CAMS-CN Exam Question 111
下列哪一項措施是金融行動特別工作小組建議金融機構 (FI) 和指定非金融企業和專業人士 (DNFBP) 採取的措施,以減輕與外國政治公眾人物 (PEP) 的業務關係產生的風險?
Correct Answer: D
PEPs posehigher risks for corruption and money laundering, requiringenhanced due diligence (EDD).
* Option D (Correct):Understanding aPEP's source of wealth and fundsensureslegitimacy of transactions.
* Option A (Incorrect):Commercial databases help identify PEPsbutdo not mitigate risk alone.
* Option B (Incorrect):Lowering monitoring thresholds, not raising them, helps detect suspicious activity.
* Option C (Incorrect):Regulatory approval isnot required, but internal risk assessments are.
Reference:FATF Recommendation 12 (Politically Exposed Persons), Wolfsberg Group AML Guidance for PEPs.
* Option D (Correct):Understanding aPEP's source of wealth and fundsensureslegitimacy of transactions.
* Option A (Incorrect):Commercial databases help identify PEPsbutdo not mitigate risk alone.
* Option B (Incorrect):Lowering monitoring thresholds, not raising them, helps detect suspicious activity.
* Option C (Incorrect):Regulatory approval isnot required, but internal risk assessments are.
Reference:FATF Recommendation 12 (Politically Exposed Persons), Wolfsberg Group AML Guidance for PEPs.
CAMS-CN Exam Question 112
恐怖分子融資通常青睞哪三種轉移恐怖分子相關資金的管道?選出 3 個答案
Correct Answer: B,C,D
Dealers in antiques, precious metals, precious stones, jewelry, and art are advised to follow these practices to reduce the element of money laundering risk:
* Verify the identities of all new vendors and customers and conduct due diligence on them. This is to ensure that the dealers know who they are dealing with and can assess the risk level of each customer or vendor. Due diligence may include obtaining and verifying identification documents, checking against sanctions lists or watchlists, obtaining information on the source and purpose of funds, and applying a risk-based approach to the level and frequency of due diligence.
* Avoid accepting cash payment from the buyers. This is to prevent the dealers from being used as a conduit for laundering illicit cash or facilitating cash smuggling. Cash transactions are more difficult to trace and may indicate attempts to evade reporting or record-keeping requirements. Dealers should encourage the use of non-cash payment methods, such as bank transfers, cheques, or credit cards, and keep records of all payment transactions.
* Insist all vendors submit an appropriate license issued by enforcement agencies authorizing the sale.
This is to ensure that the dealers are not involved in the trade of stolen, smuggled, or counterfeit goods, which may be linked to money laundering or other criminal activities. Dealers should verify the authenticity and validity of the licenses and keep copies of them for record-keeping purposes.
:
FATF Guidance on the Risk-Based Approach for Dealers in Precious Metals and Stones, pages 9-10, 13-14,
17-18, 21-22
AML-CFT Handbook for Dealers in Precious Metals and Stones, pages 25-26, 37-38, 52-53 The anti-money laundering framework for precious stones and metals dealers in Singapore, pages 7-8, 11-12,
15-16
Dealers in Precious Metals, Stones or Jewels Required to Establish Anti-Money Laundering Programs, pages
2-3, 6-7, 10-11
* Verify the identities of all new vendors and customers and conduct due diligence on them. This is to ensure that the dealers know who they are dealing with and can assess the risk level of each customer or vendor. Due diligence may include obtaining and verifying identification documents, checking against sanctions lists or watchlists, obtaining information on the source and purpose of funds, and applying a risk-based approach to the level and frequency of due diligence.
* Avoid accepting cash payment from the buyers. This is to prevent the dealers from being used as a conduit for laundering illicit cash or facilitating cash smuggling. Cash transactions are more difficult to trace and may indicate attempts to evade reporting or record-keeping requirements. Dealers should encourage the use of non-cash payment methods, such as bank transfers, cheques, or credit cards, and keep records of all payment transactions.
* Insist all vendors submit an appropriate license issued by enforcement agencies authorizing the sale.
This is to ensure that the dealers are not involved in the trade of stolen, smuggled, or counterfeit goods, which may be linked to money laundering or other criminal activities. Dealers should verify the authenticity and validity of the licenses and keep copies of them for record-keeping purposes.
:
FATF Guidance on the Risk-Based Approach for Dealers in Precious Metals and Stones, pages 9-10, 13-14,
17-18, 21-22
AML-CFT Handbook for Dealers in Precious Metals and Stones, pages 25-26, 37-38, 52-53 The anti-money laundering framework for precious stones and metals dealers in Singapore, pages 7-8, 11-12,
15-16
Dealers in Precious Metals, Stones or Jewels Required to Establish Anti-Money Laundering Programs, pages
2-3, 6-7, 10-11
CAMS-CN Exam Question 113
關於跨國機構有能力全面調查其所有海外業務中的異常活動的說法,哪一項是正確的?
