PART A · QUESTION 1
Cash from drug sales is paid into several small accounts. It is then wired through two companies' accounts abroad and finally used to buy a block of flats.
// EXAM HALL24 QUESTIONS · 30 MINUTES
AML and Financial Crime Practice Test
The basics, a statement to review against the clock, and what you do when something does not fit.
BY MICHAEL SHANG · SIXTEEN YEARS IN COMMERCIAL BANKING · UPDATED
// THE SHORT ANSWER
An AML and financial crime practice test checks that you know the basics of money laundering and sanctions, can review a customer's statement against its stated business, and know what to do once something does not fit. This paper has three parts: the basics, a timed statement review set on one exhibit, and the calls an analyst has to make. Every question is original, written for no one country's law, and none comes from any bank's test. Learn your own country's rules as well: the terms and reporting duties differ.
BASIS Practitioner judgment from sixteen years in commercial banking, set out in How Bankers Think (Highbank Press, 2026). Every borrower on this site is a composite constructed for teaching, not a client. The market is mid-market commercial lending as practised in New Zealand and Australia; where a convention differs elsewhere, the page says so.
// HOW TO SIT IT
Answer below as practice, and each read opens as you go. Or sit it as a test: 30 minutes, with every read held back until you finish.
PART A
The basics
The vocabulary and the duties. The terms differ a little from country to country; the ideas here do not.
PART A · QUESTION 2
Four new customers apply in the same week: a local plumber, a family trust set up by a foreign government minister, a village sports club and a salaried nurse.
Which one calls for enhanced due diligence from the start?
PART A · QUESTION 3
A retired surgeon wants to deposit US$2m from selling a house. She says her total assets are about US$15m, built from her career and her investments.
Which is her source of funds, and which her source of wealth?
PART A · QUESTION 4
A company's share register lists one shareholder: a nominee company, which says it holds the shares for a client it would rather not name.
Who is the bank trying to identify?
PART A · QUESTION 5
A small payment from a long-standing customer stops in screening. The beneficiary's name partly matches an entry on a sanctions list. The customer is calling to ask where the money is.
What do you do?
PART A · QUESTION 6
A new head of financial crime says the team cannot look at everything, and asks each analyst to say what 'risk-based' means.
What is the best answer?
PART A · QUESTION 7
A customer of eight years has never raised a question. Last month her brother was appointed a government minister.
What changes?
PART A · QUESTION 8
A student's account, quiet for a year, now receives several payments a day from unrelated people. Each is sent overseas within hours, less a small amount.
What does the pattern point to?
PART B
The statement review
One customer, eight questions. Read the statement against what the customer told the bank, and note what you would ask before you look at the questions.
EXHIBIT B · THE STATEMENT
A hand car wash on one site, opened eleven months ago. A limited company with one director, who owns all of it. At onboarding it declared turnover of about US$25,000 a month, mostly card with some cash, and three staff.
Monitoring has raised an alert. Cash deposits of US$10,000 or more are reported automatically in this country.
| Date | Details | Out | In | Balance |
|---|---|---|---|---|
| Opening balance | 6,240 | |||
| 02 Mar | Card settlement | 2,960 | 9,200 | |
| 04 Mar | Cash deposit, Central branch | 9,500 | 18,700 | |
| 05 Mar | Cash deposit, Northgate branch | 9,400 | 28,100 | |
| 06 Mar | Cash deposit, Harbour branch | 9,700 | 37,800 | |
| 09 Mar | Rent, commercial landlord | 3,200 | 34,600 | |
| 10 Mar | Transfer to Company B, overseas: “consulting fees” | 26,500 | 8,100 | |
| 12 Mar | Card settlement | 3,140 | 11,240 | |
| 16 Mar | Annual insurance premium | 4,180 | 7,060 | |
| 18 Mar | Cash deposit, Central branch | 9,600 | 16,660 | |
| 19 Mar | Cash deposit, Harbour branch | 9,300 | 25,960 | |
| 20 Mar | Payment in from Person C: “loan” | 15,000 | 40,960 | |
| 23 Mar | Transfer to Company B, overseas: “consulting fees” | 31,000 | 9,960 | |
| 26 Mar | Card settlement | 2,870 | 12,830 | |
| 30 Mar | Car-wash chemicals, supplier | 1,240 | 11,590 | |
| 01 Apr | Cash deposit, Northgate branch | 9,800 | 21,390 | |
| 02 Apr | Cash deposit, Central branch | 9,500 | 30,890 | |
| 03 Apr | Cash deposit, Harbour branch | 9,400 | 40,290 | |
| 06 Apr | Rent, commercial landlord | 3,200 | 37,090 | |
| 07 Apr | Transfer to Company D, overseas: “equipment” | 27,000 | 10,090 | |
| 09 Apr | Card settlement | 3,010 | 13,100 |
PART B · QUESTION 9
From Exhibit B: add up the cash deposits.
