According to the Second European Union Money Laundering Directive, what may knowledge of criminal conduct be inferred from?

A. Subjective, factual circumstances

B. Objective, factual circumstances

C. Objective, non-factual circumstances

D. Subjective, non-factual circumstances

A compliance officer at a small local bank reads in the newspaper that a high ranking local public official, who is a long-standing account holder, is being investigated by the competent authorities for accepting bribes. The compliance officer

immediately checks the official's account and new account the official opened at the bank a few weeks ago. The compliance officer's investigation of these accounts discloses that the official's long-standing account had no unusual activity

and that the recently opened had no activity since it was opened.

What should the compliance officer do next?

A. Wait until the new account receives funds and confirm their source

B. Call the competent authorities to assess the need to file a suspicious transaction report

C. Meet with staff who opened the account to understand its nature and purpose

D. Call the office to confirm the need for multiple accounts

The branch manager notices that a number of customers come in weekly and always use the same teller to process their deposits. The manager notices that the customers and the teller, who are from the same ethnic group, are speaking in a foreign language and every once in a while the customers from local ethnic restaurants will bring the teller lunch. The commercial customers that visit the teller generally deposit the same amount of cash each time they come in.

How should the branch manager respond to this activity?

A. Transfer the teller to another branch

B. Conduct further investigation before taking any other action

C. Encourage the teller to bring in more business from the ethnic community

D. Suggest to the teller to send the customers to other tellers to avoid the opportunity for collusion

A bank operates in multiple countries and offers a variety of products and services. The compliance officer recently joined the bank and wants to better understand the inherent level of anti-money laundering risk across the entire organization. Which two factors should be considered? (Choose two.)

A. The Transaction Monitoring program

B. The Customer Due Diligence program

C. Countries that the bank operates in

D. Products and services offered by the bank

What person or group is ultimately responsible for the institution's AML/CFT Program?

A. The AML audit committee

B. The AML/CFT Compliance Officer

C. The Chief Executive Officer (CEO)

D. The Board of Directors