A U.S. citizen opens an account in an offshore bank in a country that has a bilateral Model II FATCA agreement with an initial deposit of $10,000. USD Over the course of time the kinds in the account exceed
$60,000 USD.
Which obligation under FATCA applies?

• A. None the bank may accept Ihe deposited funds and is under no further obligation than to follow applicable local law
• B. The bank is required to report U.S. account holders to the U.S. Internal Revenue Service
• C. The bank is requiredtofile a Suspicious Activity Report or Suspicious Transaction Report (SAR or STR)
• D. The bank would be subject to a mandatory withholding tax on income Irom U S financial assets it holds

Mr. Johnson, a compliance officer at ABC Corporation, is conducting due diligence on a potential business partner based in a foreign country. During the due diligence process, Mr. Johnson discovers that the potential partner's principal shareholder is a politically exposed person (PEP) from a country subject to OFAC sanctions. What is the most appropriate action for Mr. Johnson to take?

• A. Proceed with the business partnership but disclose the involvement of the PEP to OFAC.
• B. Proceed with the business partnership but conduct enhanced monitoring of transactions involving the PEP.
• C. Seek guidance from OFAC on the permissibility of engaging with the potential partner.
• D. Reject the business partnership due to the involvement of a PEP from a sanctioned country.

You were recently hired as a new sanction's analyst for a large international bank in your introductory training you were told the bank generally prefers to avoid doing business with jurisdictions on U.S. sanctions lists, but has supported transactions under "specific' and "general licenses".
In your day-to-day job you find a certain business line seems to be conducting transactions with companies in sanctioned countries and these transactions are flagged by your sanction's filters more than others When you researched the companies you found the transactions were not covered under a general or specific license When you raised this issue with the division's business line manager, he said it "was a mistake".
A week later, you saw a transaction to a company with nearly the same name except shortened and slightly altered. The transaction amount is the same but there was no mention of the sanctioned jurisdiction. The business line manager assured you it was a different company m non-sanctioned country Which is the MOST appropriate next step for you to take?

• A. inform your superiors that due to conflicting information both companies should be the subject of a Suspicious Activity Report (SAR)
• B. Close the case because the original alerts were false positives The country is not on a U.S. sanctions list
• C. inform your superiors that some business lines may be stripping transaction details and dealing with entities or regions on U.S. sanctions
• D. Update your sanctions filter parameters lo note that the new company with the similar name has been internally white-listed

Your bank has recently been targeted by cyber attackers who have compromised the institutions network and stolen some customers online account credentials to conduct account takeovers.
Your team is responsible for reporting the incident to law enforcement and regulatory authorities which includes filing Suspicious Activity or Transaction Reports (SAR/STR) You are reviewing accounts that are thought to have been affected to determine if reporting is needed.
Which of the findings below would MOST likely trigger a SAR/STR report?

• A. A customer's account has not displayed any transaction activity in more than a month
• B. An account received a fairly large cash deposit shortly before the cyber incident started
• C. An account has recently initiated a series of funds transfers to previously unknown recipients
• D. An account displays several withdrawals from ATMs within the past three days

A real estate developer secured a $9.5 million construction loan from the Bank of China for a high-rise office building When the developer declared bankruptcy. The bank realized that this had become a problem loan and they began to investigate the borrower.
The developer had submitted False invoices for work that was never performed In addition, a portion of the loan money was deposited into the construction business account to pay subcontractor invoices. These invoices were never paid instead the money was diverted into private bank accounts owned by the developer and his family members.
Which type of financial crime did the forensic audit uncover?

• A. Money laundering
• B. Sanctions violations
• C. Unlicensed money transmission
• D. Pump and dump