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CAMS Certification Exam Dumps | CAMS Free Study Material
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ACAMS CAMS (Certified Anti-Money Laundering Specialists) Exam is a certification program designed for professionals working in the anti-money laundering (AML) field. CAMS exam is developed and administered by the Association of Certified Anti-Money Laundering Specialists (ACAMS), which is a non-profit organization dedicated to enhancing the knowledge and skills of AML professionals worldwide.
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ACAMS Certified Anti-Money Laundering Specialists Sample Questions (Q128-Q133):
NEW QUESTION # 128
Which factor should a bank consider before sharing information about a customer with its broker-dealer affiliate in the case of an investigation?
- A. Whether there is a mutual legal assistance treaty in place between the two institutions
- B. Whether the broker-dealer affiliate can rely on the due diligence done by the bank
- C. Whether privacy and data protection rules permit the bank to share the information with the affiliate
- D. Whether both institutions have an account or are in the process of opening an account for the customer
Answer: C
Explanation:
According to the ACAMS CAMS Certification Study Guide (6th edition), one of the challenges of information sharing within a financial group is the compliance with privacy and data protection rules that may vary across jurisdictions. Therefore, before sharing information about a customer with an affiliate, a bank should consider whether such sharing is permitted by the applicable laws and regulations, and whether the customer has consented to it. The other options are not relevant factors for information sharing in the case of an investigation.
References: ACAMS CAMS Certification Study Guide (6th edition), page 971; ACAMS CAMS Certification Video Training Course, Module 4, Lesson 22
NEW QUESTION # 129
The owner of a local retail store makes multiple deposits daily at a bank. When the owner makes these deposits, it is noted that he goes to different tellers (cashiers). The deposits consist of cash in amounts less than the currency reporting threshold. Which of the following best describes this activity?
- A. commingling
- B. layering
- C. integration
- D. structuring
Answer: A
Explanation:
The account officer has violated the principle of confidentiality by informing the customer about the legal request from law enforcement. This could amount to tipping off, which is a criminal offense in many jurisdictions. Tipping off could jeopardize the investigation, compromise evidence, and alert other potential suspects. The account officer should not discuss any details of the investigation with the customer, nor should he meet with the customer to do so. He should also report his actions to his manager and compliance department, and cooperate with law enforcement as required.
ACAMS CAMS Certification Video Training Course1, Module 4: Conducting or Supporting the Investigation, Lesson 4.3: Confidentiality and Information Sharing ACAMS CAMS Certification Study Guide2, Chapter 4: Conducting or Supporting the Investigation, Section
4.3: Confidentiality and Information Sharing, pp. 135-136
ACAMS CAMS Certification Exam Outline3, Domain 4: Conducting or Supporting the Investigation, Task
4.3: Maintain confidentiality of the investigation, p. 18
NEW QUESTION # 130
How should law enforcement obtain documentation from an institution when suspicious activity was identified? (Choose two.)
- A. Pay an employee of the accountable institution to make copies of the documents.
- B. Request copies of the relevant documents from the accountable institution.
- C. Request a Financial Intelligence Unit (FIU) share copies of suspicious transaction reports.
- D. Request the documents from the FIU.
- E. Acquire a search warrant to obtain the documents.
Answer: B,E
Explanation:
Law enforcement should obtain documentation from an institution when suspicious activity was identified by either requesting copies of the relevant documents from the accountable institution or acquiring a search warrant to obtain the documents. These are the legal and proper ways to access the supporting documentation that the institution is required to maintain for five years after filing a suspicious activity report (SAR). The institution must provide the documentation upon request by FinCEN or an appropriate law enforcement or supervisory agency, and should verify the identity and authority of the requestor. Law enforcement can also obtain a search warrant from a court if they have probable cause to believe that the documents contain evidence of a crime.
References:
Suspicious Activity Report Supporting Documentation
Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations, Question 1.
Obtaining Documentation from an Institution: Law Enforcement Procedures Reference:
https://www.federalregister.gov/documents/2010/12/03/2010-29869/financial-crimes-enforcement-network-conf
NEW QUESTION # 131
How do payable through accounts (PTAs) differ from normal foreign correspondent accounts?
- A. The customers can contact the correspondent bank directly to send wire transfers
- B. The customers do not have to worry about sanctions list screening such as OFAC
- C. The customers have the ability to directly control funds at the correspondent bank
- D. The customers can hide their identity through the use of cover payments in U.S. dollars
Answer: B
Explanation:
Explanation
Explanation/Reference:
Payable-Through, Pass Through, and Pass-By Accounts | Definitions and Summary A payable-through account (PTA) is also referred to as a pass through account or a pass-by account. These types of accounts are offered by US financial institutions as banking products and are used by foreign financial firms to provide their customers with access to the US financial system.
