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Module 4A (M4A) – Rules & Regulations for Advising on Corporate Finance
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Question 1 of 30
1. Question
MAS proposes to create a client identity regulation where financial institutions shall establish agreements with their clients to promote the supply of UBO (Ultimate beneficial owners) information to MAS or some other law enforcement entity within:
Correct
FIs shall develop agreements with its customers to enable the supply of UBO details to MAS or any other regulatory agency within 5 business days on demand. FIs are not required to report details on the UBO at the time of the transaction where the information is kept by a foreign agent, as allowed under the Notice on the Prevention of Money Laundering and Countering of Financing of Terrorism SFA-N04 (“AML Notice”).
Incorrect
FIs shall develop agreements with its customers to enable the supply of UBO details to MAS or any other regulatory agency within 5 business days on demand. FIs are not required to report details on the UBO at the time of the transaction where the information is kept by a foreign agent, as allowed under the Notice on the Prevention of Money Laundering and Countering of Financing of Terrorism SFA-N04 (“AML Notice”).
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Question 2 of 30
2. Question
Section 39(3) of the Securities and Futures (License and Operation of Business) (‘SF(LCB)R’) Regulations mandates the issuer of the Capital Markets Services License to maintain a written record of the transactions of the client. Which of the following explanations correctly describes the significance of keeping a record of O&T (Orders and Trades) communications?
I. Such documents provide vital information in the inquiry of market abuse of the identification of the people who directed the O&T.
II. Such documents provide important evidence of the effect of O&T monitoring on the customer behavior.
III. Records are valuable for the analysis of conflicts with clients concerning the specifics of trades.
IV. Records are critical for determining the number of customers with respect to the complexities of the trades.Correct
O&T communication documents are essential for the identification of conflicts with clients concerning the specifics of transactions. Such documents will also constitute vital evidence in the prosecution of business manipulation of the names of the people who directed the O&T.
Incorrect
O&T communication documents are essential for the identification of conflicts with clients concerning the specifics of transactions. Such documents will also constitute vital evidence in the prosecution of business manipulation of the names of the people who directed the O&T.
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Question 3 of 30
3. Question
In compliance with the record-keeping period referred to in section 102(3) of the SFA, all records of orders and transactions shall be maintained for:
Correct
All documents shall be maintained for a term of 5 years in compliance with the record-keeping term referred to in section 102(3) of the SFA. MAS intends to incorporate a provision for FIs to report all interactions between their trading officers and an O&T officer in the customer’s account on certain stock market items, even though those correspondence do not lead to an actual transaction.
Incorrect
All documents shall be maintained for a term of 5 years in compliance with the record-keeping term referred to in section 102(3) of the SFA. MAS intends to incorporate a provision for FIs to report all interactions between their trading officers and an O&T officer in the customer’s account on certain stock market items, even though those correspondence do not lead to an actual transaction.
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Question 4 of 30
4. Question
MAS observes that there may be valid reasons for making payments in trading accounts by cash or third party transfers. For all payments made in cash by a third-party/regular client, the financial institution should maintain a record of:
I. Name of the issuer the and account holder.
II. The relationship of the third party with the owners of the account.
III. The mode of payment.
IV. Home address and the payer’s phone number.Correct
FI should document the name of the payer, including the national identification number, the place of residence, and the telephone number, the justification for payment in cash, and the source of funds. Where cash transfers are made by a third party, the FI may report the arrangement between the third party and the account manager, if the third party holds the trade power over the account and the justification for making the payment.
Incorrect
FI should document the name of the payer, including the national identification number, the place of residence, and the telephone number, the justification for payment in cash, and the source of funds. Where cash transfers are made by a third party, the FI may report the arrangement between the third party and the account manager, if the third party holds the trade power over the account and the justification for making the payment.
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Question 5 of 30
5. Question
In the case of non-cash payments received by a third party, the FIs must carry out due diligence checks if the sums in a particular instance or in a range of instances over a continuous one-month period exceed:
Correct
In the case of non-cash transfers received by a third party, the FIs may record all relevant information, such as the form of payment, the name of the counterparty bank, and the account manager, and carry out due diligence checks if the sums reach $20,000 in a single instance or in a series of instances within a one-month period.