Correct Answer: A
A multinational institution may face challenges in conducting a full investigation of unusual activity across its foreign operations, due to the different legal and regulatory frameworks that apply in each jurisdiction. One of the main obstacles is the local privacy and data protection laws that may restrict the access, transfer, or disclosure of customer information, especially personal or sensitive data, to other entities within the same group or to external parties, such as law enforcement or regulators. Therefore, the institution should be aware of the local laws and regulations that govern the collection, processing, and sharing of customer data, and ensure compliance with them12.
:
ACAMS Study Guide, 6th Edition, page 191
Which statement about a multinational institution's ability to fully investigate unusual activity in all its foreign operations is correct? - Exam4Training Learn more
1blob:https://www.bing.com/12e36647-a7b4-48a5-9dff-13e7aab69e80
quizlet.com2blob:https://www.bing.com/2c9f865a-c41c-4acb-9e08-acb661cdbbe3 exam4training.com3blob:https://www.bing.com/2c9f865a-c41c-4acb-9e08-acb661cdbbe3 exam4training.com4blob:https://www.bing.com/12e36647-a7b4-48a5-9dff-13e7aab69e80 quizlet.com A multinational institution may face challenges in conducting a full investigation of unusual activity across its foreign operations, due to the different legal and regulatory frameworks that apply in each jurisdiction. One of the main obstacles is the local privacy and data protection lawsthat may restrict the access, transfer, or disclosure of customer information, especially personal or sensitive data, to other entities within the same group or to external parties, such as law enforcement or regulators. Therefore, the institution should be aware of the local laws and regulations that govern the collection, processing, and sharing of customer data, and ensure compliance with them12.
References:
ACAMS Study Guide, 6th Edition, page 191
Which statement about a multinational institution's ability to fully investigate unusual activity in all its foreign operations is correct? - Exam4Training
:
ACAMS Study Guide, 6th Edition, page 191
Which statement about a multinational institution's ability to fully investigate unusual activity in all its foreign operations is correct? - Exam4Training Learn more
1blob:https://www.bing.com/12e36647-a7b4-48a5-9dff-13e7aab69e80
quizlet.com2blob:https://www.bing.com/2c9f865a-c41c-4acb-9e08-acb661cdbbe3 exam4training.com3blob:https://www.bing.com/2c9f865a-c41c-4acb-9e08-acb661cdbbe3 exam4training.com4blob:https://www.bing.com/12e36647-a7b4-48a5-9dff-13e7aab69e80 quizlet.com A multinational institution may face challenges in conducting a full investigation of unusual activity across its foreign operations, due to the different legal and regulatory frameworks that apply in each jurisdiction. One of the main obstacles is the local privacy and data protection lawsthat may restrict the access, transfer, or disclosure of customer information, especially personal or sensitive data, to other entities within the same group or to external parties, such as law enforcement or regulators. Therefore, the institution should be aware of the local laws and regulations that govern the collection, processing, and sharing of customer data, and ensure compliance with them12.
References:
ACAMS Study Guide, 6th Edition, page 191
Which statement about a multinational institution's ability to fully investigate unusual activity in all its foreign operations is correct? - Exam4Training
CAMS-CN Exam Question 114
哪些因素應導致重新評估目前的反洗錢計畫?(選兩個。)
Correct Answer: A,E
According to the ACAMS CAMS Study Guide, 6th Edition, Chapter 2, Section 2.1, the AML program should be reassessed periodically or when there are significant changes in the business environment, such as:
Expansion of business to new territories: This could expose the business to new risks, regulations, and customers that require different AML policies, procedures, and controls. The AML program should be updated to reflect the new jurisdictions and their AML requirements, as well as to conduct appropriate risk assessments and due diligence on the new markets and customers.
New product offering: This could introduce new vulnerabilities, opportunities, and challenges for the AML program. The AML program should be revised to incorporate the new product features, benefits, and risks, as well as to ensure compliance with any applicable AML rules and standards for the new product.
The other options are not factors that would necessarily lead to a reassessment of the current AML program, unless they have a material impact on the AML risks, objectives, or performance of the business:
Appointment of a new Chief Financial Officer: This could affect the AML program if the new CFO has a different vision, strategy, or approach to AML than the previous one, or if the new CFO has a significant role or responsibility in the AML program. However, the appointment of a new CFO alone does not trigger a reassessment of the AML program, unless there are other changes or issues that warrant a review.
Change of company name: This could affect the AML program if the change of name reflects a change of ownership, structure, or nature of the business that could alter the AML risks, obligations, or expectations.
However, the change of name alone does not necessitate a reassessment of the AML program, unless there are other implications or consequences that affect the AML program.
Change of internal audit team members: This could affect the AML program if the new internal audit team members have different qualifications, skills, or experiences than the previous ones, or if the new internal audit team members have a different scope, methodology, or frequency of auditing the AML program.
However, the change of internal audit team members alone does not require a reassessment of the AML program, unless there are other factors or findings that indicate a need for a review.
