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You are a law enforcement agent who has received an anonymous tip about suspicious financial activities at Labor Way Inc. a company in your jurisdiction. Labor Way contracts with large corporations internationally to provide temporary employees, and handles payroll processing and lax withholding lor its temporary employees.
You begin an investigation into Labor Way and discover the following information:
* Labor Way's corporate bank account was opened in the name of a law firm that is acting as nominee
* Labor Way's financial records show a sharp increase in revenues and a corresponding increase in temporary employment contracts over the past two years
* Labor Way's transaction history shows periodic withdrawals of large amounts of cash that correspond with its payroll coming due
* Labor Way has recently gained a number of clients in other countries (where it is not located) including several in which it did not previously operate Based on (his information which is your MOST likely conclusion?

• A. Labor Way may be committing employment tax fraud because its transaction records indicate it is paying all of US temporary employees in cash
• B. Labor Way may be involved m a terrorist financing scheme because it has recently entered into contracts in overseas indications to which it has no prior business connections
• C. Labor Way may be involved in a money laundering scheme due to the presence of a beneficial owner who is hiding behind the nominee account
• D. Labor Way may be committing internal accounting fraud due to the substantial and unexplained increase in revenues

Mr. Johnson, a compliance officer at ABC Corporation, is conducting due diligence on a potential business partner based in a foreign country. During the due diligence process, Mr. Johnson discovers that the potential partner's principal shareholder is a politically exposed person (PEP) from a country subject to OFAC sanctions. What is the most appropriate action for Mr. Johnson to take?

• A. Proceed with the business partnership but conduct enhanced monitoring of transactions involving the PEP.
• B. Seek guidance from OFAC on the permissibility of engaging with the potential partner.
• C. Proceed with the business partnership but disclose the involvement of the PEP to OFAC.
• D. Reject the business partnership due to the involvement of a PEP from a sanctioned country.

A mid-size bank receives a S35 000 wire transfer request in an email from the chief financial officer (CFO) of one of the bank's business clients. The client's head of accounting was copied on the message An employee at the bank replied to the email with a wire transfer form and agreement for the client to complete.
The CFO replied with the signed and completed forms the bank began processing the wire transfer and as a routine measure called the number in the CFO's email signature to validate request. The bank received verbal confirmation to complete the transfer.
The next day a bank employee receives a call from the head of the clients accounting department inquiring about the $35,000 transfer believing it to be an error. The bank employee says that the transfer was initiated by the company CFO and produces the wire transfer forms. The head of accounting says that no such transfer was authorized and connects the bank with the CFO to confirm this Now believing the transaction to be fraudulent the bank starts an attempt to reverse the wire transfer.
Based on this information which is a weakness in the bank's cybersecurity program?

• A. The bank should have scanned the completed wire transfer forms that the CFO attached to her email for malware used in account takeover schemes
• B. The bank should have replied to the email and requested confirmation from the head of accounting in addition to the CFO
• C. The bank should have required a hard copy of the wire transfer agreement to be returned via fax before processing the wire
• D. The bank should have authenticated the request using contact information on file with the bank before processing the wire

Company A a multinational manufacturing corporation, recently acquired a local company in Country Z that has a high level of state involvement in ihe economy and history of corruption Before purchasing the company. Company A hired a major international law firm to conduct a due diligence review and uncover any potential violations of global anti-corruption laws When the review came back free of issues Company A completed its acquisition.
Two years later executives from Company A were conducting their first anti-corruption compliance training with employees from the Country Z office During the training session Company A executives were alerted by Country Z-based employees that the distributors the company uses may be bribing government officials Company A had not conducted a review of distributors in Country Z, and when it began to look into the allegations it found widespread potential Foreign Corrupt Practices Act (FCPA) violations.
Which are two weaknesses in Company A's anti-corruption compliance program? Choose 2 answers

• A. Company A failed to reach out directly togovernmentagencies within Country Z to request information on any history of corrupt payments at the company it was acquiring
• B. Company A should have conducted anti-corruption compliance training as soon as possible after acquiring the company in Country Z
• C. Company A did not include its distributors within Country Z when conducting its anti-corruption due diligence and training
• D. The due diligence review should have been exclusively conducted by local counsel from within Country Z becausetheywould be better versed in the country's culture and laws

Your client is the family of a man who is deceased. The family remembers stones that their father (the deceased) had a Cayman Islands company where he held his investments. They have located a file containing an old Cayman Islands bank statement in the name of Company A Limited and in care of a post office address. They want to know what information they can find out about the company and the account.
How can they determine if the company still exists?

• A. Conduct an internet search for the company's name as company information is public
• B. Visit the post office and ask for access to the PO Box
• C. Check with the Corporate Registry as this information is public
• D. Contact the bank and ask the status of the company