Incorrect
In the case of non-cash transfers received by a third party, the FIs may record all relevant information, such as the form of payment, the name of the counterparty bank and the account manager, and carry out due diligence checks if the sums reach $20,000 in a single instance or in a series of instances within a one-month period.
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Question 6 of 30
6. Question
Which of the following will be held to account by MAS for making sure that the business operations of the financial institution are consistent with the objectives of the Guidelines?
I. Financial advisers
II. Board of directors
III. Senior management
IV. Provisional representativesCorrect
MAS requires the Board and senior management of financial firms to set the appropriate tone in the execution of marketing and delivery operations to clients in a responsible and competent way. MAS would also keep the Board and senior management responsible for ensuring that the corporate activities of their financial institution are aligned with the goals of the Guidelines.
Incorrect
MAS requires the Board and senior management of financial firms to set the appropriate tone in the execution of marketing and delivery operations to clients in a responsible and competent way. MAS would also keep the Board and senior management responsible for ensuring that the corporate activities of their financial institution are aligned with the goals of the Guidelines.
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Question 7 of 30
7. Question
Financial companies are required to perform call-backs or polls for all consumers prospected at stores and public locations during the free-look or cool-off duration for the selling of life insurance plans, health insurance products, and mutual investment schemes. Which of the explanations in the given options correctly explains the logic for the aforementioned practices?
I. To ensure maximum sales of financial products and services.
II. Ensure the marketing and consulting activities of members at supermarkets and public places are carried out in compliance with the guidelines on standards of conduct for Marketing and Distribution activities.
III. To guarantee that all consumers are completely aware of the benefits and risks of the financial good or service they have ordered.
IV. To detect inappropriate conduct, such as mis-sale or selling pressure.Correct
Financial companies should contact via call-backs or surveys to their consumers to ensure that they are completely aware of the benefits and drawbacks of the financial service or product they have obtained. This will also help the financial institution to recognize improper actions, such as faulty-sale or selling pressure.
Incorrect
Financial companies should contact via call-backs or surveys to their consumers to ensure that they are completely aware of the benefits and drawbacks of the financial service or product they have obtained. This will also help the financial institution to recognize improper actions, such as faulty-sale or selling pressure.
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Question 8 of 30
8. Question
Callbacks or surveys are only available on financial goods with a free-look or cooling-off time (referred on as a ‘set time’) and can be carried out on all transactions closed to stores and public areas before or during the set period. This is to:
Correct
This is to encourage consumers to cancel the transaction within the agreed timeline if they eventually rethink their decision and wish not to continue with the transaction, since certain consumers may find it harder to maintain a rational judgment under certain situations and may be tempted to make impulse transactions when being prospected at stores and public locations.
Incorrect
This is to encourage consumers to cancel the transaction within the agreed timeline if they eventually rethink their decision and wish not to continue with the transaction, since certain consumers may find it harder to maintain a rational judgment under certain situations and may be tempted to make impulse transactions when being prospected at stores and public locations.
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Question 9 of 30
9. Question
Which of the following methods support each other in the management of the marketing and distribution operations of a financial institution in shops and public locations, but are not to be incorporated for the selling of banking and traditional insurance goods and services?
I. Surveys
II. Call-backs
III. Site visits
IV. Mystery shopping exercisesCorrect
Mystery shopping experiments and site tours complement each other by managing the financial institution’s marketing and delivery operations in stores and public locations. Mystery shopping experiments require more strict constraints on pricing and consulting procedures of members, while site visits guarantee that marketing and sales operations are carried out properly in a continuous manner.
Incorrect
Mystery shopping experiments and site tours complement each other by managing the financial institution’s marketing and delivery operations in stores and public locations. Mystery shopping experiments require more strict constraints on pricing and consulting procedures of members, while site visits guarantee that marketing and sales operations are carried out properly in a continuous manner.
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Question 10 of 30
10. Question
In order to undertake an effective supervision of the marketing, sales, and consulting practices of financial institutions in stores and public locations, financial institutions should maintain:
I. Keep careful accounts of their production and distribution plans.
II. Execute mystery shopping activities rather than stringent checks on revenue and consulting practices of members.
III. Conduct call-backs and polls to ensure the satisfaction of the consumers.
IV. Track the complaints arising from their marketing, distribution, and consultation practices in stores and public locations.Correct
Financial institutions should keep clear records of their promotion and delivery agreements in order to conduct efficient control of their advertisement, procurement, and advising practices in stores and public locations. This would also make it easier for financial institutions to determine the source, existence, and cause of any problem or complaint.