How much cash came in over the six weeks?
PART B · QUESTION 10
From Exhibit B: eight cash deposits, each between US$9,300 and US$9,800, in three branches, in three bursts on consecutive days.
What is this pattern called?
PART B · QUESTION 11
From Exhibit B: follow the money after each burst of cash.
Where does it go?
PART B · QUESTION 12
From Exhibit B: the statement shows rent, one insurance premium and one chemicals bill.
What would you expect to see that is not there?
PART B · QUESTION 13
From Exhibit B: a reviewer who flags everything is no more use than one who flags nothing.
Which entry would you clear as unremarkable on its face?
PART B · QUESTION 14
From Exhibit B: you have the alert and the statement, and twenty minutes before you write anything up.
What do you look at first?
PART B · QUESTION 15
From Exhibit B: the customer's file explains neither the cash, nor the overseas payments, nor the missing wages. You cannot show that any crime took place.
What do you do with the alert?
PART B · QUESTION 16
From Exhibit B: a colleague's draft escalation opens: 'Highly suspicious car wash, looks like organised crime, the director seems evasive.'
What should the summary lead with instead?
PART C
The calls
What an analyst has to decide, including when a colleague would rather they did not.
PART C · QUESTION 17
A café client starts depositing cash several times a week, each deposit just under the amount that would trigger a report. Its turnover hasn't changed.
Signal or noise?
PART C · QUESTION 18
Monitoring raises an alert on a builder's account: a US$180,000 payment in, far above normal. The invoice and contract on file show a real job for a known client.
How do you dispose of the alert?
PART C · QUESTION 19
You have reported a client's transactions as suspicious. The client calls and asks why its new payments are being held.
Your answer?
PART C · QUESTION 20
You have questions about large cash deposits by a major client. Its relationship manager calls: 'I've known them fifteen years. They're our biggest account in the region. Please close this.'
What do you do?
PART C · QUESTION 21
A new business client is owned by a company in another country, which is owned by a trust whose beneficiaries are not disclosed.
What do you ask first?
PART C · QUESTION 22
An exporter of industrial electronics has sold little to one small country for years. Since sanctions were imposed on the country next door, those sales have tripled, through a new distributor.
What does this call for?
PART C · QUESTION 23
An importer you have banked for years starts paying a new overseas supplier far above market prices for ordinary goods. The goods are shipped and invoiced normally.
Signal or noise?
PART C · QUESTION 24
A check you run finds that customer risk reviews were missed for six months after a system change. Nothing bad appears to have happened. Your manager says: 'Fix it quietly. No need to write this up.'
What do you do?
0 OF 24 ANSWERED · 0 WITH THE SENIOR READ · 0 STANDS UP · 0 OFF THE LINE
// THE REST OF THE ROUND
Every question here is original; none is any bank's real test. Written for: Financial crime analyst, Compliance officer.
- Financial crime analyst: the interview questions, against a two-minute clock.
- Situational judgement, for any seat.
- The assessment centre: a whole case in forty-five minutes.
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