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NEW QUESTION # 335
According to the Financial Action Task Force (FATF). potential risk indicators related to money laundering proceeds from environmental crimes include. (Select Two.)
- A. unexplained wealth and cash transfers involving senior officials or politically exposed persons for their family members) with a position of responsibility related to the management or preservation of natural resources.
- B. waste management sector companies based in high-risk jurisdictions with payments or trade invoices tor types of waste aligned with those they are authorized to process.
- C. small cash transfers from cash-Intensive businesses to beneficiaries in areas known as a source of gold mining, illegal logging, and Illegal land clearing.
- D. frequent payments from companies in the logging. milling, or waste trade sectors to individuals or beneficiaries unrelated to the legal parson activity or business.
Answer: A,D
NEW QUESTION # 336
An audit completed the previous week revealed that a private banking customer submitted incomplete documents when establishing an account earlier m the year. The customer received weekly electronic fund transfers from a narcotic-producing jurisdiction. While the relationship manager who opened the account is on leave for 5 weeks, the customer requests that the institution remit a substantial sum to a country that represents a high risk of money laundering. The relationship manager is a friend of the anti-money laundering specialist. What should the anti-money laundering officer do first?
- A. File a suspicious transaction report with the competent authority
- B. Suspend the transfer until the relationship manager returns
- C. Investigate the transfer of funds
- D. Postpone the follow-up on the audit finding
Answer: A
NEW QUESTION # 337
A school teacher recently opened a private banking account with a major bank. The customer indicated annual income of EUR 45,000 and listed her source of wealth as a EUR 1.5 million inheritance from relatives. The customer plans to invest EUR 12,000 to 15,000 earned annually from bearer bonds. The relationship manager verified the client's identity and documented all of the above information in the account file before opening the account. During a routine review of the account, several electronic fund transfers in excess of EUR 5 million each were made from a diamond distributor. The relationship manager also noticed that in each instance, the customer immediately transferred the funds to bank accounts in Hong Kong. Which of the following is appropriate for the anti-money laundering specialist to recommend?
- A. Arrange a meeting between the customer and legal department.
- B. Investigate the source and purpose of the transactions.
- C. Suspend further customer transactions through the bank.
- D. Contact the competent authority and local law enforcement.
Answer: B
NEW QUESTION # 338
Combating the Financing of Terrorism (CFT)]
A non-US bank is implementing a sanctions compliance program. Which extraterritorial reach of Office of Foreign Assets Control (OFAC) regulations would matter the most to the foreign bank?
- A. OFAC sanctions programs prohibit transactions and require the blocking of assets of foreign individuals that appear in negative media sources.
- B. OFAC administers sanctions based on criminal investigations against targeted foreign individuals.
- C. OFAC has the power to impose significant penalties on foreign individuals who are found to be in violation of the blocking orders.
- D. OFAC acts only under presidential wartime emergency powers, against countries and foreign individuals considered enemies of the US.
Answer: C
Explanation:
This includes civil monetary penalties, criminal prosecution, and other enforcement actions. These penalties can be enforced against foreign individuals, regardless of whether the individual is located within the US or abroad. Additionally, OFAC has the authority to impose sanctions on foreign countries and foreign individuals, including individuals and entities located outside of the US.
NEW QUESTION # 339
Note: This question is part of a series of questions that present the same scenario. Each question in the series contains a unique solution that might meet the stated goals. Some question sets might have more than one correct solution, while others might not have a correct solution.
After you answer a question, you will NOT be able to return to it. As a result, these questions will not appear in the review screen.
You are developing an application that uses an Azure Kubernetes Service (AKS) cluster.
You are troubleshooting a node issue.
You need to connect to an AKS node by using SSH.
Solution: You run the kubect1 command, and then you create an SSH connection.
Does this meet the goal?
- A. Yes
- B. No
Answer: B
NEW QUESTION # 340
Which regulatory bodies cooperate when dealing with cross-border suspicious or unusual financial activity investigations?
- A. Wolfsberg Groups
- B. Financial Intelligence Units
- C. Financial Action Task Forces
- D. European Commissions
Answer: B
Explanation:
Explanation
Financial Intelligence Units (FIUs) are the primary channels for sharing financial intelligence both within countries and across borders. FIUs cooperate with each other and other relevant law enforcement, regulatory, or intelligence agencies in the fight against money laundering, terrorism financing, and other financial crimes.
