
With regard to exchanges of information between FIUs of different countries, what are three controlling principles?
A. That sharing between FIUs be permitted only if the central banks are also a party to the sharing.
B. That the sharing of information should be done as freely as possible on the basis of reciprocity.
C. That the sharing should be on the basis of requests and also spontaneously.
D. That differences in the definition of offenses should not impede the free exchange of information.
Answer: B, C, D

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