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| Section | Weight | Objectives |
|---|---|---|
| Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) | 25% | - AML/CFT International Standards
|
| AML/CFT Compliance Program | 26% | - Customer Identification Program (CIP) and Customer Due Diligence (CDD)
|
| Money Laundering Risks and Methods | 26% | - Nature of Money Laundering, Terrorist Financing, and Threat Finance
|
| AML/CFT Investigations and Enforcement | 23% | - AML/CFT Investigation Process
|
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NEW QUESTION # 199
A bank's transaction surveillance system triggers an alert for a deposit of 250.000 USO into a client's account.
According to the bank's KYC information, the client works for afinancial advisory firm, and earns approximately 100,000 USD per year. Which actions should be taken? (Select Three.) File the suspicious transaction immediately to the financial intelligence unit.
Answer: B,D,E
Explanation:
According to the Certified Anti-Money Laundering Specialist (CAMS) Manual , 6th edition, if a bank's transaction surveillance system triggers an alert for a deposit of 250.000 USD into a client's account, the bank should take the following actions:
Request information and documentation from the client on the background of the transaction (CAMS Manual,
6th edition, page 46).
Contact the client advisor to learn if he has any insight on the transaction background (CAMS Manual, 6th edition, page 47).
Review the transaction background in the bank's transaction platform (CAMS Manual, 6th edition, page 47).
Discarding the alert as a false positive hit and reviewing the alert if the deposit is made in cash should not be done.
The bank should request additional information and documentation from the client to better understand the nature of the transaction. Additionally, the bank should reach out to the client advisor to learn if they have any insight on the transaction background. Finally, the bank should review the transaction background in the bank's transaction platform to determine if any additional alerts or anomalies are present. (CAMS Manual, 6th Edition, Pages 117-118)
NEW QUESTION # 200
A profitable commercial customer who operates an import-export business has multiple accounts with the same institution at branches m different locations. The customer receives funds from a jurisdiction perceived as highly corrupt according to Transparency International ratings. The customer makes frequent transfers among the accounts and prefers to manage the accounts separately. What should the institution do to mitigate the risk associated with these accounts?
Answer: B
NEW QUESTION # 201
What do the Financial Action Task Force (FATF) mutual evaluations of each member assess?
Answer: D
Explanation:
A compliance officer should consider the following three factors as part of the approach to implement an enterprise-wide anti-money laundering program for a bank that operates in multiple countries:
* The types of customers serviced by the bank: Different types of customers may pose different levels of money laundering risk, depending on their nature, source of funds, geographic location, transaction patterns, and other factors. A compliance officer should identify and assess the money laundering risk associated with each customer type and segment, and apply appropriate due diligence measures, monitoring systems, and risk mitigation strategies accordingly12.
* The extent of anti-money laundering regulations in the various countries: A compliance officer should be aware of the legal and regulatory requirements and expectations for anti-money laundering compliance in each country where the bank operates, and ensure that the bank's policies and procedures are consistent with them. A compliance officer should also monitor any changes or updates in the anti- money laundering laws and regulations in the various countries, and adjust the bank's program accordingly34.
* The anti-money laundering risk posed by the products and services offered by the bank: Different products and services may have different features and functionalities that could be exploited by money launderers, such as anonymity, cross-border transfers, cash transactions, complex structures, or new technologies. A compliance officer should evaluate the money laundering risk associated with each product and service offered by the bank, and implement appropriate controls, safeguards, and oversight mechanisms to prevent and detect money laundering activities5 .
References:
* 1: ACAMS, CAMS Study Guide, 6th Edition, Chapter 2: Risk Assessments
* 2: FATF, Guidance for a Risk-Based Approach: The Banking Sector
* 3: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT)
* 4: Deloitte, AML Program Effectiveness Reform
* 5: ACAMS, CAMS Study Guide, 6th Edition, Chapter 4: AML Program Design
* [6]: OCC, Money Laundering: A Banker's Guide to Avoiding Problems
Reference: https://www.fatf-gafi.org/publications/mutualevaluations/documents/more-about-mutual- evaluations.html
NEW QUESTION # 202
A financial institution's (Fl's) policy is to apply enhanced due diligence (EDD) for every new client to ensure the effectiveness of the program. How should a consultant advise the Fl's management team?
Answer: C
Explanation:
According to the Anti-Money Laundering Specialist (the 6th edition) study guide, a risk-based approach for EDD means that the FI applies more or less stringent measures depending on the level of risk posed by each client1. This allows the FI to allocate its resources more efficiently and effectively, and to focus on the clients that pose the highest risk of money laundering or terrorist financing2. Applying EDD for every new client, regardless of their risk profile, may not be the best use of the FI's resources, and may not reflect the proportionality and relevance of the EDD measures3.
References:
1: CAMS Study Guide, 6th Edition, Chapter 3, Section 3.2, page 69
2: CAMS Study Guide, 6th Edition, Chapter 3, Section 3.3, page 70
3: CAMS Study Guide, 6th Edition, Chapter 3, Section 3.4, page 71
NEW QUESTION # 203
An anti-money laundering specialist at a large institution is responsible for informing senior management about the status of the anti-money laundering program across the organization. The global institution handles retail banking, commercial banking, global markets, private banking and has an affiliated securities dealer.
The specialist and the team provide corporate strategic direction to these areas on anti-money laundering related subjects. The following information is reported to executive management on a regular basis:
*Total number of suspicious transactions identified and reported
*Suspicious transaction trends
*Training that has occurred for the various units
*Status report on the anti-money laundering regulatory environment
*Summary of exception reports
Which of the following additional elements is the most useful?
Answer: C
Explanation:
the results of related audits and examinations are the most useful additional element to report to executive management on a regular basis. Audits and examinations are essential tools to assess the effectiveness and compliance of the anti-money laundering program across the organization. They can identify strengths, weaknesses, gaps, risks, and best practices in the program and provide recommendations for improvement.
They can also help to monitor the implementation of corrective actions and remediation plans. Reporting the results of audits and examinations can help executive management to oversee the performance of the program, ensure accountability, and demonstrate commitment to the anti-money laundering objectives12:
1: ACAMS Study Guide for the CAMS Certification Examination, 6th Edition, Chapter 2, page 62
2: CERTIFICATION Candidate Handbook, page 16
NEW QUESTION # 204
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