CAMS-CN Exam Question 191
大量傳入電匯會產生有關客戶的警報。資金立即以現金提取和電匯方式記入借方。為了調查此警報/案例,應先查看哪些資訊?
Correct Answer: C
When a high volume of incoming wire transfers generates an alert about a client and the funds are immediately debited by cash withdrawals and outgoing wire transfers, the first information that should be reviewed to investigate this alert/case is the customer's account activity. This is because the account activity can reveal the origin, destination, purpose, frequency, and amount of the wire transfers, as well as any unusual or inconsistent patterns that may indicate money laundering or fraud. The account activity can also help to compare the wire transfers with the customer's profile, risk rating, expected behavior, and source of funds. Reviewing the account activity can help to determine if the alert is a false positive or a true positive, and if further investigation or reporting is required.
References:
CAMS Study Guide, 6th Edition, Chapter 4, Section 4.3.2, p. 1251
Investigating Alert/Case of High Volume Wire Transfers | CAMS Exam Prep2 Wire Transfer Red Flags: Money Laundering & Fraud Risks - Alessa3
References:
CAMS Study Guide, 6th Edition, Chapter 4, Section 4.3.2, p. 1251
Investigating Alert/Case of High Volume Wire Transfers | CAMS Exam Prep2 Wire Transfer Red Flags: Money Laundering & Fraud Risks - Alessa3
CAMS-CN Exam Question 192
埃格蒙特集團建議建立一個有效的國家金融情報機構 (FIU) 的核心目標是什麼?
Correct Answer: C
According to the Anti-Money Laundering Specialist (the 6th edition) resources, the Egmont Group is an international network of FIUs that facilitates and prompts the exchange of information, knowledge, and cooperation among its members to combat money laundering, terrorist financing, and associated predicate offences1. The Egmont Group suggests that one of the core objectives that would lead to an effective national FIU is to have absolute trust amongst national and international stakeholders before sensitive information will be exchanged with confidence2. This means that the FIU should establish and maintain a high level of credibility, professionalism, and integrity in its operations, and ensure that the information it receives and disseminates is protected and used appropriately. The FIU should also comply with the Egmont Group's principles and standards for information exchange, and foster a culture of mutual trust and cooperation with other FIUs and relevant authorities3.
The other three options are incorrect because:
The FIU must operate from physically separated premises from other law enforcement agencies and government offices is not a core objective that the Egmont Group suggests for an effective national FIU.
While the FIU should have operational independence and autonomy, and be free from undue influence or interference, it does not necessarily have to be physically separated from other agencies or offices. The FIU may be located within the judicial, law enforcement, administrative, or hybrid model, depending on the country's legal and institutional framework4.
The FIU meets the Egmont Group assessment criteria is not a core objective that the Egmont Group suggests for an effective national FIU. While meeting the Egmont Group assessment criteria is a requirement for becoming and remaining a member of the Egmont Group, it is not an objective in itself. The assessment criteria are based on the FATF recommendations and the Egmont Group's own documents, and they serve as a benchmark for evaluating the FIU's compliance and effectiveness5.
The FIU must be able to promote the value of the government's commitment to embed a corruption free society within the country is not a core objective that the Egmont Group suggests for an effective national FIU. While the FIU may contribute to the prevention and detection of corruption, as well as the recovery of illicit assets, by analyzing and sharing financial intelligence, it is not the sole or primary responsibility of the FIU to promote the value of the government's commitment to embed a corruption free society within the country. This is a broader and more complex goal that involves multiple actors and factors, such as political will, legal framework, institutional capacity, civil society, media, and international cooperation.
References:
1: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 64 2: Egmont Group, Egmont Group of Financial Intelligence Units Principles for Information Exchange Between Financial Intelligence Units, June 2013, 3, p. 2 3: Egmont Group, Egmont Group of Financial Intelligence Units Principles for Information Exchange Between Financial Intelligence Units, June 2013, 3, p. 3-4 4: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 67 5: Egmont Group, Egmont Group of Financial Intelligence Units Support and Compliance Process, June 2013, [6], p. 3-4 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 4, p. 91-92 Reference: https://www.elibrary.imf.org/view/books/069/02365-9781589063495-en/ap01.xml
The other three options are incorrect because:
The FIU must operate from physically separated premises from other law enforcement agencies and government offices is not a core objective that the Egmont Group suggests for an effective national FIU.
