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ACAMS CAMS Exam is recognized as the gold standard in AML certification. It is administered by the Association of Certified Anti-Money Laundering Specialists (ACAMS), a professional organization that is dedicated to advancing the AML profession through education, certification, and networking. ACAMS has over 70,000 members in more than 175 countries, making it the largest international membership organization dedicated to AML.
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ACAMS Certified Anti-Money Laundering Specialists Sample Questions (Q655-Q660):
NEW QUESTION # 655
In general, what is an element that a financial institution or business does not have to specifically address in an anti-money laundering program?
- A. A description of its OFAC program to address government watch list screening
- B. A system of internal policies, procedures and controls
- C. A designated compliance officer with day-to-day oversight over the AML program
- D. An ongoing employee training program
Answer: A
Explanation:
According to the Bank Secrecy Act (BSA), a financial institution or business must establish an anti-money laundering (AML) program that includes at least four elements: (a) a system of internal policies, procedures and controls to prevent, detect and report money laundering and other illicit activities; (b) a designated compliance officer who is responsible for overseeing the implementation and effectiveness of the AML program; an ongoing employee training program that covers the legal and regulatory obligations, the risks and red flags of money laundering, and the roles and responsibilities of the staff in the AML program; and (d) an independent audit function that tests and evaluates the adequacy and compliance of the AML program12.
While the Office of Foreign Assets Control (OFAC) is a key agency that enforces economic and trade sanctions against targeted foreign countries, entities and individuals, it is not part of the BSA or the AML program requirements. However, financial institutions and businesses are expected to comply with OFAC regulations and screen their customers and transactions against the OFAC lists of sanctioned parties. Failure to do so may result in civil or criminal penalties34. Therefore, it is advisable for financial institutions and businesses to have an OFAC program that is integrated with their AML program, but it is not a mandatory element that they have to specifically address in their AML program.
1: Financial Crimes Enforcement Network (2020). Anti-Money Laundering Programs
2: ACAMS (2020). CAMS Certification Package (6th Edition)
3: Office of Foreign Assets Control (2023). Sanctions Programs and Country Information
4: Moses & Singer LLP (2023). Anti-Money Laundering, Bank Secrecy and OFAC Regulations
NEW QUESTION # 656
An anti-money laundering specialist has been asked to create internal anti-money laundering policies, procedures and controls for a recently chartered offshore financial institution.
Which three should be included? Choose 3 answers
- A. A training program for senior management and staff
- B. Basel Committee on Banking Supervision's capital adequacy requirements for the host country
- C. An anti-money laundering compliance program, internal audit program, and procedure manual
- D. Compliance requirement of host and charting countries
Answer: A,C,D
Explanation:
these are the essential components of an effective anti-money laundering program for any financial institution, especially an offshore one. According to the CAMS Study Guide, 6th Edition, an anti-money laundering program should include the following elements1:
* A risk assessment that identifies and evaluates the money laundering and terrorist financing risks faced by the institution, and the measures taken to mitigate them.
* A compliance program that establishes policies, procedures, and controls to prevent, detect, and report money laundering and terrorist financing activities, and to comply with the applicable laws and regulations of the host and chartering countries.
* A designated compliance officer who is responsible for overseeing the implementation and maintenance of the compliance program, and for liaising with the relevant authorities and stakeholders.
* A training program that provides regular and appropriate education and awareness to senior management and staff on their roles and responsibilities in relation to anti-money laundering and terrorist financing, and on the latest trends and typologies in these areas.
* An independent audit function that reviews and tests the adequacy and effectiveness of the compliance program, and reports the findings and recommendations to senior management and the board of directors.
The Basel Committee on Banking Supervision's capital adequacy requirements for the host country (answer A) are not directly related to anti-money laundering, but rather tothe prudential regulation and supervision of banks. They are important for ensuring the financial soundness and stability of banks, but they are not sufficient to prevent or combat money laundering and terrorist financing2.
:
1: CAMS Study Guide, 6th Edition, Chapter 5: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), page 139-140. 2: Basel Committee on Banking Supervision, Bank for International Settlements.