Incorrect
Financial institutions should keep clear records of their promotion and delivery agreements in order to conduct efficient control of their advertisement, procurement, and advising practices in stores and public locations. This would also make it easier for financial institutions to determine the source, existence, and cause of any problem or complaint.
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Question 11 of 30
11. Question
Financial firms should maintain a registry sharing information on their marketing and delivery practices in stores and public locations. The registry should maintain track of all of the following, except for:
Correct
The registry shall maintain a record of the locations of the selling and delivery plans and/or events of the financial institution; the time duration of the agreements and/or events; the names of the members and managers involved; and the financial goods and/or services sold or delivered.
Incorrect
The registry shall maintain a record of the locations of the selling and delivery plans and/or events of the financial institution; the time duration of the agreements and/or events; the names of the members and managers involved; and the financial goods and/or services sold or delivered.
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Question 12 of 30
12. Question
The financial institution should specifically describe and explain to its representatives the details to be revealed and the way in which the disclosures should be made. Which of the activities referred below must be carried out by the representatives?
I. Representatives must specifically display their worker passes or wear company uniforms, logos and badges to represent their financial institution.
II. Representatives are expected to supply consumers with their name cards.
III. Representatives shall live in the immediate proximity of the sales booth on a weekly basis.
IV. Representatives must behave in compliance with the script provided by the FI as they meet customers.Correct
Representatives must provide a prospect in the near area of the sales booth, must behave according to the template provided by the FI when addressing customers, must supply customers with their name cards, and must show clearly their personnel passes or wear company uniforms, logos and badges to distinguish their financial institution.
Incorrect
Representatives must provide a prospect in the near area of the sales booth, must behave according to the template provided by the FI when addressing customers, must supply customers with their name cards, and must show clearly their personnel passes or wear company uniforms, logos and badges to distinguish their financial institution.
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Question 13 of 30
13. Question
In order to evaluate the performance and compliance record of the representative, which of the following details about the representative do not need to be reviewed by the financial institution?
Correct
The financial institution should determine the regulatory record of the representative by assessing the reasonable scorecard rating of the representative, any complaint(s) previously lodged against the representative; any administrative action(s) previously taken against the representative; and all other applicable details obtained from the due diligence of the financial institution by the representative.
Incorrect
The financial institution should determine the regulatory record of the representative by assessing the reasonable scorecard rating of the representative, any complaint(s) previously lodged against the representative; any administrative action(s) previously taken against the representative; and all other applicable details obtained from the due diligence of the financial institution by the representative.
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Question 14 of 30
14. Question
To assure that the representatives do not deliberately encourage or attract the attention of the consumers through the gifts given along the purchase made by them, which of the following measures must be taken by the Financial Institutions?
Correct
Prescribing a monetary limit on the valuation of gifts in such a manner that gifts given to clients are only of negligible value equal to the amount spent, requiring all gifts distributed under those provisions to be permitted by the financial institution, and controlling the sales and consulting activities of the agents to ensure that grants are not the major objective of the deal are some of the correct steps that must be taken by the FIs.
Incorrect
Prescribing a monetary limit on the valuation of gifts in such a manner that gifts given to clients are only of negligible value equal to the amount spent, requiring all gifts distributed under those provisions to be permitted by the financial institution, and controlling the sales and consulting activities of the agents to ensure that grants are not the major objective of the deal are some of the correct steps that must be taken by the FIs.
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Question 15 of 30
15. Question
Financial institutions should make sure that the location for their marketing and delivery operations is a suitable location for representatives to hold a regular sales and advisory meetings. Choose the points that need to be taken into account when choosing a venue in the aforementioned context?
I. Ensure that the venue is such that it impresses the customers and convinces them to purchase the services/products.
II. Ensure that consumers are able to understand precisely the risks, advantages, and incentives of financial goods or services.
III. Ensure that the area is dense and conveniently available to consumers.
IV. Ensure that the facilities available and the setting in which their promotion and delivery systems are situated are sufficient for the type and scale of the activities involved.Correct
Venues can be such as to ensure that consumers have a good experience and are able to fully understand the risks and benefits of the financial goods or services they buy. The area available and the setting in which their promotion and delivery systems are situated must be sufficient for the form and scope of the activities involved. Diversions should also be mitigated by guaranteeing that the area is not overcrowded or noisy.
