Which of the options below is an indicator of potential insider activity that may warrant escalation For further investigation?

• A.An investigator does not complete the automated transaction monitoring system alerts assigned to them before the time required by company procedures.
• B.A relationship manager advocates for overriding the results of the company's client risk rating model that resulted in a client's high-risk rating.
• C.A relationship manager makes an exception to company policy and proceeds with onboarding a customer without documenting a passport for customer identification
• D.An If employee shares information about a firm's risk management framework with employees of other firms at an industry convention.

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A compliance officer is completing a case and has determined that the events do not merit filing a suspicious activity report (SAR).
Which of the following should be included in the case notes to justify not filing a SAR? (Choose two.)

• A.Who made the decision not to file the SAR
• B.Why the officer deemed that the case did not merit filing a SAR
• C.How much money was involved in the case
• D.How the money flowed through the institution
• E.When the unusual activity occurred

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A compliance officer is developing management reporting information to provide leadership with insights into the financial crime risk related to an institution's customer population.
Which of the following is a key risk indicator to include in the reporting to allow leadership to monitor whether there are any key changes to the inherent risk of the customer population? (Choose two.)

• A.Percentage of regulatory reports for high-risk customers not completed within the required regulatory deadlines
• B.Percentage change of transaction monitoring alerts escalated for investigation compared to the previous quarter
• C.Percentage of customers for whom onboarding verification was not completed within KYC policy service-level agreement (SLA) requirements
• D.Number and percentage of senior politically exposed persons (PEPs) who were onboarded in the past quarter compared to all active customers

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Which of the following laws or regulations can impact the application of AML/CFT programs and require financial institutions (r" Is) to balance multiple compliance requirements?

• A.Consumer protection laws may intersect will) AML/CFT requirements when handling customer complaints or disputes, potentially affecting how FIs implement their compliance programs.
• B.Data privacy laws can restrict the sharing of customer information, while financial inclusion initiatives require FIs to avoid excessive de-risking that could exclude vulnerable populations.
• C.AML/CFT laws are the primary focus for FIs, and other regulations like data privacy and consumer protection may only indirectly influence their compliance obligations
• D.Environmental, social, and governance (ESG) frameworks can influence a Fl's risk management strategies but are generally considered separate from core AML/CFT compliance requirements

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An internal audit team is reviewing the anti-financial crime (AFC) program of its firm.
Which of the following attributes of the third line of defense would be most critical to ensure unbiased and effective oversight?

• A.Consistency of approach
• B.Periodic training of the function
• C.Qualification of the team
• D.Independent testing

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