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Self Assessment C.
1. Complete the Questions
The 40 questions that follow must be answered before submitting your assessment, there is
ONE
correct answer per question. You are required to achieve a
pass rate of 80%.
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3.
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Q1
What is money laundering?
1. The process by which criminals attempt to hide and disguise their criminal money
2. A modern-day term for fencing stolen goods
3. The process by which criminals attempt to hide and disguise their criminal assets
4. The process by which criminal attempt to hide and convert their criminal cash
Q2
What is the purpose of money laundering?
1. To allow criminals to use their criminally derived assets without fear of detection and prosecution and confiscation
2. To make criminal money clean before it enters the economy
3. To avoid non-legal tender from flooding the financial markets
4. To allow a criminal to buy a piece of art without having to explain their source of wealth
Q3
What is terrorist financing?
1. The funding or financing of acts of terrorism and any costs associated to such
2. Providing financial assistance in support of the prevention of terrorism
3. Providing financial assistance to the victims and families of terrorist attacks
4. Evading international sanctions orders
Q4
Can works of art be used to launder money or fund terrorism?
1. Yes
2. No
Q5
How much money is estimated to be laundered through the UK each year?
1. Between £1.6 and £4 trillion
2. Over £4 trillion
3. £50 billion
4. Over £100 billion
Q6
What brought AMP’s under the money laundering regulations in the UK?
1. The Money Laundering (and Terrorist Financing) Regulations 2019
2. The Proceeds of Crime Act (PoCA) 2002
3. The Terrorism Act 2000
4. The Sanctions and AML Act (SAMLA) 2018
Q7
Which of these are offences under the Proceeds of Crime Act 2002?
1. Concealing, disguising, converting or transferring criminal property
2. Becoming involved in the arrangements relating to criminal property
3. The acquisition, use or possession of criminal property
4. All of the above
5. None of the above
Q8
What is a predicate offence to money laundering?
1. The act of laundering money
2. The underlying offence that created the proceeds of crime in the first place
3. The process by which criminal assets are confiscated by the court
4. The act of integrating criminal assets into society
Q9
Which of the below would be classified as a predicate offence to money laundering?
1. Theft
2. Fraud
3. Bribery
4. All of the above
Q10
If an AMP suspected that it was involved with the sale of some art work that was not owned by the seller, and being sold without the true owner’s permission, what could the AMP be guilty of?
1. Money Laundering
2. Aiding and abetting theft
3. Handling stolen goods
4. All of the above
Q11
What is due diligence?
1. The process by which AMPs ascertain who they are dealing with
2. Verifying someone’s identity
3. Establishing the legal right to buy/sell a piece of art
4. Confirming the source of wealth/funds associated to the buying of a piece of art
5. All of the above
Q12
Is there a difference between identifying and verifying someone’s identity?
1. Yes
2. No
Q13
What is a Politically Exposed Person?
1. An individual who has been entrusted with a prominent public function
2. A close associate of an individual who has been entrusted with a prominent public function
3. A family member of an individual who has been entrusted with a prominent public function
4. All of the above
Q14
What level of risk should a PEP be given?
1. It depends on why they are a PEP
2. It will vary given the location of the PEP
3. Always high risk
4. Medium to High risk
Q15
What is the inherent risk of doing business with a PEP?
1. They may commit fraud
2. We do not want to do business with government officials
3. Their role may have exposed them to bribery, the proceeds of which they pass to us
4. There is no more risk than dealing with any other type of customer
Q16
Could the sale of art be abused to bypass sanctions controls and allow a sanctioned person to “trade” in their art?
1. Yes, due to its transportability
2. No, the art work will be sanctioned too
Q17
What legislation criminalises money laundering in the UK?
1. The Money Laundering (and Terrorist Financing) Regulations 2019
2. The Proceeds of Crime Act (PoCA) 2002
3. The Terrorism Act 2000
4. The Sanctions and AML Act (SAMLA) 2018
Q18
What are the three levels of due diligence that can be applied to a customer?
1. Simplified, standard and enhanced
2. Low, medium and high
3. Standard, enhanced and high
4. Exempt, standard and enhanced
Q19
My company is a subsidiary of a larger parent company which has already undertaken CDD on my customer. Do I need to do it again?
1. No. if the parent company has done it, the subsidiary doesn’t have to
2. No, the subsidiary can place reliance on the parent company’s actions.
3. The subsidiary can use the CDD undertaken by the parent, but it must still be valid, current and sufficient to the subsidiary’s needs, or refreshed CDD would be required.
4. Yes, the customer must supply all new CDD information
Q20
If a customer asked a gallery to inflate the price of a painting on the invoice compared to what was actually paid for it, would this be?
1. Fraud by failing to disclose
2. Fraud by false representation
3. Fraud by abuse of position of trust
4. Obtaining services dishonestly
Q21
What three elements are usually required to be present for fraud to be committed?
