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ACAMS CAMS (Certified Anti-Money Laundering Specialists) exam is a certification exam that is designed to test the knowledge and skills of individuals involved in anti-money laundering (AML) compliance. CAMS exam covers a broad range of topics related to AML, including the legal and regulatory framework, risk assessment, customer due diligence, transaction monitoring, and reporting. It is a rigorous and challenging exam, and passing it demonstrates a high level of expertise in the field of AML.
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ACAMS Certified Anti-Money Laundering Specialist (CAMS7 the 7th edition) Sample Questions (Q108-Q113):
NEW QUESTION # 108
With which person(s) should an anti-money laundering officer coordinate when implementing a new hire screening program?
- A. Internal Auditor
- B. Local Financial Intelligence Unit
- C. Institution's Regulator
- D. Human Resources
Answer: D
NEW QUESTION # 109
In establishing procedures for the review of suspicious transactions and filling of STRs, what thing should an institution focus on?
- A. The need to have on-going training as to potential red flags that the institution might encounter
- B. The appropriateness of having a centralized review of suspicious transactions and recommendations to file an STR to ensure consistency
- C. The need not to ensure that the institution has a strong case of impropriety before filling an STR
- D. A system for tracking STRs and ensuring that appropriate supporting documentation is segregated and maintained
Answer: B
Explanation:
An institution should focus on the appropriateness of having a centralized review of suspicious transactions and recommendations to file an STR to ensure consistency. This is because a centralized review process can help to avoid duplication, inconsistency, or omission of STRs, as well as to ensure compliance with regulatory requirements and internal policies. A centralized review process can also facilitate the analysis of trends, patterns, and typologies of suspicious transactions across the institution, and enable the communication and coordination with relevant stakeholders, such as law enforcement, regulators, or other financial institutions.
ACAMS Study Guide for the CAMS Certification Examination, 6th Edition, Chapter 5, Section 5.3.1, page
1911
ACAMS CAMS Certification Video Training Course, Module 5, Lesson 5.3, video time 2:30-4:002 ACAMS CAMS Certification Practice Exam, Question 124, page 2843
NEW QUESTION # 110
A bank has opened a new account for a well-known attorney to manage client funds. During the first six months, bank staff observe the account receives multiple deposits via wire transfer. They also observe that the attorney withdraws cash, makes payments to various people, and transfers funds to the law firm's account online.
What is considered a red flag for potential money laundering in this situation?
- A. Making payment to various people
- B. Withdrawing cash
- C. Receiving multiple deposits via wire transfer
- D. Transferring funds to his law firm's account online
Answer: A
Explanation:
According to the ACAMS CAMS Study Guide, one of the methods that attorneys may use to facilitate money laundering is to make payments to third parties on behalf of their clients, using funds from their client accounts. This may obscure the source and destination of the funds, and create a false appearance of legitimate transactions. Therefore, making payment to various people is a red flag for potential money laundering in this situation.
:
ACAMS CAMS Study Guide, 6th Edition, page 117
FATF Report on Money Laundering and Terrorist Financing Vulnerabilities of Legal Professionals, June
2013, page 341
AML/CFT Red Flags for Lawyers, AML-CFT.net, October 20202
NEW QUESTION # 111
the Financing of Terrorism (CFT)]
The AML investigator is reviewing the transaction monitoring alerts and the customer's historical profile for the past two years. A review of the negative news search from a blog indicates that the customer was previously part of a terrorist group. Which activities warrant further escalation? (Select Two.)
- A. The credit transactions in the account relate mostly to salary and rental income from property.
- B. The customer has bought and sold several real estate properties over the last year.
- C. The customer remitted monies in several transactions to the account of a recognized charity non-profit organization.
- D. The account received a large cash deposit followed by systematic automated teller machine (ATM) withdrawals until the balance was nominal.
- E. The customer conducts multiple cash transactions on a regular basis which do not match the customer's occupation.
Answer: D,E
Explanation:
1. D. The account received a large cash deposit followed by systematic automated teller machine (ATM) withdrawals until the balance was nominal.
This pattern of behavior, known as "structuring" or "smurfing," is often associated with money laundering.
The large cash deposit followed by smaller withdrawals in a systematic manner raises red flags and requires further investigation.
2. E. The customer conducts multiple cash transactions on a regular basis which do not match the customer's occupation.
Conducting frequent cash transactions that do not align with the customer's stated occupation or income source is suspicious. It suggests potential attempts to hide the true origin of funds or evade reporting requirements1.
D: Large Cash Deposit Followed by ATM Withdrawals:
The large cash deposit followed by systematic ATM withdrawals is indicative of structuring, a common money laundering technique. Structuring involves breaking down large sums of money into smaller transactions to avoid detection. In this case, the customer's behavior warrants further scrutiny to determine the purpose behind these transactions.
E: Inconsistent Cash Transactions:
When a customer conducts multiple cash transactions that do not align with their stated occupation or income source, it raises suspicions. Such behavior may indicate an attempt to obscure the true origin of funds or evade reporting requirements. Investigating the reasons behind these inconsistent cash transactions is essential to assess potential money laundering risks1.
References: 1: Anti-Money Laundering Specialist (6th edition), ACAMS, Chapter 3: "Money Laundering and Terrorist Financing Methods," Section 3.1.2: "Structuring," and Section 3.1.3: "Inconsistent Cash Transactions."
NEW QUESTION # 112
When should a financial institution (FI) exit a relationship? (Choose two.)
- A. The FI's requirements for opening an account
- B. The FI's stated policies and procedures for closing an account
- C. The suspicious conduct of the account holder
- D. The request from law enforcement to close the account
- E. The reputational risk to the FI posed by closing the account
Answer: B,C
Explanation:
A financial institution (FI) should exit a relationship when the suspicious conduct of the account holder or the FI's stated policies and procedures for closing an account warrant such action. A FI has the right and responsibility to terminate a customer relationship that poses an unacceptable level of risk to the FI or violates its AML/CFT program. A FI should have clear and consistent criteria for exiting a relationship, such as the number and severity of SARs filed, the nature and extent of due diligence conducted, the availability and effectiveness of mitigating controls, and the alignment of the customer profile with the FI's risk appetite. A FI should also document the rationale and process for exiting a relationship, communicate the decision to the customer and relevant stakeholders, and monitor the account until closure.
The reputational risk to the FI posed by closing the account or the request from law enforcement to close the account are not valid reasons for exiting a relationship by themselves. A FI should consider the potential reputational impact of closing an account, but it should not outweigh the legal and regulatory obligations of the FI to prevent and detect money laundering and terrorist financing. A FI should also cooperate with law enforcement requests, but it should not automatically close an account based on such requests, as they may interfere with ongoing investigations or intelligence gathering. A FI should exercise its own judgment and discretion in deciding whether to exit a relationship, based on its own policies and procedures and the facts and circumstances of each case.
Exiting Relationships: Ten Steps to a Successful Client Exit Strategy
De-risking your SARs: Building SAR relationship exit strategies into your AML/CFT program Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations
NEW QUESTION # 113
......
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