A compliance officer is tasked with implementing an enterprise-wide anti-money laundering program for a bank, which operates in multiple countries. Not all the bank products and services are available in all countries. Which three factors should be considered as part of the approach? (Choose three.)
Correct Answer: B,D,E
Question 247
How do payable through accounts (PTAs) differ from normal foreign correspondent accounts?
Correct Answer: A
Explanation Explanation/Reference: Payable-Through, Pass Through, and Pass-By Accounts | Definitions and Summary A payable-through account (PTA) is also referred to as a pass through account or a pass-by account. These types of accounts are offered by US financial institutions as banking products and are used by foreign financial firms to provide their customers with access to the US financial system. A payable-through account (PTA) is a demand deposit account through which banking agencies located in the United States extend cheque writing privileges to the customers of other institutions, often foreign banks. PTA accounts are a concern to bank regulators because the banks or agencies providing the accounts may not subject the end customers to the same level of scrutiny as they would their own customers. These concerns were addressed in Title 3A, especially Section 311(b)(4), of the Patriot Act. Foreign financial institutions use PTAs, also known as "pass-through" or "pass-by" accounts, to provide their customers with access to the U.S. banking system. Some U.S. banks, Edge and agreement corporations, and U.S. branches and agencies of foreign financial institutions (collectively referred to as U.S. banks) offer these accounts as a service to foreign financial institutions. Law enforcement authorities have stated that the risk of money laundering and other illicit activities is higher in PTAs that are not adequately controlled. What is the difference between a regular correspondent bank account and a "payable-through, pass through, or pass-by account"? With a payable-through, pass through or pass-by account, a foreign financial firm is able to create a corresponding account in the US. However, the foreign bank also provides checks to its foreign customers who might be interested in conducting US transactions. These foreign customers are then able to write checks to withdraw from or make deposits into the account. In general, these foreign customers of a foreign bank are not subject to anti-money laundering screening, but they end up having full access to the US financial system. Higher Money Laundering Risk Based on their nature, payable-through, pass through, and pass-by accounts are considered as posing higher money laundering risk concerns. Risk Factors PTAs may be prone to higher risk because U.S. banks do not typically implement the same due diligence requirements for PTAs that they require of domestic customers who want to open checking and other accounts. For example, some U.S. banks merely request a copy of signature cards completed by the payable through customers (the customer of the foreign financial institution). These U.S. banks then process thousands of sub- accountholder checks and other transactions, including currency deposits, through the foreign financial institution's PTA. In most cases, little or no independent effort is expended to obtain or confirm information about the individual and business subaccountholders that use the PTAs. Foreign financial institutions' use of PTAs, coupled with inadequate oversight by U.S. banks, may facilitate unsound banking practices, including money laundering and related criminal activities. The potential for facilitating money laundering or terrorist financing, OFAC violations, and other serious crimes increases when a U.S. bank is unable to identify and adequately understand the transactions of the ultimate users (all or most of whom are outside of the United States) of its account with a foreign correspondent. PTAs used for illegal purposes can cause banks serious financial losses in criminal and civil fines and penalties, seizure or forfeiture of collateral, and reputation damage.
Question 248
While all employees need AML awareness training, which three groups within the institution should receive targeted AML training? Choose 3 answers
Correct Answer: A,C,D
Question 249
What might limit a compliance officer's ability to respond to a foreign law enforcement official's request to provide information with regard to an anti-money laundering investigation?
Correct Answer: A
Question 250
Following a recent exercise which explained how a correspondent banking operation could be used by money launderers, an anti-money laundering specialist decided to re-write the due diligence procedures for entering into agreements with foreign financial institutions. Which of the following information should be included to establish a rigorous "Know Your Respondent" procedure?
