FIs mustcooperate with law enforcement requestswhile ensuringlegal compliance.
Option C (Correct):Adesignated compliance officershould handledocument preparation and internal review.
Option A (Incorrect):There isno requirementto wait for theCEO's approval.
Option B (Incorrect):Privacy policies should already align withAML laws, delaying compliance isnot recommended.
Option D (Incorrect):Blocking a lawful requestcould lead tolegal and regulatory action.
Reference:FATF Recommendation 40 (International Cooperation), U.S. Bank Secrecy Act (BSA) Subpoena Guidelines, Egmont Group FIU Cooperation Standards.

According to the AML Directive of the EU, obliged entities, such as banks and other financial institutions, are required to apply enhanced vigilance in business relationships and transactions involving high-risk third countries, which are those identified by the Commission as having strategic deficiencies in their anti-money laundering and countering the financing of terrorism regimes1. The types of enhanced vigilance requirements are basically extra checks and control measures which are defined in article 18a of the Directive1. However, these requirements are not exhaustive, and obliged entities should also implement additional mitigating measures that are complementary to the enhanced customer due diligence procedures, in accordance with a risk based approach1. This means that obliged entities should assess the level of risk posed by each customer, product, service, transaction, or delivery channel, and apply appropriate measures to mitigate those risks2. The additional mitigating measures may include, for example, obtaining additional information on the customer and the beneficial owner, applying additional elements of enhanced monitoring, increasing the frequency and intensity of transaction testing, or requiring the first payment to be carried out through an account in the customer's name with a bank subject to similar customer due diligence standards1.
1: Directive (EU) 2018/843 of the European Parliament and of the Council of 30 May 2018 amending Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, and amending Directives 2009/138/EC and 2013/36/EU (Text with EEA relevance)
2: Guidance on Risk Factors, EBA, 2021
Reference: https://www.nortonrosefulbright.com/en/knowledge/publications/8f84c163/the-eus-fifth-anti- money-laundering-directive-a-regulatory-compliance-perspective

According to the 6th edition Certified Anti-Money Laundering Specialist Study Guide, when the compliance department receives an internal referral that appears to indicate terrorist financing, the first step in the investigation process should be to gather background and transaction information. This includes obtaining customer identification and verifying customer data, obtaining additional information about the customer and the transaction, and reviewing the transaction activity. This information will help to determine if the referral is accurate and if further action is needed.

Money laundering through capital markets often involves pump-and-dump schemes, wash trading, and layering funds through rapid trading activity.
Option A (Correct): A sudden spike in demand for a low-priced security is a red flag for pump-and-dump schemes, where criminals manipulate the market to inflate stock prices artificially before selling off shares for a profit.
Option B (Incorrect): A gradual decline in trading volume and price does not indicate suspicious activity related to money laundering.
Option C (Incorrect): An increase in demand for ETFs is common and not necessarily linked to money laundering.
Option D (Incorrect): Holding securities in one specific emerging market may indicate a geographic investment strategy, not necessarily money laundering.
Common Money Laundering Typologies in Capital Markets:
Pump-and-Dump Schemes - Fraudulently inflating stock prices to cash out illicit funds.
Wash Trading - Conducting self-trades to create an illusion of high market activity.
Layering Funds Through Rapid Trading - Engaging in frequent buy-and-sell orders to obfuscate the origin of funds.
Best Practices for AML in Capital Markets:
Monitor unusual trading volume and price fluctuations.
Use AI-driven surveillance systems to detect manipulative behavior.
Investigate transactions involving offshore brokers or shell entities.
Reference:
FATF Report on Money Laundering in Capital Markets
SEC and FINRA Guidance on Market Manipulation Risks
Wolfsberg Group Principles for Capital Markets AML Compliance

When presented with a search warrant, the AML specialist should record the names and affiliations of the agents who conduct the search. This will help in identifying who conducted the search in case there are any issues that need to be addressed later. Additionally, the AML specialist should obtain a copy of the warrant or photocopy the original warrant. This is important to ensure that the warrant is valid and that the agents are authorized to conduct the search. It is not appropriate to ask the agents questions or remember what items they have seized, as this could interfere with the search and potentially lead to legal issues. Finally, leaving the premises to allow the agents to conduct the search is not necessary, as the AML specialist has the right to be present during the search.