While the FIU should have operational independence and autonomy, and be free from undue influence or interference, it does not necessarily have to be physically separated from other agencies or offices. The FIU may be located within the judicial, law enforcement, administrative, or hybrid model, depending on the country's legal and institutional framework4.
The FIU meets the Egmont Group assessment criteria is not a core objective that the Egmont Group suggests for an effective national FIU. While meeting the Egmont Group assessment criteria is a requirement for becoming and remaining a member of the Egmont Group, it is not an objective in itself. The assessment criteria are based on the FATF recommendations and the Egmont Group's own documents, and they serve as a benchmark for evaluating the FIU's compliance and effectiveness5.
The FIU must be able to promote the value of the government's commitment to embed a corruption free society within the country is not a core objective that the Egmont Group suggests for an effective national FIU. While the FIU may contribute to the prevention and detection of corruption, as well as the recovery of illicit assets, by analyzing and sharing financial intelligence, it is not the sole or primary responsibility of the FIU to promote the value of the government's commitment to embed a corruption free society within the country. This is a broader and more complex goal that involves multiple actors and factors, such as political will, legal framework, institutional capacity, civil society, media, and international cooperation.
References:
1: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 64 2: Egmont Group, Egmont Group of Financial Intelligence Units Principles for Information Exchange Between Financial Intelligence Units, June 2013, 3, p. 2 3: Egmont Group, Egmont Group of Financial Intelligence Units Principles for Information Exchange Between Financial Intelligence Units, June 2013, 3, p. 3-4 4: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 67 5: Egmont Group, Egmont Group of Financial Intelligence Units Support and Compliance Process, June 2013, [6], p. 3-4 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 4, p. 91-92 Reference: https://www.elibrary.imf.org/view/books/069/02365-9781589063495-en/ap01.xml
CAMS-CN Exam Question 193
在許多司法管轄區,金融機構禁止僱用曾犯過何種罪行的人員?
Correct Answer: B
Reference: http://www.capitol.hawaii.gov/hrscurrent/vol07_ch0346-0398/HRS0378/HRS_0378-0003.htm (See 9th point)
CAMS-CN Exam Question 194
透過貨幣服務公司或貨幣服務公司進行電匯匯款可以使用哪種方法洗錢?
Correct Answer: B
The correct answer is B, because it describes a method of money laundering known as structuring or smurfing. This is when a customer or a group of customers break down large amounts of illicit funds into smaller transactions that are below the reporting threshold, and then send them to another customer or entity, often in another country. This way, they avoid triggering any suspicion or regulatory reporting by the bureau de change or money services business (MSB) that processes the wire transfers.
Structuring or smurfing is a common technique used by money launderers to move funds across borders and disguise their origin and destination.
The other options are not necessarily indicative of money laundering, although they may require further investigation depending on the circumstances and the risk profile of the customers and countries involved.
Option A describes a regular and small wire transfer that may be legitimate, such as a remittance to a family member or a friend. Option C describes a large volume of wire transfers that may be related to a seasonal or business activity, such as a holiday or a trade event. Option D describes a series of small wire transfers that may be coincidental or random, and do not necessarily add up to a significant amount.
References:
* ACAMS CAMS Certification Video Training Course - 6th Edition1
* Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)2
* ACAMS CAMS Study Guide - 6th Edition, Chapter 2, pages 36-37
https://www.acams.org/wp-content/uploads/2019/09/ACAMS-CAMS-Study-Guide-6th-Edition-Chapter-2.pdf
Structuring or smurfing is a common technique used by money launderers to move funds across borders and disguise their origin and destination.