Incorrect
Venues can be such as to ensure that consumers have a good experience and are able to fully understand the risks and benefits of the financial goods or services they buy. The area available and the setting in which their promotion and delivery systems are situated must be sufficient for the form and scope of the activities involved. Diversions should also be mitigated by guaranteeing that the area is not overcrowded or noisy.
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Question 16 of 30
16. Question
The financial institution should ensure that sufficient mechanisms are placed in place to compensate for and safely hold payments obtained under marketing and delivery agreements distributed in stores and public locations, such as:
Correct
Examples of good practices include decreasing the processing of cash payments, providing receipts to consumers and ensuring a correct database of all payments received on a timely basis, naming a delegate to be responsible for the safekeeping of payments obtained, and requiring members to forward money and checks to the financial institution as soon as possible.
Incorrect
Examples of good practices include decreasing the processing of cash payments, providing receipts to consumers and ensuring a correct database of all payments received on a timely basis, naming a delegate to be responsible for the safekeeping of payments obtained, and requiring members to forward money and checks to the financial institution as soon as possible.
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Question 17 of 30
17. Question
Which of the following is accountable for the AML/CFT ( anti-money laundering and countering the financing of terrorism) compliance role, which includes a continuous supervision of the payment service provider’s performance on all AML/CFT duties by the payment service provider?
Correct
The AML/CFT compliance role under the second line of defense is responsible for the continuous supervision by the payment service provider of the execution of all AML/CFT duties by the supplier. This includes a reference evaluation and a study of the exemption files. Enforcement should warn the senior management of the service provider if it suspects that its officers are struggling to fix ML/TF risks and concerns.
Incorrect
The AML/CFT compliance role under the second line of defense is responsible for the continuous supervision by the payment service provider of the execution of all AML/CFT duties by the supplier. This includes a reference evaluation and a study of the exemption files. Enforcement should warn the senior management of the service provider if it suspects that its officers are struggling to fix ML/TF risks and concerns.
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Question 18 of 30
18. Question
Select the functions from the list of functions given below that are to be monitored and regulated by the third line of defense to combat the financial crimes.
I. The payment service provider’s internal audit functions
II. Evaluation of the ML/TF risk management framework and controls
III. Customer-facing functions of the payment service provider’s business
IV. The AML/CFT compliance functionsCorrect
As the third line of defense, the internal audit mechanism of the payment service provider plays a significant role in objectively reviewing the ML / TF risk management process and processes for disclosure to the audit committee of the payment service provider’s board of directors or related supervisory authority.
Incorrect
As the third line of defense, the internal audit mechanism of the payment service provider plays a significant role in objectively reviewing the ML / TF risk management process and processes for disclosure to the audit committee of the payment service provider’s board of directors or related supervisory authority.
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Question 19 of 30
19. Question
As per the third line of defense, the internal review mechanism of the payment service provider plays a significant role in the independent appraisal of the ML/TF risk management process and controls. Payment service providers should develop policies for regular AML/CFT internal controls covering various aspects such as the following, except for:
Correct
Regulations should be developed to ensure the soundness of AML/CFT payment service provider policies, processes, and controls in detecting ML/TF threats, assure the mitigation of the defined risks and compliance with regulations and notifications; the efficacy of the payment service provider’s policy implementation; the effectiveness of regulatory monitoring and quality management, including the requirements and conditions for transaction alerts; and the efficacy of the preparation of appropriate personnel and officers by the payment service company.
Incorrect
Regulations should be developed to ensure the soundness of AML/CFT payment service provider policies, processes, and controls in detecting ML/TF threats, assure the mitigation of the defined risks and compliance with regulations and notifications; the efficacy of the payment service provider’s policy implementation; the effectiveness of regulatory monitoring and quality management, including the requirements and conditions for transaction alerts; and the efficacy of the preparation of appropriate personnel and officers by the payment service company.