1. Faith, hope and charity
2. Pressure, access and control
3. Method, control and access
4. Pressure, rationalization and opportunity
Q22
Broadly speaking, what is the purpose of transaction monitoring?
1. To help an AMP understand its customer better
2. So an AMP can monitor which kind of customer buys what kind of art
3. To assist an AMP to identify suspicious or unusual activity
4. Ensuring money goes to the bank account to which it was intended following a sale
Q23
What activity would be expected to represent EDD?
1. Obtaining a copy of the customer’s passport and driving licence
2. More in-depth research and analysis of the customer’s circumstances, source of funds, source of wealth and ID&V documentation
3. Obtaining 2 forms of personal verification and two forms of address verification
4. Asking other AMPs if they have ever dealt with the customer
Q24
Under UK law, under which 3 criteria does an AMP have to make a disclosure to the authorities?
1. When it has knowledge, suspicion or reasonable grounds to suspect money laundering
2. When it has knowledge, an admission and proof of money laundering
3. When it is told by another AMP that it has knowledge and proof of money laundering
4. When is has reasonable grounds, evidence and an admission of guilt
Q25
Is reasonable grounds an objective or subjective test?
1. Objective
2. Subjective
Q26
What is the maximum penalty for money laundering?
1. 10 years in prison
2. 14 years in prison and an unlimited fine
3. 10 years in prison or an unlimited fine
4. 14 years in prison
Q27
What is the maximum penalty for tipping off?
1. 5 years in prison
2. 14 years in prison and an unlimited fine
3. 2 years in prison or an unlimited fine
4. 2 years in prison
Q28
Which piece of legislation allowed the UK to implement its own AML and Sanctions rules and laws post Brexit?
1. The Money Laundering (and Terrorist Financing) Regulations 2019
2. The Proceeds of Crime Act (PoCA) 2002
3. The Terrorism Act 2000
4. The Sanctions and AML Act (SAMLA) 2018
Q29
What is the maximum penalty for failure to report knowledge, suspicion or reasonable grounds to suspect money laundering?
1. 5 years in prison
2. 14 years in prison and an unlimited fine
3. 5 years in prison or an unlimited fine
4. 2 years in prison
Q30
To whom is knowledge, suspicion or reasonable grounds to suspect money laundering reported to in the UK?
1. BAMF
2. The Financial Conduct Authority
3. The Serious Fraud Office
4. The National Crime Agency (NCA)
Q31
What is a DAML?
1. Defence Against Money Laundering
2. Directive Against Money Laundering
3. Direction Against Money Laundering
4. Disclosure Against Money Laundering
Q32
When should an AMP make a DAML request?
1. After a transaction has completed
2. Before a transaction has been executed
3. On the chance that a transaction may occur
4. When there is knowledge of money laundering having been committed
Q33
My customer lives at one address, but also has a holiday home, the artwork being purchased is to be sent to the spouse of the customer at the holiday home address, what ID7V do we need to undertake?
1. The customer’s name and address only
2. The spouses name and holiday home address only
3. The customer’s name and holiday home address only
4. The customer’s name and both his address and holiday home address
Q34
What is a UBO?
1. The legal entity that ultimately benefits from an organization
2. The natural person that is the ultimate beneficial owner of a company
3. The underlying beneficiary occupant of a company
4. The legal or natural person who is the ultimate buyer of the company
Q35
If a purchase of art was made by a Trust, would CDD still be required on the Trust?
1. No. Where a trust is involved no CDD is required.
2. Yes, because Trusts are not regulated
3. Yes, CDD must run through the entire transaction, even through and beyond a trust
4. No, CDD would only have to be conducted on actual people
Q36
Other than for compliance with the Data Protection Act why is data protection important?
1. Because customers like us to protect their data
2. Because we will be fined if we lose the data
3. Because a loss of customer data can lead to identity fraud, which leads to money laundering
4. Because data protection is a predicate offence to money laundering
Q37
We seem to be aligned to working the same way as banks do, is this right?
1. Yes, it is – AMPs are now required to follow the same rules as the banks
2. No, AMPs are required to implement a lower level of rules than banks
Q38
As an AMP, do we need to register with the Financial Conduct Authority (FCA) for money laundering compliance and supervision purposes?
1. Yes. All firms who are required to comply with the money laundering regulations must be registered for regulation by the FCA
2. No. AMP’s must be registered for supervision with the regulations with HMRC
Q39
If I am not a bank, why do I have to have similar AML/CTF controls as a bank?
1. You do not. You only need to comply with the BAMF and HMRC rules.
2. Because your bank is a bank and will want you, as a customer of theirs, to be as compliant as is necessary for your bank not to get into trouble with the FCA.
3. Because every sector is regulated to the same standard and level no matter who regulates them.
4. Because HMRC reports to the FCA in respect of AML supervision and regulation.
Q40
If a piece of art was purchased using funds that partially or fully derived from criminal activity, would that art then represent the proceeds of crime?
1. Yes
2. No
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