CAMS-CN Exam Question 166
下列哪項客戶與證券交易商的交易最有可能表示洗錢嫌疑最高?
Correct Answer: B
The Financial Action Task Force (FATF) Recommendation that should cause an anti-money laundering specialist the most concern is B: Financial institutions should not keep anonymous accounts. This is because anonymous accounts are accounts that are opened or maintained without verifying the identity of the customer or the beneficial owner, or with fictitious or incomplete information. Anonymous accounts pose a high risk of money laundering and terrorist financing, as they can be used to conceal the origin, destination, and purpose of illicit funds, and to evade the detection and reporting of suspicious transactions. Therefore, the FATF Recommendation 10 requires financial institutions to identify and verify the identity of their customers and the beneficial owners, and to prohibit the opening or maintaining of anonymous accounts or accounts in obviously fictitious names1.
The other options are also FATF Recommendations, but they are less relevant or applicable to the scenario.
Option A: Financial institutions should not warn their customers when information relating to them is being reported to the competent authorities, is the FATF Recommendation 21, which aims to prevent tipping-off, i.e., alerting the customer that they are being investigated or reported for money laundering or terrorist financing. However, this does not directly address the issue of identity verification or anonymous accounts2.
Option C: Financial institutions should maintain all necessary suspicious transaction report records on transactions, both domestic and international, for at least 5 years, is the FATF Recommendation 11, which aims to ensure that financial institutions have adequate and consistent records of their customers and transactions, and that these records are available to the competent authorities when needed. However, this does not prevent the opening or maintaining of anonymous accounts in the first place3. Option D: If financial institutions suspect that funds stem from criminal activity, they should be required to close the account, is not a FATF Recommendation, but rather a possible action that financial institutions may take in accordance with their risk assessment and policies. However, the FATF does not mandate or recommend the closure of accounts as a general rule, and advises that financial institutions should consult with the competent authorities before taking such action, as it may alert the customer or compromise the investigation4.
References:
1: FATF Recommendation 10: Customer due diligence, 1 2: FATF Recommendation 21: Tipping-off and confidentiality, 2 3: FATF Recommendation 11: Record keeping, 3 4: Frequently Asked Questions (FAQs) related to Suspicious Transaction Reporting, 5
The other options are also FATF Recommendations, but they are less relevant or applicable to the scenario.
Option A: Financial institutions should not warn their customers when information relating to them is being reported to the competent authorities, is the FATF Recommendation 21, which aims to prevent tipping-off, i.e., alerting the customer that they are being investigated or reported for money laundering or terrorist financing. However, this does not directly address the issue of identity verification or anonymous accounts2.
Option C: Financial institutions should maintain all necessary suspicious transaction report records on transactions, both domestic and international, for at least 5 years, is the FATF Recommendation 11, which aims to ensure that financial institutions have adequate and consistent records of their customers and transactions, and that these records are available to the competent authorities when needed. However, this does not prevent the opening or maintaining of anonymous accounts in the first place3. Option D: If financial institutions suspect that funds stem from criminal activity, they should be required to close the account, is not a FATF Recommendation, but rather a possible action that financial institutions may take in accordance with their risk assessment and policies. However, the FATF does not mandate or recommend the closure of accounts as a general rule, and advises that financial institutions should consult with the competent authorities before taking such action, as it may alert the customer or compromise the investigation4.
References:
1: FATF Recommendation 10: Customer due diligence, 1 2: FATF Recommendation 21: Tipping-off and confidentiality, 2 3: FATF Recommendation 11: Record keeping, 3 4: Frequently Asked Questions (FAQs) related to Suspicious Transaction Reporting, 5
CAMS-CN Exam Question 167
什麼顯示律師可能進行洗錢活動?
