CTMA Practice Test

Understand how alerts are generated and identify different alert sources including manually prepared reports, human referrals, and automated transaction monitoring programs

Determine if an alert is valid by differentiating between valid alerts, false positives, and non-productive alerts

Understand why the volume of alerts may change over time and know how and when to report changes to higher level managers

Explain the purpose of scenarios, rules, patterns, behavior bases, and thresholds in transaction monitoring systems

Understand the purpose of tuning, the responsible parties and governance structure, when tuning should be conducted, and how the alert monitoring process informs tuning activities in the organization

Identify money laundering typologies and red flags and their associated unusual transaction activity, including structuring, transactions with no apparent economic, business, or lawful purpose, and suspicious wire transfers

Identify terrorist financing typologies and red flags and their associated unusual transaction activity, including those involving charities and non-profits, diamonds, precious metals, and antiquities

Identify non-AML financial crime typologies, red flags, and associated unusual transaction activity including fraud, sanctions, tax evasion, and bribery/corruption

Understand how to investigate multiple alerts generated for one customer within a single transaction monitoring period

Execute the research steps involved in transaction monitoring investigations including obtaining and reviewing KYC-CDD information, reviewing the case management system, checking internal sources, looking at transaction data related to the alerts, and reviewing linked counter-parties and accounts

Apply best practices for gathering additional information including contacting a customer as part of an investigation, submitting a request for information (RFI), and conducting public searches

Recognize common mistakes in transaction monitoring including not considering the source of the data and using out-of-date records in the review process

Identify new risks that emerge during transaction monitoring investigations and understand the appropriate escalation process

Identify and apply the appropriate outcomes of transaction monitoring investigations including alert closure, alert closure with CDD update or other recommendation, escalation, and recommended SAR filing

Document rationales for decisions and create an audit trail for regulators, future law enforcement inquiries, assurance and audit teams

Understand regulatory requirements associated with reporting suspicious and/or unusual activity including MLRO responsibility, when the process begins, time period for filing, agency for reporting, and criteria for manually escalating an alert to a case

Understand the reasons activity should be escalated for a potential SAR filing, the confidentiality of SARs including tipping off prohibitions, and what occurs after a SAR is filed

Understand notifications from FIU/law enforcement including requests to close accounts or maintain normal business activity, and dealing with repeat SARs