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| Section | Weight | Objectives |
|---|---|---|
| Topic 1: AML/CFT Compliance Programs | 28% | - Reporting and record-keeping
|
| Topic 2: Risks and Methods of Money Laundering and Terrorist Financing | 26% | - Money laundering stages and mechanisms
|
| Topic 3: Conducting and Responding to Investigations | 21% | - Investigation process and case management
|
| Topic 4: Compliance Standards for AML/CFT | 25% | - Global regulatory frameworks
|
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質問 # 54
A financial institution receives a regulatory enforcement action because of deficiencies in its anti-money laundering program.
Which action should the board of directors take?
正解：D
解説：
program
Explanation:
The board of directors is ultimately responsible for ensuring that the financial institution has an effective anti-money laundering program that complies with the applicable laws and regulations. If the institution receives a regulatory enforcement action, the board should take prompt and corrective actions to address the deficiencies and mitigate the risks of further violations or penalties. One of the most important actions is to instruct the compliance officer to develop a plan to remediate the institution's anti-money laundering program, which should include a root cause analysis, a gap assessment, a timeline, and a budget. The board should also monitor the implementation and progress of the remediation plan, and communicate with the regulators on a regular basis.
The other options are not appropriate actions for the board of directors to take in response to a regulatory enforcement action. Terminating the compliance officer and staff may not solve the underlying issues of the anti-money laundering program, and may create more disruption and instability. Purchasing and installing a new suspicious activity monitoring system may not be necessary or sufficient to address the deficiencies, and may entail additional costs and challenges. Hiring an attorney to protest the enforcement action may not be in the best interest of the institution, and may antagonize the regulators and escalate the situation.
Reference:
CAMS Certification Package - 6th Edition | ACAMS, Chapter 5: Risk Management, Section 5.2: Regulatory Examinations and Enforcement Actions, pp. 171-174.
CAMS Certifications: How to Get CAMS Certified | ACAMS, CAMS Examination Preparation Guide, Section 3: Regulatory Compliance, pp. 23-24.
質問 # 55
The anti-money laundering specialist of a small bank has identified suspicious activity at a branch located in an area of town where drug dealers are known to operate. An investigation of this activity discloses that the suspicious transactions occurred within the last 3 months and were processed by the same teller (cashier). The teller (cashier) did not file an internal report of unusual activity on these transactions. When checking personnel files, the specialist finds that the teller (cashier) has been a trusted employee for over 15 years, has an impeccable work record, and has participated in several anti-money laundering training sessions. The specialist recently became aware that the employee's daughter has contracted a rare disease and is undergoing a very expensive treatment program. Regarding the teller's (cashier's) failure to report the unusual activity to the institution, the specialist should recommend
正解：B
解説：
The specialist should recommend directing the teller (cashier) to file a suspicious transaction report (STR). This is because the teller (cashier) has failed to comply with the bank's internal policies and procedures for reporting unusual or suspicious activity, which is a key component of an effective anti-money laundering (AML) program1. The teller (cashier) should have filed an internal report of unusual activity as soon as he or she noticed the suspicious transactions, regardless of the personal circumstances or the length of service of the customer involved2. Failing to do so could expose the bank to regulatory sanctions, reputational damage, or legal liability3.
The other options are not appropriate recommendations for the specialist to make in this situation. Continuing to monitor the accounts is not sufficient, as it does not address the past non-compliance or the potential money laundering risk posed by the suspicious transactions. Refreshing anti-money laundering training for the teller (cashier) is not enough, as it does not ensure that the teller (cashier) will report the suspicious transactions or prevent future violations. Suspending the teller's (cashier's) employment is too harsh, as it does not take into account the teller's (cashier's) long and exemplary work record, the personal hardship faced by the teller's (cashier's) family, or the possibility of remedial actions or corrective measures4.
Reference:
1: Internal Controls | FinCEN.gov1 2: Reporting Suspicious Transactions - ACAMS2 3: The Consequences of Non-Compliance with AML Regulations - Blog | Unit213 4: Employee Discipline in the Workplace: A Guide for Managers4
質問 # 56
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?
正解：C
質問 # 57
One key aspect of the Office of Foreign Assets Control's extraterritorial reach includes the blocking of certain non-United States initiated transactions for or through the United States (U.S.) for benefit of a restricted person or entity.
Under which three circumstances are U.S. banks required to block transactions? (Choose three.)
正解：B、C、D
解説：
For example, if a funds transfer comes from offshore and is being routed through a U.S. bank to an offshore bank, and there is an OFAC-designated party to the transaction, it must be blocked. The definition of assets and property is broad and is specifically defined within each sanction program. Assets and property includes anything of direct, indirect, present, future, or contingent value (including all types of bank transactions). Banks must block transactions that:
* Are by or on behalf of a blocked individual or entity;
* Are to or go through a blocked entity; or
* Are in connection with a transaction in which a blocked individual or entity has an interest.
質問 # 58
The branch manager calls the compliance officer and informs her that a law enforcement officer has just left the branch and was asking a lot of question and left a business card.
What should the compliance officer do?
正解：A
質問 # 59
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