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Question 20 of 30
20. Question
Besides evaluating the ML/TF risks posed by an individual client, the payment service provider shall detect and test ML/TF risks at the organizational level. This shall include a combined examination of the ML/TF risks for the payment service provider which occur across all of its:
I. Personal relations
II. Product lines
III. Business units
IV. Delivery channelsCorrect
This requires a comprehensive evaluation of the ML/TF risks of the payment service provider that occur across all of its business divisions, product lines, and delivery channels. The service provider must consider the ML/TF risks of its affiliates and subsidiaries, including those outside Singapore, as part of its integrated assessment of its corporate ML/TF risks.
Incorrect
This requires a comprehensive evaluation of the ML/TF risks of the payment service provider that occur across all of its business divisions, product lines, and delivery channels. The service provider must consider the ML/TF risks of its affiliates and subsidiaries, including those outside Singapore, as part of its integrated assessment of its corporate ML/TF risks.
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Question 21 of 30
21. Question
The payment service provider should acquire identification documents that identify a specific image of the customer. The documents that include the name, unique identification number, birth date, citizenship, and recent service or telephone bill, bank statement, or communication from a government entity shall be needed if the customer is:
Correct
Name, personal identification number, date of birth and nationality on the basis of a valid passport or national identity card containing a photograph of the customer, a home address on the basis of a national Id card, and a recent service or telephone bill, a bank statement or documentation from a government department is needed if the customer is a natural person.
Incorrect
Name, personal identification number, date of birth and nationality on the basis of a valid passport or national identity card containing a photograph of the customer, a home address on the basis of a national Id card, and a recent service or telephone bill, a bank statement or documentation from a government department is needed if the customer is a natural person.
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Question 22 of 30
22. Question
Assuming that the customer documentation is in a foreign language, reasonable precautions need to be taken by the payment processing provider in order to be assured that the paperwork clearly contains proof of the identity of the client. Which of the following steps should be taken to ensure the ML/TF threats associated with the client are adequately defined and assessed?
Correct
They should verify that any document critical to the effectiveness of any evaluation necessary under the Notice is translated into English by a trained translator. They can rely on the translation of that particular document by an employee or agent of the payment service provider, independent of the payment service provider’s dealings with the client who is conversant in that foreign language.
Incorrect
They should verify that any document critical to the effectiveness of any evaluation necessary under the Notice is translated into English by a trained translator. They can rely on the translation of that particular document by an employee or agent of the payment service provider, independent of the payment service provider’s dealings with the client who is conversant in that foreign language.
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Question 23 of 30
23. Question
As set out in the Guidelines in MAS Notice PS-N02 on the Prevention of Money Laundering and Combating Terrorism Funding for all occupants of a payment service license engaged in the provision of digital payment token service, if there is a long list of natural persons named to operate on behalf of the client, the service provider should:
Correct
Where there is a lengthy list of natural persons designated to work on behalf of the client (e.g. a list of more than 10 approved signatories), the payment service provider can at the very least validate certain natural persons who interact directly with the payment service provider.
Incorrect
Where there is a lengthy list of natural persons designated to work on behalf of the client (e.g. a list of more than 10 approved signatories), the payment service provider can at the very least validate certain natural persons who interact directly with the payment service provider.
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Question 24 of 30
24. Question
When defining a natural person who essentially owns a legal person or legal arrangement, the shareholdings within the ownership scheme of the legal person or legal agreement should be recognized. A natural person who does not fulfill the share capital requirement but influences the consumer (e.g. by exerting substantial influence) is regarded as:
Correct
A natural person who does not surpass the shareholding criterion referred to above but who influences the client (e.g. by reinforcing substantial influence) is a beneficial owner under the Notice.
Incorrect
A natural person who does not surpass the shareholding criterion referred to above but who influences the client (e.g. by reinforcing substantial influence) is a beneficial owner under the Notice.
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Question 25 of 30
25. Question
Suppose the client is a majority-owned affiliate of a publicly listed legal body. Beneficiary owners should be recognized and validated if there are any non-publicly recognized legal persons who own:
Correct
When the customer is a majority-owned division of a publicly listed legal entity, it is not important to recognize and check the identity of beneficial owners of the customer. But, where there are other non-publicly-listed legal persons who own more than 25% of the customer or otherwise regulate the customer, the beneficial owners of those non-publicly-listed legal persons should be identified and validated.
Incorrect
When the customer is a majority-owned division of a publicly listed legal entity, it is not important to recognize and check the identity of beneficial owners of the customer. But, where there are other non-publicly-listed legal persons who own more than 25% of the customer or otherwise regulate the customer, the beneficial owners of those non-publicly-listed legal persons should be identified and validated.