A payable-through account (PTA) is a demand deposit account through which banking agencies located in the United States extend cheque writing privileges to the customers of other institutions, often foreign banks.
PTA accounts are a concern to bank regulators because the banks or agencies providing the accounts may not subject the end customers to the same level of scrutiny as they would their own customers. These concerns were addressed in Title 3A, especially Section 311(b)(4), of the Patriot Act.
Foreign financial institutions use PTAs, also known as "pass-through" or "pass-by" accounts, to provide their customers with access to the U.S. banking system. Some U.S. banks, Edge and agreement corporations, and
U.S. branches and agencies of foreign financial institutions (collectively referred to as U.S. banks) offer these accounts as a service to foreign financial institutions. Law enforcement authorities have stated that the risk of money laundering and other illicit activities is higher in PTAs that are not adequately controlled.
What is the difference between a regular correspondent bank account and a "payable-through, pass through, or pass-by account"?
With a payable-through, pass through or pass-by account, a foreign financial firm is able to create a corresponding account in the US. However, the foreign bank also provides checks to its foreign customers who might be interested in conducting US transactions. These foreign customers are then able to write checks to withdraw from or make deposits into the account.
In general, these foreign customers of a foreign bank are not subject to anti-money laundering screening, but they end up having full access to the US financial system.
Higher Money Laundering Risk
Based on their nature, payable-through, pass through, and pass-by accounts are considered as posing higher money laundering risk concerns.
Risk Factors
PTAs may be prone to higher risk because U.S. banks do not typically implement the same due diligence requirements for PTAs that they require of domestic customers who want to open checking and other accounts.
For example, some U.S. banks merely request a copy of signature cards completed by the payable through customers (the customer of the foreign financial institution). These U.S. banks then process thousands of sub- accountholder checks and other transactions, including currency deposits, through the foreign financial institution's PTA. In most cases, little or no independent effort is expended to obtain or confirm information about the individual and business subaccountholders that use the PTAs.
Foreign financial institutions' use of PTAs, coupled with inadequate oversight by U.S. banks, may facilitate unsound banking practices, including money laundering and related criminal activities. The potential for facilitating money laundering or terrorist financing, OFAC violations, and other serious crimes increases when a U.S. bank is unable to identify and adequately understand the transactions of the ultimate users (all or most of whom are outside of the United States) of its account with a foreign correspondent. PTAs used for illegal purposes can cause banks serious financial losses in criminal and civil fines and penalties, seizure or forfeiture of collateral, and reputation damage.
NEW QUESTION # 132
Normal account-opening procedures reveal a customer who contacted a financial institution to open a bank account is the brother of a prominent member of a foreign judiciary. Which of the following actions should the anti-money laundering specialist recommend immediately?
- A. Contact the institution's legal advisor.
- B. Perform enhanced due diligence.
- C. File a suspicious transaction report with the competent authority.
- D. Monitor the customer's account.
Answer: B
Explanation:
A customer who is the brother of a prominent member of a foreign judiciary is considered a politically exposed person (PEP) or a family member of a PEP. PEPs are individuals who hold or have held positions of public trust or influence in a foreign country, such as heads of state, senior politicians, high-ranking military officers, judges, or executives of state-owned enterprises. PEPs pose a higher risk of money laundering, corruption, or bribery due to their access to public funds, influence over policy decisions, or connections to other powerful individuals. Therefore, financial institutions are required to perform enhanced due diligence (EDD) on PEPs and their family members, as well as monitor their transactions and activities more closely.
EDD is a set of additional measures that go beyond the standard customer due diligence (CDD) to obtain more information about the customer, such as their source of wealth, source of funds, expected account activity, business relationships, and reputation. EDD also involves conducting ongoing reviews and updating the customer risk profile regularly. EDD helps the financial institution to mitigate the risks associated with PEPs and detect any signs of money laundering or other illicit activities.
References:
* ACAMS Study Guide1, Chapter 2: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), pages 51-52
* FATF Guidance on Politically Exposed Persons2, pages 9-10, 13-14, 17-18
* Wolfsberg Group Guidance on Politically Exposed Persons3, pages 2-3, 6-7
NEW QUESTION # 133
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