NEW QUESTION # 341
Which factors specific to the securities industry increase the exposure to money laundering risk? (Select Two.)
- A. The link to sanctioned countries
- B. The speed of the transactions
- C. The increase of sector-specific guidance
- D. The practice of brokerage firms maintaining securities as nominees
- E. The complexity of the securities business
Answer: B,D
Explanation:
The practice of brokerage firms maintaining securities as nominees and the speed of the transactions are two factors specific to the securities industry that increase the exposure to money laundering risk. Nominee accounts can be used to conceal beneficial ownership and obscure transaction trails. The speed of transactions can make it difficult to detect and prevent suspicious activity in real time.
NEW QUESTION # 342
A suspicious transaction report has been filed on an account owned by the wife of the bank's ChiefExecutive Officer. Which of the following is the most important consideration when deciding whether to recommend closing the account?
- A. Customer relations
- B. Requests from the competent authority
- C. Chief Executive's reputational risk
- D. The institution's anti-money laundering policy
Answer: D
Explanation:
The most important consideration when deciding whether to recommend closing the account is the institution' s anti-money laundering policy. This is because the policy should provide clear and consistent criteria for account closure decisions, based on the risk assessment, the nature and severity of the suspicious activity, the customer due diligence information, and the legal and regulatory obligations of the institution. The policy should also ensure that the account closure process is independent, objective, and transparent, and that it does not compromise the confidentiality of the suspicious transaction report or the investigation.
References: =
* ACAMS Study Guide for the CAMS Certification Examination, 6th Edition, Chapter 5, Section 5.4.2, page 1971
* ACAMS CAMS Certification Video Training Course, Module 5, Lesson 5.4, video time 9:00-10:302
* ACAMS CAMS Certification Practice Exam, Question 145, page 2863
NEW QUESTION # 343
A branch manager for a small community bank has a new customer who deposits four EUR 50,000 checks into one account. Shortly thereafter, the customer goes to another branch and asks to transfer all but EUR 1,500 to three accounts in different foreign jurisdictions.
Which suspicious activity should be the focus of the suspicious transaction report?
- A. The customer opened the account with four large checks
- B. The customer asks to transfer funds to accounts in three different foreign jurisdictions
- C. The customer transfers almost all of the funds out of the account
- D. The customer goes to a different branch to make this transaction
Answer: B
NEW QUESTION # 344
In the FATF 40 recommendations, the focus of AML efforts has been expanded beyond Financial Institutions.
Which three businesses and/or professions are covered? Choose 3 answers
- A. Real estate agents when they are involved in transactions for clients concerning buying and selling properties
- B. Dealers in art, when they engage in any cash transaction with a customer at or above a designated threshold
- C. casinos, when customers engage in financial transactions equal to or above a designated Threshold
- D. Trust and company service providers
Answer: A,C,D
Explanation:
According to the FATF 40 recommendations, the focus of AML efforts has been expanded beyond financial institutions to include other businesses and professions that are vulnerable to money laundering and terrorist financing risks. These include:
Casinos, when customers engage in financial transactions equal to or above a designated threshold. Casinos are required to identify and verify the identity of their customers, keeprecords of transactions, report suspicious transactions, and implement internal controls and compliance programs to prevent money laundering and terrorist financing. The designated threshold is USD/EUR 3,000 or more1.
Real estate agents, when they are involved in transactions for clients concerning buying and selling properties.
Real estate agents are required to identify and verify the identity of their customers and beneficial owners, keep records of transactions, report suspicious transactions, and implement internal controls and compliance programs to prevent money laundering and terrorist financing. Real estate transactions can involve large amounts of money and complex legal arrangements that can be used to conceal the source or destination of illicit funds2.
Trust and company service providers, when they prepare for or carry out transactions for a client concerning the creation, operation or management of legal persons or arrangements. Trust and company service providers are required to identify and verify the identity of their customers and beneficial owners, keep records of transactions, report suspicious transactions, and implement internal controls and compliance programs to prevent money laundering and terrorist financing. Trust and company service providers can facilitate the misuse of legal persons or arrangements, such as shell companies or trusts, to hide the true ownership and control of assets or funds3.
The other option, dealers in art, when they engage in any cash transaction with a customer at or above a designated threshold, is not covered by the FATF 40 recommendations. However, dealers in precious metals and stones are covered when they engage in any cash transaction with a customer at or above a designated threshold of USD/EUR 15,000 or more. Dealers in art may be subject to national or regional regulations that impose AML obligations on them, depending on the jurisdiction.
