IACCP
money laundering definition - answercriminal activity that occurs when money from illegal activity is moved through the financial system to make to appear legit
OFAC - answerOFAC oversees the enforcement of federally mandated economic sanctions against certain foreign governments, financial institutions, and the SDN List.
SDN List - answerindividuals &various entities that are targets of sanctions either due to
drug trafficking, terrorism, or other illegal activity. All financial institutions, including investment advisers, should screen all accounts and activities to insure that no transaction involves a person on the SDN List or a person that is the
subject of an OFAC administered sanctions program.
Delegating AML Program - answerFirms need to evaluate what AML actions they can take, what functions may be out-sourced, what services third-party vendors can or should perform for them, and appropriate combinations of such tasks. Bear in mind that outsourced activities need to be available to federal examiners upon request and for purposes of review.
FinCEN/IRS Form 8300 - answerAll advisory firms have a responsibility to report to FinCEN on FinCEN/IRS Form 8300 (Form 8300) the receipt of cash in excess of $10,000 (coin and paper money) and cash equivalents such as cashier's checks, money
orders, bank drafts, or traveler's checks, or having a face amount of not
more than $10,000 received in any transaction in which the recipient knows that the instrument is being used in an attempt to avoid the reporting requirements.
4 pillars of an AML program - answer1. Written AML Program
2. Designated AML Officer
3. Independent Testing of AML Compliance
4. Ongoing AML Training
Do audits and tests on AML programs need to be independent or external? - answerindependent
who must approve the AML program? - answerSenior management (board of directors, general partner, etc.)
Does FINCEN enforce rules on Unregistered investment companies or RIA's? - answerno
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