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| Section | Objectives |
|---|---|
| Topic 1: Customer Due Diligence (CDD) and KYC | - Customer identification and verification - Beneficial ownership and PEP screening - Enhanced due diligence for high-risk customers |
| Topic 2: AML Compliance Framework | - Internal controls and governance - Regulatory obligations and enforcement expectations - AML compliance program structure |
| Topic 3: Financial Crime Typologies and Risk | - Risk assessment methodologies - Sanctions and embargo compliance - Common money laundering typologies across industries |
| Topic 4: Transaction Monitoring and Reporting | - Suspicious activity detection and monitoring systems - Suspicious Activity Reports (SAR) / STR filing - Case management and investigation processes |
| Topic 5: AML and CTF Fundamentals | - Money laundering and terrorist financing concepts - International AML/CTF standards and FATF recommendations - Stages and typologies of money laundering |
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問題 #533
A client who owns a swimming pool company requests to open 19 accounts at a bank, each with a debit card for its swimming pool technicians. When asked about the purpose of each account, the client explains that each technician needs a separate checking account to purchase pool chemicals.
Which available source could be used in the bank's internal investigation on this client's activities?
答案：C
解題說明：
The bank's internal investigation is aimed at understanding the activities and legitimacy of the client who wants to open multiple accounts for their swimming pool company, with each account assigned to a debit card for the company's technicians. The purpose of these accounts, as stated by the client, is to facilitate the purchase of pool chemicals. To conduct a thorough investigation, the bank can consider several available sources of information. Let's analyze each option:
A: Client's credit bureau report: The client's credit bureau report primarily contains information related to the individual's credit history, including loans, credit cards, payment patterns, and any financial obligations.
While this information may be useful in assessing the client's creditworthiness, it may not provide substantial insight into the specific activities and legitimacy of the swimming pool company or the need for multiple accounts.
B: Local law enforcement investigation report: The local law enforcement investigation report may contain information about any criminal or suspicious activities involving the client or the swimming pool company, such as fraud, money laundering, tax evasion, or other offenses. However, this source may not be readily available to the bank, as it may require a formal request or a subpoena to access. Moreover, the report may not be comprehensive or up-to-date, as it may depend on the scope and progress of the law enforcement investigation.
C: Interview swimming pool technicians and chemical suppliers: The interview with the swimming pool technicians and chemical suppliers may provide some information about the nature and frequency of the transactions involving the pool chemicals, such as the amount, the price, the payment method, and the delivery mode. However, this source may not be reliable or verifiable, as the technicians and suppliers may be biased or influenced by the client. Moreover, the interview may not be feasible or practical, as it may require the bank to contact and arrange meetings with multiple parties, which may be time-consuming and costly.
D: Internet search showing how such business are typically operated: The internet search showing how such business are typically operated may provide some information about the industry standards and best practices for running a swimming pool company, such as the average number of technicians, the typical expenses, the common suppliers, and the expected revenue. This source may be useful in comparing and contrasting the client's business model and operations with the industry norms and identifying any red flags or anomalies.
Moreover, this source may be easily accessible and inexpensive, as it may only require the bank to use a web browser and a search engine.
Therefore, the best available source for the bank's internal investigation on this client's activities is option D.
1: CAMS Certification Package - 6th Edition | ACAMS 2: CAMS Certifications: How to Get CAMS Certified
| ACAMS 3: ACAMS CAMS Certification Video Training Course - Exam-Labs 4: Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition) 5: Bank's Internal Investigation on Client's Activities | CAMS Exam Prep 6: South Florida: Couple arrested for more than $2 million fraud 7: Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations
問題 #534
Combating the Financing of Terrorism (CFT)]
Which type of sanctions are most likely to be used in order to avoid escalating violent conflicts and/or proliferation of weapons?
答案：C
解題說明：
Arms and related materials embargo is a type of sanction that prohibits the supply, sale, transfer, or export of arms and related materials to a targeted country, entity, or individual. This type of sanction is most likely to be used in order to avoid escalating violent conflicts and/or proliferation of weapons, as it aims to reduce the availability and access of weapons and ammunition that could fuel violence and instability. Arms and related materials embargo can also prevent the transfer of weapons of mass destruction and their delivery systems to non-state actors or rogue states. According to the UN, arms and related materials embargo is one of the most common and effective forms of sanctions that the Security Council imposes to address threats to international peace and security12.
:
1: Different types of sanctions - Consilium1
2: UN Sanctions and the Prevention of Conflict - United Nations University2 Reference: https://collections.unu.edu/eserv/UNU:6431/UNSanctionsandPreventionConflict-Aug-2017.pdf (3)
問題 #535
The most important anti-money laundering issue associated with on-line banking is accurately
答案：D
解題說明：
One of the main challenges of online banking is verifying the identity of customers who open accounts or conduct transactions remotely, without face-to-face interaction. This poses a higher risk of money laundering, as criminals may use false or stolen identities, or hide behind shell companies or nominees, to move illicit funds through online platforms. Therefore, online banking providers must implement robust and risk-based customer due diligence (CDD) measures, such as verifying identity documents, using biometric or digital verification methods, screening customers against sanctions and watchlists, and monitoring customer behavior and transactions for any red flags or anomalies.
ACAMS Study Guide for the CAMS Certification Examination, 6th Edition, Chapter 2: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), Section 2.2:
Customer Due Diligence (CDD) and Know Your Customer (KYC), p. 32-35.
eWallets: AML Risks & How to Comply1
問題 #536
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?
答案：D
問題 #537
Bank A is located in Country A.
A wire transfer from Bank B located in Country B is processes by Bank A, where the funds are being moved to a customer at Bank C located in Country C.
The wire transfer is deemed suspicious by Bank A.
Who should Bank A file a suspicious transaction report on?
答案：D
問題 #538
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