The other options are not necessarily indicative of money laundering, although they may require further investigation depending on the circumstances and the risk profile of the customers and countries involved.
Option A describes a regular and small wire transfer that may be legitimate, such as a remittance to a family member or a friend. Option C describes a large volume of wire transfers that may be related to a seasonal or business activity, such as a holiday or a trade event. Option D describes a series of small wire transfers that may be coincidental or random, and do not necessarily add up to a significant amount.
References:
* ACAMS CAMS Certification Video Training Course - 6th Edition1
* Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)2
* ACAMS CAMS Study Guide - 6th Edition, Chapter 2, pages 36-37
https://www.acams.org/wp-content/uploads/2019/09/ACAMS-CAMS-Study-Guide-6th-Edition-Chapter-2.pdf
CAMS-CN Exam Question 195
一家金融機構遠端抵押貸款發放部門的當地經理剛發現,沒有對新客戶進行製裁篩選。
在這種情況下,當地經理應該採取什麼行動?
在這種情況下,當地經理應該採取什麼行動?
Correct Answer: C
This action is the most appropriate because it demonstrates the local manager's responsibility and accountability for the sanctions compliance program. Sanctions screening is an important part of the Know Your Customer (KYC) and Anti-Money Laundering (AML) processes, as it helps to identify and prevent transactions with sanctioned individuals or entities, which could expose the financial institution to legal, regulatory, and reputational risks. Failing to perform sanctions screening could result in violations of sanctions laws and regulations, which could lead to fines, penalties, sanctions, or even criminal prosecution. Therefore, the local manager should immediately inform senior management of the issue, so that they can take corrective actions, such as implementing screening procedures, conducting a risk assessment, reviewing existing customers, reporting any potential violations, and providing training and guidance to the staff.
The other actions are not appropriate because they either do not address the root cause of the problem, or they could worsen the situation. Starting screening new customers without informing senior management could create a false sense of compliance, and it could also miss the existing customers who may be sanctioned.
Immediately informing the regulators without informing senior management could undermine the trust and communication within the organization, and it could also trigger an investigation or enforcement action before the issue is resolved internally. Doing nothing because the department only handles a very small number of mortgages could be a sign of negligence or indifference, and it could also expose the financial institution to significant risks, as even one transaction with a sanctioned party could have serious consequences.
References:
* CAMS Certification Package - 6th Edition | ACAMS, Chapter 4: Developing and Implementing an AML Training Program, pp. 97-98
* CAMS Certifications: How to Get CAMS Certified | ACAMS, CAMS Study Guide, pp. 76-77
* What is Sanctions Screening and How Does It Work? | Jumio, Introduction and Benefits of Sanctions Screening
* Sanctions Screening: Challenges and Control Considerations, Background and Regulatory Expectations for Sanctions Screening
* Sanction Screening: A Complete Guide | KYC AML Guide, What is Sanction Screening and Why is it Important?
The other actions are not appropriate because they either do not address the root cause of the problem, or they could worsen the situation. Starting screening new customers without informing senior management could create a false sense of compliance, and it could also miss the existing customers who may be sanctioned.
Immediately informing the regulators without informing senior management could undermine the trust and communication within the organization, and it could also trigger an investigation or enforcement action before the issue is resolved internally. Doing nothing because the department only handles a very small number of mortgages could be a sign of negligence or indifference, and it could also expose the financial institution to significant risks, as even one transaction with a sanctioned party could have serious consequences.
References:
* CAMS Certification Package - 6th Edition | ACAMS, Chapter 4: Developing and Implementing an AML Training Program, pp. 97-98
* CAMS Certifications: How to Get CAMS Certified | ACAMS, CAMS Study Guide, pp. 76-77
* What is Sanctions Screening and How Does It Work? | Jumio, Introduction and Benefits of Sanctions Screening
* Sanctions Screening: Challenges and Control Considerations, Background and Regulatory Expectations for Sanctions Screening
* Sanction Screening: A Complete Guide | KYC AML Guide, What is Sanction Screening and Why is it Important?
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