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| Section | Weight | Objectives |
|---|---|---|
| Topic 1: AML Compliance Framework | 25% | - Compliance program components
|
| Topic 2: Detecting and Preventing Financial Crime | 20% | - Investigations and enforcement
|
| Topic 3: Risk Management and Due Diligence | 25% | - Customer Due Diligence (CDD/KYC)
|
| Topic 4: Money Laundering and Terrorist Financing Concepts | 30% | - Global AML/CFT standards
|
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NEW QUESTION # 172
Unusual wire transfer transactions can include: (Choose two.)
Answer: A,D
Explanation:
Unusual wire transfer transactions may include transfers in different currencies between accounts at different banks for the same client, which can be used to obscure fund flows, and incoming third-party transfers followed by real estate purchases, which may indicate layering and integration stages of money laundering. These patterns deviate from typical financial behavior and warrant closer scrutiny.
NEW QUESTION # 173
A bank is preparing for a regulatory exam after a previous regulatory exam identified weaknesses in the bank's AML program. Since the last exam, the bank has improved the written AML program, hired an experienced AML compliance officer, and has taken actions to demonstrate a strong culture of compliance. The bank is now focused on getting through their transaction monitoring case backlog and completing enhancements to its sanctions screening program.
Which of the following are correct? (Select Two.)
Answer: B,C
Explanation:
B: If a bank fails to demonstrate sustained improvement or cannot resolve identified deficiencies, it can face civil or even criminal penalties from regulators. Regulators expect not just policy changes, but proof of effectiveness and ongoing compliance improvements.
C: Even after addressing many concerns, if all issues are not resolved--such as outstanding transaction monitoring backlogs--regulators may issue orders to further remediate the AML program until full compliance is achieved.
CAMS 6th Edition and regulatory guidance clarify that "regulators may impose penalties, issue consent orders, or require further remediation where weaknesses persist."
NEW QUESTION # 174
What are the common financial crime risks posed to the e-commerce business model? (Select Three.)
Answer: A,B,E
Explanation:
E-commerce business models are exposed to several financial crime risks that are clearly identified in Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) regulatory guidance, including publications from the Financial Action Task Force (FATF) and national supervisory authorities.
One key risk is the use of stolen bank card or payment data to purchase goods or services online.
E-commerce platforms are particularly vulnerable to card-not-present fraud, where criminals exploit remote payment channels to generate illicit proceeds.
Another common risk is fraud against customers through non-delivery of goods or services. In these cases, fraudulent merchants accept payments without any intention of fulfilling orders. This form of consumer fraud is recognized as a predicate offense to money laundering under AML frameworks.
Additionally, online marketplaces may be abused to move or disguise criminally obtained funds.
Criminals may conduct fake transactions, self-purchases, or repeatedly buy and resell goods to legitimize illicit funds. This activity aligns with recognized typologies such as transaction laundering and trade-based money laundering.
Although export control evasion and bribery and corruption are serious financial crimes, they are not typically considered common or inherent financial crime risks specific to standard e- commerce business models in AML/CFT guidance.
NEW QUESTION # 175
The degree of attraction that a company holds to criminal organizations is influenced by the (Select Two.)
Answer: A,B
Explanation:
The susceptibility of a company or jurisdiction to ML/TF abuse is significantly increased by:
* Permissibility of bearer shares (B):"Bearer shares make it easy to hide ownership and control, presenting a major risk for misuse by criminals."(CAMS 6th Edition, Beneficial Ownership and Company Transparency)
* Rules governing the disclosure of beneficial ownership by the jurisdiction (C):"Weak requirements or loopholes in beneficial ownership disclosure are frequently exploited to conceal criminal involvement in corporate structures."(CAMS 6th Edition, Chapter: Legal Persons and Arrangements) Incorrect Options:
* A: High or low fees are not a significant ML/TF risk driver.
* D: Ease of travel is unrelated to ML/TF risk related to company structures.
References:
CAMS 6th Edition, Beneficial Ownership and Transparency
FATF Recommendations 24, 25
NEW QUESTION # 176
Which risk factors should a financial institution (FI) examine for a new corporate customer intending to open a new bank account? (Select Three.)
Answer: A,B,E
NEW QUESTION # 177
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