NEW QUESTION # 657
Which activities conducted by a lawyer could be a red flag for money laundering? (Select Two.)
- A. The lawyer spent two days working a case.
- B. The lawyer was paid substantially higher than usual fees.
- C. The lawyer does not have experience in providing the particular services requested.
- D. The lawyer worked unusual hours to perform case duties.
- E. The lawyer does not document case notes for the services provided.
Answer: B,C
Explanation:
Lawyers who lack experience in providing specific services requested by clients or receive unusually high fees can raise red flags for money laundering. Inadequate documentation of case notes may also be suspicious, but the absence of experience and excessive fees are more significant indicators. These behaviors warrant further scrutiny to assess potential money laundering risks12.
References:
1. ComplyAdvantage: AML Red Flags - What are the Top 10 Indicators?
2. HyperVerge: AML Red Flags: A Guide to Identification and Response
NEW QUESTION # 658
Which is a key aspect of the first EU Directive on Money Laundering?
- A. It defined money laundering as a separate crime.
- B. It established drug trafficking as a predicate offense of money laundering.
- C. IT expanded the definition of criminal activity to all serious crimes.
- D. It extended the scope beyond drug-related crimes.
Answer: C
Explanation:
IT expanded the definition of criminal activity to all serious crimes. The first EU Directive on Money Laundering, adopted in 1990, was the first major international agreement to combat money laundering. It expanded the definition of criminal activity to all serious crimes and established drug trafficking as a predicate offense of money laundering. The Directive also extended the scope of money laundering beyond drug-related crimes, making it applicable to all serious crimes. This was a major step forward in the fight against money laundering, as it made it easier for law enforcement to investigate and prosecute money laundering cases.
NEW QUESTION # 659
Combating the Financing of Terrorism (CFT)]
Abank organized under foreign lawand located outside of the U.S. maintains acorrespondent banking relationshipwith aU.S.-based bankto handlefinancial transactions in U.S. dollarsfor its clients.
In compliance with theUSA PATRIOT Act of 2001, allU.S. banks and broker-dealers in securities must obtain a signed certificationfrom allnon-U.S. foreign bank clients conducting business with them.
What information does theUSA PATRIOT Act of 2001require theforeign bank to certify to the U.S. bank?
(Select Three.)
- A. The jurisdictions in which the foreign bank maintains a physical presence.
- B. The foreign bank will not allow indirect use of the correspondent bank accounts by shell banks.
- C. The foreign bank's operations will be limited to the country of incorporation.
- D. The ownership details of the foreign bank.
- E. The foreign bank will not allow indirect use of the correspondent bank accounts by Politically Exposed Persons (PEPs).
Answer: A,B,D
Explanation:
TheUSA PATRIOT Act Section 313 & 319(b)placesstrict requirements on foreign correspondent banking relationshipsto prevent money laundering.
* Option A (Correct):Theforeign bank must disclose its ownership structureto identifyultimate beneficial owners (UBOs).
* Option C (Correct):Theforeign bank must certify that it maintains a physical presencein a regulated jurisdiction.
* Option E (Correct):Theforeign bank must not allow shell banks to use its U.S. correspondent accounts.
Why Other Options Are Incorrect:
* Option B (Incorrect):Thecertification does not specifically exclude PEPs, butPEPs require enhanced due diligence (EDD).
* Option D (Incorrect):The foreign bankmay operate in multiple jurisdictions, but it must be regulated where it has a presence.
Key Compliance Measures for Correspondent Banking:
* Conduct EDD on foreign bank relationships.
* Ensure correspondent banks do not facilitate shell banks.
* Monitor transactions for money laundering and terrorist financing risks.
Reference:
USA PATRIOT Act Section 313 & 319(b) (Foreign Correspondent Banking Rules) FATF Recommendation 13 (Correspondent Banking Due Diligence) Wolfsberg Group Guidance on Correspondent Banking Risk Management
NEW QUESTION # 660
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