CAMS-CN Exam Question 161
涉及銀行或其他存款機構的洗錢整合階段的例子是什麼?
Correct Answer: C
The integration stage of money laundering is where the illicit funds are reintroduced into the legitimate financial system, making them appear as lawful income or assets. This may include using multiple accounts, transferring funds between different banks or jurisdictions, and engaging in various financial activities to legitimize the illicit funds. The integration stage aims to make the illicit funds appear legitimate and indistinguishable from lawful funds within the financial system1.
Option C is an example of the integration stage of money laundering involving a bank or another deposit-taking institution, as it involves moving the illicit funds from one bank account to another, creating a complex trail of transactions that obscures the origin and ownership of the funds. This technique is also known as wire transfer laundering or electronic funds transfer laundering2.
Option A is an example of the placement stage of money laundering, as it involves depositing the illicit funds into the financial system for the first time, using a front company as a cover for the illegal source of the funds.
A front company is a legitimate business that is used to conceal or facilitate illicit activity.
Option B is an example of the layering stage of money laundering, as it involves converting the illicit cash into other forms of value that are less conspicuous and easier to move, such as negotiable instruments. Negotiable instruments are documents that promise payment to a specified person or the bearer, such as checks, money orders, or traveler's checks.
Option D is not an example of the integration stage of money laundering involving a bank or another deposit-taking institution, as it does not involve any financial transactions or accounts. It is rather an example of the integration stage of money laundering involving the purchase of goods or services, such as a luxury vehicle, with the illicit funds that had previously been deposited and layered through the financial system.
References:
* 1: Integration Stage of Money Laundering: Bank or Deposit-Taking Institution
* 2: Process of Money Laundering: Placement, Layering, Integration - Tutorial
* : ACAMS Study Guide 6th Edition, Chapter 2, page 32
* : ACAMS Study Guide 6th Edition, Chapter 2, page 34
* : The Three Stages Of Money Laundering And How Money Laundering Works Reference: https://www.moneylaundering.ca/public/law/3_stages_ML.php
Option C is an example of the integration stage of money laundering involving a bank or another deposit-taking institution, as it involves moving the illicit funds from one bank account to another, creating a complex trail of transactions that obscures the origin and ownership of the funds. This technique is also known as wire transfer laundering or electronic funds transfer laundering2.
Option A is an example of the placement stage of money laundering, as it involves depositing the illicit funds into the financial system for the first time, using a front company as a cover for the illegal source of the funds.
A front company is a legitimate business that is used to conceal or facilitate illicit activity.
Option B is an example of the layering stage of money laundering, as it involves converting the illicit cash into other forms of value that are less conspicuous and easier to move, such as negotiable instruments. Negotiable instruments are documents that promise payment to a specified person or the bearer, such as checks, money orders, or traveler's checks.
Option D is not an example of the integration stage of money laundering involving a bank or another deposit-taking institution, as it does not involve any financial transactions or accounts. It is rather an example of the integration stage of money laundering involving the purchase of goods or services, such as a luxury vehicle, with the illicit funds that had previously been deposited and layered through the financial system.
References:
* 1: Integration Stage of Money Laundering: Bank or Deposit-Taking Institution
* 2: Process of Money Laundering: Placement, Layering, Integration - Tutorial
* : ACAMS Study Guide 6th Edition, Chapter 2, page 32
* : ACAMS Study Guide 6th Edition, Chapter 2, page 34
* : The Three Stages Of Money Laundering And How Money Laundering Works Reference: https://www.moneylaundering.ca/public/law/3_stages_ML.php
CAMS-CN Exam Question 162
一名執法人員致電銀行反洗錢調查員,要求提供有關上個月提交的可疑交易報告的資訊。
調查人員該如何應對?
調查人員該如何應對?
Correct Answer: A
A U.S. bank must block or reject an international funds transfer when there is an OFAC designated party to the transaction, regardless of the beneficiary or the correspondent bank. This is because the U.S. bank is prohibited from dealing with any person or entity that is on the Specially Designated Nationals and Blocked Persons List (SDN List) or subject to any other OFAC sanctions program1. The SDN List includes individuals, groups, and entities, such as terrorists and narcotics traffickers, that are designated under programs that are not country-specific2. The U.S. bank must also report any blocked or rejected transactions to OFAC within 10 business days3.
References: 1: FFIEC BSA/AML Office of Foreign Assets Control - Office of Foreign ... 2: Specially Designated Nationals And Blocked Persons List (SDN) Human ... 3: [Reporting Blocked Transactions | Office of Foreign Assets Control]
References: 1: FFIEC BSA/AML Office of Foreign Assets Control - Office of Foreign ... 2: Specially Designated Nationals And Blocked Persons List (SDN) Human ... 3: [Reporting Blocked Transactions | Office of Foreign Assets Control]
CAMS-CN Exam Question 163
一家金融機構因客戶存入大量大額貨幣來償還貸款而提交可疑交易報告。執法人員致電反洗錢官員討論可疑交易報告。法律允許反洗錢官員執行下列哪一項操作?