Correct Answer: A
Option A indicates potential money laundering activity by a lawyer, as it involves the use of a trust account to receive and transfer funds from unknown sources in high risk jurisdictions, without any apparent legitimate purpose or explanation. This could be a sign of layering, where the money launderer attempts to conceal the origin and ownership of the illicit funds by moving them through multiple accounts and jurisdictions. Option B does not necessarily indicate money laundering, as the source of the funds is a reputable entity and the transfer could be explained by a legitimate transaction or service. Option C does not necessarily indicate money laundering, as the bank draft could be a payment for a legal service or a settlement between parties. Option D does not necessarily indicate money laundering, as the cash deposit could be a fee for a legal service or a donation, and the amount could be below the reporting threshold to avoid unnecessary paperwork or scrutiny.
References: =
CAMS Certification Package - 6th Edition | ACAMS1
CAMS Certifications: How to Get CAMS Certified | ACAMS2
ACAMS CAMS Certification Video Training Course - Exam-Labs3
Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)4
References: =
CAMS Certification Package - 6th Edition | ACAMS1
CAMS Certifications: How to Get CAMS Certified | ACAMS2
ACAMS CAMS Certification Video Training Course - Exam-Labs3
Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)4
CAMS-CN Exam Question 168
在進行調查時,銀行在與其經紀自營商附屬機構分享客戶資訊之前應考慮哪些因素?
Correct Answer: C
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
References: ACAMS CAMS Certification Study Guide (6th edition), page 971; ACAMS CAMS Certification Video Training Course, Module 4, Lesson 22
CAMS-CN Exam Question 169
沃爾夫斯堡集團在其關於制止資助恐怖主義的聲明中提到了哪些內容容易受到恐怖主義融資的影響?
Correct Answer: C
Alternative remittance, also known as underground banking or informal value transfer systems, is a method of transferring money or value without using formal financial institutions or channels. It is often used by migrant workers, refugees, or people who lack access to formal banking services. However, it can also be exploited by criminals and terrorists to move funds across borders without detection or regulation. The Wolfsberg Group, a group of leading international banks that promotes best practices in anti-money laundering and counter-terrorist financing, cited alternative remittance as one of the sectors and activities that are widely used for the financing of terrorism in its Statement on the Suppression of the Financing of Terrorism. The Wolfsberg Group recommended that financial institutions apply enhanced and appropriate due diligence to customers engaged in alternative remittance and report any suspicious transactions to the relevant authorities.
References:
* Wolfsberg Group (2002). Wolfsberg Statement on Anti-Terrorism Financing1
* Pieth, M. (ed.) (2002). Financing Terrorism. Springer, Dordrecht2
* ACAMS (2020). CAMS Certification Package (6th Edition)3
References:
* Wolfsberg Group (2002). Wolfsberg Statement on Anti-Terrorism Financing1
* Pieth, M. (ed.) (2002). Financing Terrorism. Springer, Dordrecht2
* ACAMS (2020). CAMS Certification Package (6th Edition)3
CAMS-CN Exam Question 170
一家私人銀行高階主管的近親要求開戶。由於這種關係,工作人員無需遵循既定的開戶程序即可加快開戶速度。應用巴塞爾銀行監理委員會的原則,下列哪一項構成的操作風險最高?
Correct Answer: A
According to the Basel Committee on Banking Supervision principles, one of the core principles for effective banking supervision is that the supervisor determines that banks have adequate policies and processes for identifying, assessing and managing the risk and impact of exposures to and transactions with related parties, and that these policies and processes are effectively implemented1. Failure to conduct proper due diligence on a close relative of a senior manager who requests to open an account poses the highest operational risk, as it could result in conflicts of interest, reputational damage, legal liability, or financial losses for the bank. The other options are not necessarily the highest operational risk, as they depend on the nature and extent of the relationship, the type and size of the account, and the regulatory and legal framework of the jurisdiction.
References: 1 Core principles for effective banking supervision, Principle 20.
References: 1 Core principles for effective banking supervision, Principle 20.
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