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Question 26 of 30
26. Question
Steps taken by the payment service company to consider the intent and planned existence of contractual partnerships and activities performed without opening an account should be proportional to the customer’s market and risk profile. With higher risk clients, the payment service provider must attempt to analyze:
Correct
In the case with higher risk clients, the payment processing provider may attempt to identify the planned account operation (e.g. the volume with transactions likely to proceed, the estimated sum for each transaction, the identities of the individuals to which the money is to be transferred) and consider, as part of continuous surveillance, whether the operation is compliant with the stated purpose.
Incorrect
In the case with higher risk clients, the payment processing provider may attempt to identify the planned account operation (e.g. the volume with transactions likely to proceed, the estimated sum for each transaction, the identities of the individuals to which the money is to be transferred) and consider, as part of continuous surveillance, whether the operation is compliant with the stated purpose.
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Question 27 of 30
27. Question
In evaluating what may constitute a fraudulent, complicated, exceptionally vast or irregular series of transactions performed without the opening of an account, the payment service provider should pay heed to transaction characteristics, unlike:
Correct
Characteristics of the transaction, such as the nature of the transaction (e.g. irregular size or frequency for that client or groups of similar); if a sequence of transactions are made in order to circumvent disclosing thresholds; the geographical location or origin of the payment (e.g. to or from a person residing in or situated in a higher risk country); and the parties involved must be taken into account.
Incorrect
Characteristics of the transaction, such as the nature of the transaction (e.g. irregular size or frequency for that client or groups of similar); if a sequence of transactions are made in order to circumvent disclosing thresholds; the geographical location or origin of the payment (e.g. to or from a person residing in or situated in a higher risk country); and the parties involved must be taken into account.
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Question 28 of 30
28. Question
Payment service providers should keep in mind that online applications and purchases made over the internet or by phone pose higher risks than other non-face-to-face purchases. Which of the following variables correctly describes the explanation behind it?
I. The speed through electronic transactions.
II. The ease of producing several fake applications without incurring extra expenses or the possibility of detection.
III. The availability and accessibility to national security.
IV. The absence of physical records.Correct
The ease of illegal access to the system, through time zones and location; the ease of rendering many fake applications without accruing unnecessary costs or chance of detection; the lack of physical documents; and the speed of electronic transactions, which can, taken together, intensify ML/TF threats.
Incorrect
The ease of illegal access to the system, through time zones and location; the ease of rendering many fake applications without accruing unnecessary costs or chance of detection; the lack of physical documents; and the speed of electronic transactions, which can, taken together, intensify ML/TF threats.
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Question 29 of 30
29. Question
In order to efficiently handle the ML/TF uncertainties resulting from the delay of the completion of the verification, the payment service provider should suspend contractual ties with the client and abstain from engaging in further transactions if the validation remains incomplete for:
Correct
The payment service provider may suspend contractual ties with the customer and prevent from carrying out any further transactions (with the exception of returning funds to their origins to the degree that this is possible) if any assurance remains unfulfilled 30 business days after the establishment of business ties.
Incorrect
The payment service provider may suspend contractual ties with the customer and prevent from carrying out any further transactions (with the exception of returning funds to their origins to the degree that this is possible) if any assurance remains unfulfilled 30 business days after the establishment of business ties.
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Question 30 of 30
30. Question
Screening is meant to be a preventive strategy. The payment service provider is informed that all parties listed corresponding to the Notice must be reviewed, regardless of the risk profile of the client. When the test findings have a positive impact on the sanction lists, what shall the payment service provider do?
Correct
It is reminded of its responsibilities to seize, without delay and without prior warning, the funds or other properties of designated individuals and organizations under its supervision in order to comply with the relevant regulations in Singapore, including the TSOFA and MAS Regulations provided pursuant to Section 27A of the Singapore Monetary Authority Act (Cap. 186) on restrictions and the freezing of personal assets.
Incorrect
It is reminded of its responsibilities to seize, without delay and without prior warning, the funds or other properties of designated individuals and organizations under its supervision in order to comply with the relevant regulations in Singapore, including the TSOFA and MAS Regulations provided pursuant to Section 27A of the Singapore Monetary Authority Act (Cap. 186) on restrictions and the freezing of personal assets.