During onboarding al Private Bank A, client C indicated that the account would be initially funded with a transfer from Bank B totaling 50 million USD. On which source of funds should Bank A conduct additional scrutiny? (Select Two.)

• A. Client's overall wealth
• B. Transfer from Bank B
• C. Documented sale of client properties
• D. Client's verified employment income
• E. Third-party transfer

An analyst reviews an alert for high volume Automated Clearing House (ACH) activity in an account. The analyst's initial research finds the account is for a commercial daycare account that receives high volumes of large government-funded ACH transactions to support the programs. The account activity consists of checks (cheques) made payable to individual names in varying dollar amounts. One check indicates rent to another business.
An Internet search finds that the daycare company owner has previous government-issued violations for safety and classroom size needs, such as not having enough chairs and tables per enrollee. These violations were issued to a different daycare name.
Simultaneous to this investigation, another analyst sends an email about negative news articles referencing local child/adult daycare companies misusing governmental grants. This prompts the financial institution (Fl) to search all businesses for names containing daycare' or care*. Text searches return a number of facilities as customers at the Fl and detects that three of these businesses have a similar transaction flow of high volume government ACH funding with little to no daycare expenses.
The analyst determines that site visits should be conducted for the three daycare businesses. Which observations at the on-site visits would justify writing a SAR/STR? (Select Three.)

• A. Visible signage indicating the purpose of the building
• B. A full parking lot of cars with no staff at the site
• C. Lights turned off at the site during operational hours
• D. Visible attendance with children being dropped off by parents
• E. A site located in a commercial building
• F. Signs of severe wear and poor maintenance at the site

A new customer has just been onboarded in a securities firm. After a few weeks, there are unusual trading patterns that are being flagged. Which pattern is most concerning to the compliance officer?

• A. The customer accumulates securities of a low volume counter in small increments on a weekly basis.
• B. The customer engages in large trading in securities that are liquid or highly priced from the trading account.
• C. The customer's repeated trading in securities that are low priced and low volume counters.
• D. The customer receives many incoming wire transfers from related parties to the trading account.

A SAR/STR regarding money-mule activity prompts law enforcement action. Under U.S. law, the alleged money mules can be prosecuted:

• A. in a country only if funds were transferred between accounts maintained in the same country.
• B. even if they were unaware that money was transferred.
• C. unless they can prove they were not aware of the origin of the funds.
• D. only if they were aware of their role and actively participated.