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

The bookkeeper lor Corporation A has been charged wilh embezzling corporate funds. It was discovered that the bookkeeper misappropriated customer checks received in the mail cashed the checks and wrote-off the accounts receivable asuncollectible. The corporation had policies to ensure there was a segregation of duties.
Which condition is MOST likely to have provided an opportunity for the bookkeeper to embezzle corporate income checks?

• A. The corporate mail duties of the receptionist which include logging the receipt of payments from customers are covered by a student intern when the receptionist calls in sick
• B. The bookkeeper and receptionist who opens the mail cover lor each other while the other is at lunch
• C. The bookkeeper enters all payments received (rom customers into the corporate Cash Receipts Journal
• D. The outside accountant receives and reconciles the monthly bank statement

Ms. Lee, a compliance analyst at a multinational bank, discovers that a new client has close business ties with entities in a country subject to comprehensive OFAC sanctions. What is the most appropriate action for Ms.
Lee to take regarding the onboarding of the new client?

• A. Proceed with onboarding the new client but restrict transactions involving entities in the sanctioned country.
• B. Conduct enhanced due diligence on the new client and obtain approval from senior management before proceeding with onboarding.
• C. Reject the onboarding of the new client due to the client's business ties with entities in a sanctioned country.
• D. Seek guidance from OFAC on the permissibility of onboarding the new client given the circumstances.

You are a law enforcement agent investigating an associate of Country X's former prime minister who is suspected of helping high-level government officials facilitate a scheme to misappropriate hundreds of millions of dollars in public funds. During your investigations, you uncovered a network of legal entities that you believe have been used to transfer and conceal the proceeds of this corruption scheme.
Through public record searches requests to law enforcement in other jurisdictions and subpoenas to financial institutions you have outlined the following arrangement.
* The associate contacted a relationship manager at a small private bank based in Country X to open a private bank account
* The associate's attorney created an offshore investment company Tropico, Ltd that holds the private banking account
* The associates attorney then appointed three shelf companies formed in Panama as Tropico's directors
* A fourth shelf company formed in the Cayman Islands was named as the primary shareholder You are now trying to determine the true owners behind the funds and assets concealed through this corporate structure Wh.ch is the MOST effect.ve next steptoidentify these individuals?

• A. Obtain articles of incorporation for the three shelf companies formed in Panama and listed as Tropics directors
• B. Obtain a subpoena that requires the relationship manager to provide testimony on the ownership structure of the legal entities
• C. Obtain transaction records from the private bank to determine who transferred funds into the account after it was established
• D. Obtain articles of incorporation for the shelf company formed in the Cayman Islands that was listed as primary shareholder