Under the USA PATRIOT Act, in which scenario would the US not have jurisdiction?

• A.US bank subsidiaries located in foreign jurisdictions
• B.Foreign branch of a bank located in the US
• C.Foreign bank with a US correspondent account
• D.Shell banks operating in foreign jurisdictions

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A startup virtual currency exchange has registered as a money services business and will commence operations in six months. The company will provide digital wallets to customers to hold their virtual currency after purchase. Customers will have the option to conduct purchases of the virtual currency and transfer the currency to and from the digital wallet. The startup must develop an anti-money laundering compliance program prior to launch.
Which two anti-money laundering responsibilities should be considered before business launch? (Choose two.)

• A.A customer onboarding process
• B.Employees to handle complaints in a timely fashion
• C.Transaction limits consistent with risk appetite
• D.Mechanisms to monitor and protect customers' digital wallets from cyber-attacks

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What does the Financial Action Task Force (FATF) urge its members and all other jurisdictions to do when a jurisdiction is identified as having lax anti-money laundering / counter financing of terrorism controls?

• A.Consider customers from that jurisdiction as high risk
• B.Cease doing business with that jurisdiction immediately
• C.Apply economic sanctions until otherwise notified by FATF
• D.Apply counter-measures to that jurisdiction

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Which statements regarding the USA PATRIOT ACT best describe key aspects that have extraterritorial reach? (Choose three.)

• A.It allows for the US Attorney General to subpoena records from a foreign bank with US correspondent accounts, including those that are located outside the US.
• B.It allows foreign banks to voluntarily designate a registered agent in the US to accept service of subpoenas.
• C.It allows the Secretary of the Treasury to order a US financial institution (FI) to close a correspondent account when a subpoena has not been responded by a foreign bank in a timely manner.
• D.It obliges the government to trace the origin of the funds when a seizure of assets occurs in a correspondent account that has been opened and maintained for a foreign bank in the US.
• E.It excludes as foreign FIs businesses that would be considered broker-dealers, money transmitters, and currency exchangers.
• F.It allows federal banking supervisors to require records of the identity of the owners of a foreign bank from a Fl operating in the US.

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A bank has maintained an account for a European charity for several years. The charity provides clothing to persons in need in various countries with active terrorists' cells.
Which action by the charity indicates possible terrorist financing?

• A.The charity frequently withdraws cash from the bank
• B.The charity has branch locations located in various countries
• C.The charity receives cash donations primarily from European countries
• D.The charity maintains a bank account for non-business-related expenses

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