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ACAMS CAMS (Certified Anti-Money Laundering Specialists) Exam is a highly respected certification program that is designed to help professionals in the financial crime prevention field to demonstrate their expertise in the industry. Certified Anti-Money Laundering Specialists certification is recognized globally and is highly valued by employers in financial institutions, regulatory bodies, and law enforcement agencies. The CAMS Certification is awarded by the Association of Certified Anti-Money Laundering Specialists (ACAMS) which is the largest international membership organization dedicated to enhancing the knowledge, skills, and expertise of AML/CTF professionals.
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NEW QUESTION # 80
Which step should financial institutions take when complying with sanctions requirements?
Answer: D
Explanation:
The financial institution should freeze the funds or assets of designated persons and entities once this decision is approved by the Board. This is to comply with the obligation to implement targeted financial sanctions imposed by the United Nations Security Council (UNSC) or other relevant authorities. Freezing means preventing any access, use, transfer, or disposal of the funds or assets by the designated persons and entities or by any other person on their behalf. The financial institution should also report the freezing action to the competent authority and the relevant sanctions committee12.
Option A is not a sufficient step to comply with sanctions requirements, but rather a tool to facilitate compliance. Adopting automatic screening systems to detect designated persons and entities can help the financial institution to identify potential matches and flag them for further investigation. However, screening systems are not infallible and may generate false positives or false negatives. Therefore, the financial institution should also conduct manual checks and verification of the screening results13.
Option B is not a relevant step to comply with sanctions requirements, but rather a measure to mitigate money laundering and terrorist financing risks. Conducting enhanced due diligence for prohibited entities on the sanctions list may be useful to obtain more information about the nature and purpose of the business relationship, the source and destination of the funds, and the beneficial ownership and control structure of the entity. However, enhanced due diligence does not replace the obligation to freeze the funds or assets of the designated persons and entities14.
Option C is not an appropriate step to comply with sanctions requirements, but rather a violation of the obligation to freeze the funds or assets of the designated persons and entities. Changing the risk profile to "high-risk" if an existing customer becomes a sanctioned entity and continuing to monitor further transactions may expose the financial institution to legal and reputational risks, as well as potential sanctions evasion or circumvention. The financial institution should terminate the business relationship with the designated person or entity and freeze their funds or assets without delay1 .
NEW QUESTION # 81
To ensure compliance with economic sanctions established by governmental authorities in the jurisdictions where it operates, a financial institution requires that all new and existing customers be screened at onboarding and quarterly thereafter.
Is this step sufficient to ensure compliance?
Answer: C
Explanation:
Screening customers at onboarding and quarterly thereafter is not sufficient to ensure compliance with economic sanctions, as sanctions lists may change frequently and the financial institution may not be aware of the latest updates. Screening should occur promptly after list updates to ensure that the financial institution is not dealing with a sanctioned individual or entity, or facilitating a prohibited transaction. This is recommended by the international guidance from the Financial Action Task Force (FATF) and the Wolfsberg Group12. Screening and performing enhanced due diligence on new relationships is also important, but not the only step to ensure compliance.
References:
* CAMS Certification Package - 6th Edition | ACAMS, Chapter 3: Sanctions, page 86
* The Wolfsberg Group Correspondent Banking Due Diligence Questionnaire 2014, Section 5: Sanctions Policy, page 12
* ACAMS CAMS Certification Video Training Course - Exam-Labs, Video 3.1: Sanctions
* Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition), Question 109 The European Union Fourth Anti-Money Laundering Directive (4th AMLD) is a legal framework that aims to prevent the use of the Union's financial system for the purposes of money laundering and terrorist financing.
One of the provisions of the 4th AMLD is to lower the currency threshold for cash payments from €15,000 to
€10,000. This means that any person who makes or receives cash payments of €10,000 or more, whether in a single transaction or in several linked transactions, is subject to customer due diligence and record-keeping obligations. The 4th AMLD also extends its applicability to providers of gambling services, which are now listed as 'obliged entities'.
References:
* Directive - 2015/849 - EN - Fourth Anti-Money Laundering Directive - EUR-Lex, Article 11 and Recital 23.
* EUR-Lex - 02015L0849-20210630 - EN - EUR-Lex, Article 11 and Recital 23.
* Key elements of the 4th EU Anti-Money Laundering Directive, Section: Cash payments.
* Anti-money laundering and countering the financing of terrorism legislative package, Section: New EU AML/CFT Regulation.
NEW QUESTION # 82
An immigrant residing in the United States opens a bank account that includes a debit card. Several months later, the transactional monitoring system identifies small deposits into the account followed by corresponding ATM withdrawals from a country bordering a conflict zone.
How should the bank respond?