References:
ACAMS CAMS Study Guide, 6th Edition, Chapter 2, Section 2.1
ACAMS CAMS Certification Video Training Course - Exam-Labs
Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)
Expansion of business to new territories: This could expose the business to new risks, regulations, and customers that require different AML policies, procedures, and controls. The AML program should be updated to reflect the new jurisdictions and their AML requirements, as well as to conduct appropriate risk assessments and due diligence on the new markets and customers.
New product offering: This could introduce new vulnerabilities, opportunities, and challenges for the AML program. The AML program should be revised to incorporate the new product features, benefits, and risks, as well as to ensure compliance with any applicable AML rules and standards for the new product.
The other options are not factors that would necessarily lead to a reassessment of the current AML program, unless they have a material impact on the AML risks, objectives, or performance of the business:
Appointment of a new Chief Financial Officer: This could affect the AML program if the new CFO has a different vision, strategy, or approach to AML than the previous one, or if the new CFO has a significant role or responsibility in the AML program. However, the appointment of a new CFO alone does not trigger a reassessment of the AML program, unless there are other changes or issues that warrant a review.
Change of company name: This could affect the AML program if the change of name reflects a change of ownership, structure, or nature of the business that could alter the AML risks, obligations, or expectations.
However, the change of name alone does not necessitate a reassessment of the AML program, unless there are other implications or consequences that affect the AML program.
Change of internal audit team members: This could affect the AML program if the new internal audit team members have different qualifications, skills, or experiences than the previous ones, or if the new internal audit team members have a different scope, methodology, or frequency of auditing the AML program.
However, the change of internal audit team members alone does not require a reassessment of the AML program, unless there are other factors or findings that indicate a need for a review.
References:
ACAMS CAMS Study Guide, 6th Edition, Chapter 2, Section 2.1
ACAMS CAMS Certification Video Training Course - Exam-Labs
Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)
CAMS-CN Exam Question 115
金融機構(FI)在決定完成內部反洗錢調查和向金融情報部門(FIU)提交可疑活動報告(SAR)的時間表時應採用哪些做法?
Correct Answer: A
Thetimely filing of SARs is legally mandated, and financial institutions mustfollow jurisdiction-specific reporting deadlines.
Option A (Correct):Regulatory requirements dictate SAR filing deadlines(e.g., in the U.S., SARs must be filed within30 calendar daysof detecting suspicious activity).
Option B (Incorrect):30 days is the U.S. standard, but different jurisdictions may havedifferent SAR deadlines (e.g.,EU AMLD mandates prompt reporting).
Option C (Incorrect):Complexity-based reporting delaysare not permitted if theyexceed regulatory timelines.
Option D (Incorrect):Relying solely on professional judgmentrather than regulatory rules can lead tonon- compliance.
SAR Filing Deadlines in Different Jurisdictions:
Jurisdiction
SAR Filing Deadline
United States (FinCEN)
30 calendar days(60 days if no suspect is identified)
United Kingdom (FCA/NCA)
As soon as practicable
European Union (6AMLD)
"Promptly" (no fixed number of days)
Australia (AUSTRAC)
3 business daysfor terrorism financing,14 business daysfor other cases
Why Timely SAR Filing Matters:
Delays in reporting can result in regulatory penalties.
Early SAR filing enables FIUs to take swift action against financial crime.
Non-compliance can lead to fines, criminal charges, and reputational damage.
Reference:
FATF Recommendation 20 (Reporting Suspicious Transactions)
FinCEN SAR Filing Requirements
6th EU Anti-Money Laundering Directive (6AMLD)
Option A (Correct):Regulatory requirements dictate SAR filing deadlines(e.g., in the U.S., SARs must be filed within30 calendar daysof detecting suspicious activity).
Option B (Incorrect):30 days is the U.S. standard, but different jurisdictions may havedifferent SAR deadlines (e.g.,EU AMLD mandates prompt reporting).
Option C (Incorrect):Complexity-based reporting delaysare not permitted if theyexceed regulatory timelines.
Option D (Incorrect):Relying solely on professional judgmentrather than regulatory rules can lead tonon- compliance.
SAR Filing Deadlines in Different Jurisdictions:
Jurisdiction
SAR Filing Deadline
United States (FinCEN)
30 calendar days(60 days if no suspect is identified)
United Kingdom (FCA/NCA)
As soon as practicable
European Union (6AMLD)
"Promptly" (no fixed number of days)
Australia (AUSTRAC)
3 business daysfor terrorism financing,14 business daysfor other cases
Why Timely SAR Filing Matters:
Delays in reporting can result in regulatory penalties.
Early SAR filing enables FIUs to take swift action against financial crime.
Non-compliance can lead to fines, criminal charges, and reputational damage.
Reference:
FATF Recommendation 20 (Reporting Suspicious Transactions)
FinCEN SAR Filing Requirements
6th EU Anti-Money Laundering Directive (6AMLD)
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