FATF Recommendation 22: Designated Non-Financial Businesses and Professions: Customer Due Diligence FATF Recommendation 23: Designated Non-Financial Businesses and Professions: Other Measures FATF Recommendation 24: Transparency and Beneficial Ownership of Legal Persons
[FATF Recommendation 25: Transparency and Beneficial Ownership of Legal Arrangements]
NEW QUESTION # 345
According to experts, what is the most effective way to prevent money laundering through financial institutions?
- A. Implementing a sound customer due diligence program
- B. Ensuring that transaction monitoring systems can identify terrorist financing
- C. Collecting information on beneficial owners and foreign customers
- D. Instituting a policy prohibiting the acceptance of funds intended for terrorist financing
Answer: A
Explanation:
Implementing a sound customer due diligence (CDD) program is the most effective way to prevent money laundering through financial institutions, according to experts. CDD is the process of identifying and verifying the identity of customers and assessing their risk profile, source of funds, and expected activity.
CDD helps financial institutions to detect and prevent money laundering by enabling them to know their customers, monitor their transactions, and report any suspicious or unusual behavior. CDD is also a key requirement of the international standards and best practices for anti-money laundering and combating the financing of terrorism (AML/CFT), such as the Financial Action Task Force (FATF) Recommendations and the Basel Committee on Banking Supervision (BCBS) Guidelines.
The other options are not as effective as CDD, as they are either too narrow or too broad in scope. Ensuring that transaction monitoring systems can identify terrorist financing is important, but it does not address the broader issue of money laundering, which may involve other types of criminal proceeds or activities.
Collecting information on beneficial owners and foreign customers is a part of CDD, but it is not sufficient by itself, as it does not cover the risk assessment and ongoing monitoring aspects of CDD. Instituting a policy prohibiting the acceptance of funds intended for terrorist financing is a good practice, but it is not a preventive measure, as it relies on the assumption that the funds are already identified as such, which may not be the case.
:
Customer Due Diligence - FATF-GAFI.ORG
Sound management of risks related to money laundering and financing of terrorism - Bank for International Settlements CAMS Study Guide 6th Edition, page 36-37.
NEW QUESTION # 346
A suspicious transaction report filed on a car dealer structuring deposits initiates a criminal investigation. The dealer changes branches and begins placing transactions with a frontline employee to whom the dealer has given numerous gifts.
This employee handles all of the dealer's structured deposits and does not report the suspicious activity internally.
The competent authority has advised the anti-money laundering specialist to avoid tipping off the employee until the investigation is finalized.
What action should the specialist take next?
- A. Consult with senior management and the legal advisor.
- B. Advise that the dealer's accounts should be closed.
- C. Inform the institution's regulatory agency of the situation.
- D. Recommend the immediate termination of the employee.
Answer: A
Explanation:
it describes the action that the anti-money laundering specialist should take next, which is to consult with senior management and the legal advisor. This is because the specialist needs to seek guidance and approval from the higher authorities and the legal experts on how to handle the situation without compromising the ongoing criminal investigation or violating the anti-money laundering laws and regulations. The specialist also needs to ensure that the institution's internal policies and procedures are followed and that the appropriate measures are taken to mitigate the risks and protect the reputation of the institution.
The other options are not necessarily actions that the anti-money laundering specialist should take next, although they may be considered or implemented later depending on the outcome of the consultation and the investigation. Option A describes a possible consequence for the employee, which is to recommend the immediate termination of the employee, but this may not be the best course of action at this stage, as it may alert the employee or the dealer of the investigation, or it may be premature or disproportionate without sufficient evidence or due process. Option B describes a possible measure for the dealer, which is to advise that the dealer's accounts should be closed, but this may not be feasible or advisable at this stage, as it may also tip off the dealer or the employee of the investigation, or it may interfere with the collection of evidence or the prosecution of the case. Option D describes a possible reporting obligation for the institution, which is to inform the institution's regulatory agency of the situation, but this may not be required or appropriate at this stage, as it may conflict with the instructions of the competent authority or the confidentiality of the investigation, or it may expose the institution to legal or regulatory liabilities or sanctions.
