Chapter 4

Question 1

Three Basic Functions of an FIU

Answer 1

• Receive, Analysis, Dissemination.

Question 2

When presented with a search warrant, an institution should consider taking the following steps.

Answer 2

• Call counsel and/or designated officer in charge of security, risk management or similar area.
• Review the warrant to understand its scope.
• Ask for and obtain a copy of the warrant.
• Ask for a copy of the affidavit that supports the search warrant. The agents are not obligated to
provide a copy of the affidavit, but, if a financial institution is allowed to see the affidavit, the
financial institution can learn more about the purpose of the investigation.
• Remain present while the agents make an inventory of all items they seize and remove from the
premises. Keep track of the records taken by the agents.
• Ask for a copy of law enforcement’s inventory of what it has seized.
• Write down the names and agency affiliations.

Question 3

Key steps to conducting an effective financial investigation into potential suspicious activity

Answer 3

(a) reviewing internal transactions, information obtained from the customer
and other relevant internal documentation;
(b) identifying and reviewing external information to
understand the customer, related entities, and relevant media;
(c) contacting business line employees
responsible for the account relationship and
(d) generating a written report documenting relevant
findings.

Question 4

Some of the factors that the institution should consider on deciding to close an account.

Answer 4

• the legal basis for closing an account;
• the institution’s stated policies and procedures for closing an account, which may include automatic
closure recommendation following a specified number of STR filings;
• the seriousness of the underlying conduct. If the conduct rises to the level where the account
would ordinarily be closed, then the institution should consider closing the account;
• the reputational risk to the institution posed by maintaining the account; and
• correspondence with law enforcement and requests from law enforcement to either cancel or
maintain the account.

Question 5

When considering whether- or to what extent- to bring a case against an institution involving
money laundering-related charges, prosecutors will look at.

Answer 5

• The institution has a crinlinal history.
• The institution has cooperated with the investigation.
• The institution discovered and self-repo1ted the money laundering-related issues.
• The institution has had a comprehensive and effective AMVCIT program.
• The institution has taken timely and effective remedial action.
• There are civil remedies available that can serve as punishment.
• Deterring wrongdoing by others is needed and will be served by a prosecution.
• Advice and recommendations from regulatory agencies and/or the FIU for the jurisdiction is
available.

Question 6

clearinghouse of money laundering information for the benefit of national and international anti-money laundering agencies.

Answer 6

• The International Money Laundering Information Network (IMoLIN)

Question 7

IMoLIN has five main features, all but one accessible to the public.

Answer 7

• AMLID: Anti-Money Laundering International Database- A compendium and analysis of
national AML laws and regulations, as well as information on national contacts and authorities.
The database is password protected.
• Reference data: Research and analysis, bibliography, conventions, legal instruments and model
laws.
• Country page: Includes full text of AML legislation where available, and links to national F1Us.
• Calendar of events: Chronological listing of training events, conferences, seminars, workshops
and other meetings in the AML field.
• Current events: Current news of recent AML initiatives.