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ACAMS Certified Anti-Money Laundering Specialists Sample Questions (Q500-Q505):
NEW QUESTION # 500
the Financing of Terrorism (CFT)]
OFAC-issued regulations apply to which entities? (Choose two.)
- A. US branches of a foreign bank
- B. Intermediaries transacting with US banks
- C. Foreign banks with US customers
- D. Foreign subsidiaries of US banks
- E. Foreign import-export companies
Answer: A,D
Explanation:
OFAC-issued regulations apply to all U.S. persons, including U.S. banks, bank holding companies, and non- bank subsidiaries, regardless of where they are located. This means that foreign subsidiaries of U.S. banks and
U.S. branches of a foreign bank are also subject to OFAC compliance. However, intermediaries transacting with U.S. banks, foreign banks with U.S. customers, and foreign import-export companies are not necessarily subject to OFAC regulations, unless they are involved in transactions that involve U.S. jurisdiction or U.S.
persons.
:
Basic Information on OFAC and Sanctions
OFAC Consolidated Frequently Asked Questions
Office of Foreign Assets Control - Overview
NEW QUESTION # 501
Which statement about U.S. Specified Unlawful Activities (SUA) is true?
- A. SUAs are limited to crimes that occur within the borders of the U.S. and its territories and possessions
- B. SUAs are generally limited to a small sub-set of crimes
- C. In order to secure a conviction, the defendant must be proven to have known the precise nature of the source of funds
- D. At least one SUA must be proven in order to pursue a money laundering conviction
Answer: D
NEW QUESTION # 502
A customer comes into the bank and appears to be ill-at-ease waiting in the teller line. When the customer gets to the teller, he become exceedingly nervous and asks for a large cashier's check to be cashed and disbursed to him in $100 bills.
What should the teller do after completing the transaction?
- A. Monitor the customer's account going forward
- B. File a CTR on the customer by the end of the day
- C. File a SAR on the customer
- D. Confer with the bank' s account going forward
Answer: A
Explanation:
A customer who is nervous, uneasy, or in a hurry to cash a large cashier's check may be trying to launder money or evade reporting requirements. The teller should complete the transaction as normal, but also flag the customer's account for further monitoring and review. The teller should look for any unusual or suspicious patterns of activity, such as frequent large cash transactions, transfers to or from high-risk jurisdictions, or transactions that do not match the customer's profile or expected behavior. The teller should also document the transaction and the customer's demeanor, and report any findings or concerns to the appropriate authority within the bank.
The teller should not confer with the bank's account going forward, as this may alert the customer to the bank's suspicion or compromise the investigation. The teller should not file a SAR on the customer, unless there are other grounds to suspect money laundering or terrorist financing, as this may be premature or unnecessary. The teller should not file a CTR on the customer by the end of the day, unless the transaction exceeds the threshold of $10,000, as this is a legal requirement for cash transactions in the US.
Reference:
[ACAMS Study Guide for the CAMS Certification Examination, 6th Edition], Chapter 4: Conducting or Supporting the Investigation Process, pp. 103-104, 107-108.
Suspicious Activity Reporting - Overview, Federal Financial Institutions Examination Council, April 2018, pp. 1-2, 4-5.
Currency Transaction Reporting - Overview, Federal Financial Institutions Examination Council, April 2018, pp. 1-2, 4-5.
17 AML Analyst Interview Questions and Answers, CLIMB, July 15, 2022.
NEW QUESTION # 503
Combating the Financing of Terrorism (CFT)]
A financial institution's (Fl's) policy is to apply enhanced due diligence (EDD) for every new client to ensure the effectiveness of the program. How should a consultant advise the Fl's management team?
- A. Suggest the management team select the clients that are chosen for EDD.
- B. Suggest the FI needs to implement a risk-based approach for EDD.
- C. Suggest the management team ask the regulator for advice on EDD measures.
- D. Suggest EDD for 50% of the clients is appropriate.
Answer: B
Explanation:
According to the Anti-Money Laundering Specialist (the 6th edition) study guide, a risk-based approach for EDD means that the FI applies more or less stringent measures depending on the level of risk posed by each client1. This allows the FI to allocate its resources more efficiently and effectively, and to focus on the clients that pose the highest risk of money laundering or terrorist financing2. Applying EDD for every new client, regardless of their risk profile, may not be the best use of the FI's resources, and may not reflect the proportionality and relevance of the EDD measures3.
References:
1: CAMS Study Guide, 6th Edition, Chapter 3, Section 3.2, page 69
2: CAMS Study Guide, 6th Edition, Chapter 3, Section 3.3, page 70
3: CAMS Study Guide, 6th Edition, Chapter 3, Section 3.4, page 71
NEW QUESTION # 504
A compliance officer is developing an anti-money laundering program for a financial institution located in a Financial Action Task Force member country. The institution conducts business with customers located in countries/jurisdictions that are not members of Financia Action Task Force. Which of the following issues should be addressed in the program?
1. The requirement to identify the beneficial owners of accounts.
2. The requirement for customer identification for the opening of new accounts.
3. The financial institution's obligation to report suspicious transactions.
4. The obligation to freeze funds involved in suspicious transactions.
- A. 1, 2, and 4 only
- B. 2, 3, and 4 only
- C. 1, 2, and 3 only
- D. 1, 3, and 4 only
Answer: C
Explanation:
A financial institution located in a Financial Action Task Force (FATF) member country should address the following issues in its anti-money laundering program when dealing with customers located in countries/jurisdictions that are not members of FATF:
* The requirement to identify the beneficial owners of accounts: Beneficial owners are the natural persons who ultimately own or control a customer or a legal entity. Identifying the beneficial owners of accounts is a key component of customer due diligence (CDD) and helps the financial institution to assess the risk profile of the customer, prevent the misuse of legal entities for money laundering or terrorist financing, and comply with the FATF Recommendations12.
* The requirement for customer identification for the opening of new accounts: Customer identification is the process of verifying the identity of a customer using reliable and independent sources of information or documents. Customer identification is another essential element of CDD and helps the financial institution to establish a business relationship with the customer, prevent identity fraud, and comply with the FATF Recommendations13.
* The financial institution's obligation to report suspicious transactions: Suspicious transactions are transactions that have no apparent economic or lawful purpose, or are inconsistent with the customer's known profile or business activities, or indicate involvement in money laundering or terrorist financing. Reporting suspicious transactions to the competent authorities is a core obligation of the financial institution under the FATF Recommendations14 and helps to detect and deter illicit activities and support law enforcement investigations.
The obligation to freeze funds involved in suspicious transactions is not an issue that should be addressed in the anti-money laundering program, as it is not a requirement under the FATF Recommendations. The FATF Recommendations require the financial institution to freeze funds or other assets of designated persons and entities that are subject to targeted financial sanctions related to terrorism, proliferation of weapons of mass destruction, or other threats to the international financial system1 . However, the financial institution is not obliged to freeze funds involved in suspicious transactions, unless it receives a specific order from the competent authorities or the courts.
References:
* The FATF Recommendations, as amended November 2023
* Interpretive Note to Recommendation 10 (Customer Due Diligence), paragraphs 5(b) and 6
* Recommendation 10 (Customer Due Diligence), paragraph 1
* Recommendation 20 (Reporting of Suspicious Transactions)
* Recommendation 6 (Targeted Financial Sanctions Related to Terrorism and Terrorist Financing), Recommendation 7 (Targeted Financial Sanctions Related to Proliferation), and Recommendation 8 (Non-Profit Organisations)
NEW QUESTION # 505
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