References:
* ACAMS CAMS Certification Video Training Course - 6th Edition1
* Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)2
* ACAMS CAMS Study Guide - 6th Edition, Chapter 6, pages 132-133
https://www.acams.org/wp-content/uploads/2019/09/ACAMS-CAMS-Study-Guide-6th-Edition-Chapter-6.pdf
NEW QUESTION # 347
As a result of an audit, a policy exception was identified that had been approved by the compliance officer.
The auditor determined that the policy exception is a violation of a regulatory requirement.
What should the auditor do?
- A. Include the regulatory violation in the audit report and recommend the compliance officer be subject to disciplinary action by the board of directors.
- B. Include the regulatory violation in the audit report and report it to the board of directors.
- C. Advise the compliance officer on how to appropriately respond to policy exceptions.
- D. Consult with legal counsel to determine if the approval of the policy exception was acceptable.
Answer: B
Explanation:
The auditor should include the regulatory violation in the audit report and report it to the board of directors.
This is because the auditor has the responsibility to report any findings of non-compliance or material weaknesses in the institution's internal controls, policies, and procedures. The auditor should also provide recommendations for corrective actions and follow-up on their implementation. The board of directors has the ultimate oversight and accountability for the institution's compliance program and should be informed of any significant issues or risks that may affect the institution's reputation, operations, or regulatory status12.
References:
1: CAMS Certification Package - 6th Edition | ACAMS, Chapter 6: Developing an Effective Anti-Money Laundering Program, p. 125-126 2: The Wolfsberg Group, The Wolfsberg Anti-Money Laundering Principles for Correspondent Banking, October 2014, p. 7, https://www.wolfsberg-principles.com/sites/default/files/wb
/pdfs/Wolfsberg-Correspondent-Banking-Principles-2014.pdf
NEW QUESTION # 348
Which statement is true about when an institute becomes aware that a particular employee is under investigation by law enforcement as a result of a subpoena or warrant?
- A. Under no circumstances can the employee be interviewed by the institution without theconsent of law enforcement for fear of tipping the employee off
- B. The institute has a duty as an employer to inform the employee he or she is under investigationby law enforcement, buy must not inform them that a warrant or subpoena has been received
- C. The employee can and should be interviewed, as well as notified of the investigation todemonstrate the seriousness of the offence and to get the employee's full attention andcooperation
- D. If an independent investigation provides grounds to interview the employee, they can beinterviewed and, if necessary, terminated buy not advised that they are under investigation
Answer: D
NEW QUESTION # 349
A new AML Officer for a US-based money service business (MSB) is drafting procedures around types of activity that require further review. Which should be included? (Choose two.)
- A. A customer buying multiple money orders for $250 totaling $2,000 USD.
- B. A customer visiting multiple branches of the MSB on the same day in order to transfer funds internationally.
- C. A customer sending funds to a family member living in a high-risk jurisdiction that is subject to civil unrest.
- D. A customer attempting to buy money orders under $3,000 USD in cash multiple times a day.
- E. A customer buying several money orders totaling over $10,000 USD using debit card on the same day using government-issued identification.
Answer: B,D
Explanation:
A customer visiting multiple branches of the MSB on the same day in order to transfer funds internationally is a potential indicator of structuring, which is a technique used by money launderers to avoid reporting thresholds or detection by authorities. A customer attempting to buy money orders under $3,000 USD in cash multiple times a day is also apossible sign of structuring, as well as an attempt to evade the identification and recordkeeping requirements for MSBs. Both scenarios should be included in the procedures for further review by the AML Officer.
BSA/AML Risk Assessment for Money Services Businesses (MSBs), section "Risk Factors", sub-section
"Structuring": "Structuring is the practice of conducting financial transactions in a specific pattern calculated to avoid the creation of certain records and reports required by the BSA and/or 31 CFR Chapter X.
Structuring is illegal and is often indicative of money laundering or other illicit activity." Money Services Business (MSB) - AML Compliance Guide, section "AML Compliance Requirements for MSBs", sub-section "Identification and Recordkeeping": "MSBs must verify the identity of any person who conducts a transaction of $3,000 or more. They must also keep records of the transaction, including the name, address, date of birth, and identification number of the customer, as well as the amount, date, and method of payment."
NEW QUESTION # 350
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The Certified Anti-Money Laundering Specialists (CAMS) exam is a globally-recognized certification for professionals in the anti-money laundering (AML) field. CAMS exam is designed to test the knowledge and skills of individuals who work in compliance, AML investigations, and regulatory roles. 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 and skills of AML professionals.
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