Answer: A
Explanation:
According to the ACAMS CAMS Certification Study Guide (6th edition), the bank should file a SAR if it knows, suspects, or has reason to suspect that a transaction involves funds derived from illegal activity, or is intended or conducted to hide or disguise funds or assets derived from illegal activity, or to evade any BSA regulation or federal law, or has no business or apparent lawful purpose, or is not the sort in which the customer would normally be expected to engage1. The scenario described in the question meets these criteria, as the small deposits and withdrawals from a high-risk country could indicate money laundering, terrorist financing, or other illicit activities. The bank should also document its decision to file or not file a SAR, and retain the supporting documentation for five years1.
The other options are not correct because they either do not comply with the BSA requirements, or do not adequately address the potential risk of the activity. Blocking any further activity could alert the customer of the bank's suspicion, and could also interfere with law enforcement investigations. Initiating an investigation into the activity could be part of the bank's due diligence process, but it does not substitute the obligation to file a SAR if the activity is suspicious. Contacting the customer could also tip off the customer, or elicit false or misleading explanations that could hinder the bank's assessment of the activity.
NEW QUESTION # 83
the Financing of Terrorism (CFT)]
Which of the following is the most likely reason for the Financial Action Task Force to remove a jurisdiction from the Non-Cooperative Countries and Territories list?
Answer: C
Explanation:
The Financial Action Task Force (FATF) is an inter-governmental body that sets standards and monitors compliance with anti-money laundering and counter-terrorist financing (AML/CFT) measures. The FATF conducts periodic mutual evaluations of its members and other jurisdictions to assess their level of implementation of the FATF Recommendations, which are the international AML/CFT standards. The FATF also identifies jurisdictions with strategic deficiencies in their AML/CFT regimes that pose a risk to the international financial system, and places them on two public lists: the High-Risk Jurisdictions subject to a Call for Action (also known as the black list) and the Jurisdictions under Increased Monitoring (also known as the grey list). The FATF works with these jurisdictions to address their deficiencies and monitors their progress through regular follow-up reports and on-site visits. The FATF may remove a jurisdiction from the list if it has made sufficient and sustainable progress in implementing the required reforms and has effectively addressed the identified strategic deficiencies. Therefore, receiving a favorable mutual evaluation is the most likely reason for the FATF to remove a jurisdiction from the list, as it indicates that the jurisdiction has met the FATF standards and has a robust AML/CFT system in place.
Conducting successful annual self-assessments, entering into a mutual legal assistance treaty, or joining the Wolfsberg Group are not sufficient reasons for the FATF to remove a jurisdiction from the list, as they do not necessarily reflect the overall compliance with the FATF Recommendations or the resolution of the strategic deficiencies. Moreover, the Wolfsberg Group is a private association of global banks that develops guidance and best practices for the financial sector on AML/CFT issues, and is not affiliated with the FATF.
:
ACAMS Study Guide for the CAMS Certification Examination - 6th Edition, Chapter 1: Risks and Methods of Money Laundering and Terrorism Financing, page 11.
ACAMS CAMS Certification Video Training Course, Module 1: Risks and Methods of Money Laundering and Terrorism Financing, Lesson 1.4: FATF and the 40 Recommendations.
About the Non-Cooperative Countries and Territories NCCT Initiative, FATF website.
NEW QUESTION # 84
During a law enforcement investigative interview regarding potential money laundering, the suspect starts making assertions and statements that the investigator believes are false.
How should the investigator respond?
Answer: C
Explanation:
QUE According to the ACAMS Study Guide, one of the skills of an effective AML investigator is to conduct investigative interviews using appropriate techniques and methods1. One of the techniques is to use open-ended questions that elicit detailed responses from the interviewee, and to avoid leading or suggestive questions that may reveal the investigator's assumptions or suspicions1. Therefore, the best option is to ask question of a material nature about the suspected false statements without revealing the suspected deception, as this would allow the investigator to gather more information and evidence, and to test the consistency and credibility of the interviewee's answers.
The other options are not advisable or effective, because:
* A. Informing the suspect that deception is obvious and continuing the interview is not a good strategy, because it may antagonize the suspect and make them less cooperative or more defensive. It may also alert the suspect to the investigator's knowledge and sources, and give them an opportunity to change or modify their story2.
* B. Advising the suspect that the interview will be terminated if there is suspicion of deception is not a good strategy, because it may create a negative impression of the investigator and the investigation, and it may discourage the suspect from providing any useful information. It may also imply that the investigator has insufficient evidence or authority to pursue the case2.
* C. Directing the interview in another direction until there is better rapport before returning back to the troubling question is not a good strategy, because it may waste time and resources, and it may lose the focus and momentum of the investigation. It may also signal to the suspect that the investigator is not confident or competent, and it may give the suspect a chance to prepare or rehearse their answers2.
References:
1: ACAMS Study Guide, 6th Edition, Chapter 4: Conducting and Supporting the Investigation, page 105. 2: 46 AML Investigator Interview Questions (And Sample Answers)
NEW QUESTION # 85
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