1. 討論所報告活動的各個面向。
2. 提供客戶貸款文件影本。
3. 解釋客戶的貸款支付歷史。
4. 發送可疑交易報告中提到的存款文件。
1. 討論所報告活動的各個面向。
2. 提供客戶貸款文件影本。
3. 解釋客戶的貸款支付歷史。
4. 發送可疑交易報告中提到的存款文件。
Correct Answer: B
According to the guidance issued by the Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies, a financial institution is legally permitted to discuss any aspects of the reported activity with the law enforcement officer who contacts them about the suspicious transaction report (SAR), as long as the officer provides appropriate credentials and a written request for the information. The financial institution is also legally permitted to send the deposit documents referenced in the SAR, as they are part of the supporting documentation that may be requested by law enforcement1 However, the financial institution is not legally permitted to provide copies of the customer's loan documents or explain the customer's loan payment history, as they are not directly related to the reported activity and may contain confidential information that is protected by privacy laws or contractual agreements. The financial institution should only disclose the minimum amount of information necessary to respond to the law enforcement request and should not volunteer any information that is not relevant or requested12 References:
* 1: Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations, FinCEN and Federal Banking Agencies, 2021, Question 1
* 2: The best practices for effective Suspicious Activity Reporting, The Payments Association, 2020
* 1: Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations, FinCEN and Federal Banking Agencies, 2021, Question 1
* 2: The best practices for effective Suspicious Activity Reporting, The Payments Association, 2020
CAMS-CN Exam Question 164
根據金融行動特別工作小組的規定,在什麼情況下金融機構應退出與客戶的關係?
Correct Answer: A
According to the Financial Action Task Force (FATF), financial institutions should apply a risk-based approach to customer due diligence (CDD), which includes obtaining and updating information on the identity, beneficial ownership, and business activities of their clients. If a client refuses to provide or update such information, or provides false or misleading information, the financial institution should consider this as a red flag for potential money laundering or terrorist financing, and should exit the relationship with the client, unless the circumstances warrant otherwise. Exiting the relationship with a client who refuses to update information is also consistent with the FATF's Recommendation 10, which requires financial institutions to terminate the business relationship if they are unable to perform CDD measures.
References:
1: This document contains the FATF's 40 Recommendations, which are the international standards for combating money laundering and terrorist financing. Recommendation 10 covers the CDD requirements for financial institutions, and paragraph 22 states that "If the financial institution is unable to comply with paragraphs 10 to 12, 15 and 17, it should not open the account, commence business relations or perform the transaction; or should terminate the business relationship; and should consider making a suspicious transactions report in relation to the customer."
2: This document provides guidance on the implementation of the FATF's Recommendations on transparency and beneficial ownership, which are relevant for CDD purposes. It explains the definition of beneficial owner, the risks associated with legal persons and arrangements, and the effective mechanisms to combat the misuse of such entities. It also provides examples of situations where financial institutions should exit the relationship with a client, such as when the client refuses to provide or update information on beneficial ownership or control, or when the client is a shell company or a trust with no legitimate economic purpose.
References:
1: This document contains the FATF's 40 Recommendations, which are the international standards for combating money laundering and terrorist financing. Recommendation 10 covers the CDD requirements for financial institutions, and paragraph 22 states that "If the financial institution is unable to comply with paragraphs 10 to 12, 15 and 17, it should not open the account, commence business relations or perform the transaction; or should terminate the business relationship; and should consider making a suspicious transactions report in relation to the customer."
2: This document provides guidance on the implementation of the FATF's Recommendations on transparency and beneficial ownership, which are relevant for CDD purposes. It explains the definition of beneficial owner, the risks associated with legal persons and arrangements, and the effective mechanisms to combat the misuse of such entities. It also provides examples of situations where financial institutions should exit the relationship with a client, such as when the client refuses to provide or update information on beneficial ownership or control, or when the client is a shell company or a trust with no legitimate economic purpose.
CAMS-CN Exam Question 165
個人使用非文件驗證在離岸賭博網站上開設電子帳戶,並在行動裝置上建立電子錢包。為了為帳戶添加資金,個人使用信用卡、電匯、加密貨幣和貨幣服務業務。哪一種資金來源代表洗錢風險較大?
Correct Answer: B
Cryptocurrency is a digital or virtual currency that uses cryptography to secure and verify transactions.
Cryptocurrencies are decentralized and operate outside the control of any central authority, such as a government or a bank. This makes them attractive for money launderers, who can use them to transfer funds anonymously, quickly, and globally, without leaving a trace or being subject to regulation. Cryptocurrencies pose more risk of money laundering than other sources of money, such as wire transfers, credit cards, or money service businesses, which are subject to more oversight, verification, and reporting requirements.
References:
CAMS Study Guide, 6th Edition, Chapter 1, Section 1.9, page 37
CAMS eLearning Course, Module 1, Lesson 9
ACAMS Crypto Hub
Reference: https://complyadvantage.com/knowledgebase/money-laundering-crypto-exchanges/
Cryptocurrencies are decentralized and operate outside the control of any central authority, such as a government or a bank. This makes them attractive for money launderers, who can use them to transfer funds anonymously, quickly, and globally, without leaving a trace or being subject to regulation. Cryptocurrencies pose more risk of money laundering than other sources of money, such as wire transfers, credit cards, or money service businesses, which are subject to more oversight, verification, and reporting requirements.
References:
CAMS Study Guide, 6th Edition, Chapter 1, Section 1.9, page 37
CAMS eLearning Course, Module 1, Lesson 9
ACAMS Crypto Hub
Reference: https://complyadvantage.com/knowledgebase/money-laundering-crypto-exchanges/
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