CAMS-CN Exam Question 31
建立涉及執法機構、金融情報機構 (FIU) 和私營部門之間資訊共享的公私合作夥伴關係 (PPP) 的目的是:(選擇兩個。)
Correct Answer: A,B
Public-Private Partnerships (PPPs)are collaborative initiatives involvinglaw enforcement, FIUs, and financial institutions. Their objective is to improve theefficiency and effectivenessof the fight against money laundering, terrorist financing, and other financial crimes bysharing both operational and strategic intelligence.
Option A - Exchange operational information between public authorities and obliged entities:
PPPs often facilitate real-time or near-real-time information sharing that supportsspecific investigations and the detection of suspicious activity, helping financial institutions respond quickly and accurately to ongoing threats.
Option B - Exchange strategic information between FIUs and obliged entities:
Strategic-level intelligence sharing helps financial institutionsunderstand typologies, risk trends, and evolving criminal methods, thereby strengthening their risk assessments and transaction monitoring frameworks.
Option Cis incorrect: Strategic information exchange between private institutions is limited and heavily regulated.
Option Dis incorrect: FATF does not collect or manage databases of suspicious activity reports; it sets standards and reviews national frameworks.
Reference: ACAMS CAMS Study Guide - 6th Edition, Chapter:Public-Private Partnerships and Information Sharing- Section:Purpose and Function of PPPs in AML/CFT
Option A - Exchange operational information between public authorities and obliged entities:
PPPs often facilitate real-time or near-real-time information sharing that supportsspecific investigations and the detection of suspicious activity, helping financial institutions respond quickly and accurately to ongoing threats.
Option B - Exchange strategic information between FIUs and obliged entities:
Strategic-level intelligence sharing helps financial institutionsunderstand typologies, risk trends, and evolving criminal methods, thereby strengthening their risk assessments and transaction monitoring frameworks.
Option Cis incorrect: Strategic information exchange between private institutions is limited and heavily regulated.
Option Dis incorrect: FATF does not collect or manage databases of suspicious activity reports; it sets standards and reviews national frameworks.
Reference: ACAMS CAMS Study Guide - 6th Edition, Chapter:Public-Private Partnerships and Information Sharing- Section:Purpose and Function of PPPs in AML/CFT
CAMS-CN Exam Question 32
在發現員工無意中向正在組織交易的客戶提供協助時,反洗錢專家應建議
Correct Answer: B
Structuring is the practice of breaking down large amounts of cash into smaller transactions to avoid triggering currency transaction reports (CTRs) or suspicious activity reports (SARs) by financial institutions.
CTRs are required for cash deposits or withdrawals of more than $10,000 in the United States, and SARs are filed when there is a reasonable suspicion of money laundering or other illicit activity. By making multiple deposits of less than $10,000 at different tellers, the owner of the retail store is attempting to evade the reporting requirements and conceal the source or destination of the funds. This is a common technique used by money launderers in the placement stage of the money laundering process, when they try to introduce illegal proceeds into the financial system. Structuring is illegal under the Bank Secrecy Act and can result in civil and criminal penalties.
:
6: CAMS Certification Package - 6th Edition | ACAMS, Chapter 2: Money Laundering Risks and Methods, page 43
1: Structuring Cash Deposits, Withdrawals, & Transactions Risk, Golding & Golding
2: Structuring - Wikipedia
CTRs are required for cash deposits or withdrawals of more than $10,000 in the United States, and SARs are filed when there is a reasonable suspicion of money laundering or other illicit activity. By making multiple deposits of less than $10,000 at different tellers, the owner of the retail store is attempting to evade the reporting requirements and conceal the source or destination of the funds. This is a common technique used by money launderers in the placement stage of the money laundering process, when they try to introduce illegal proceeds into the financial system. Structuring is illegal under the Bank Secrecy Act and can result in civil and criminal penalties.
:
6: CAMS Certification Package - 6th Edition | ACAMS, Chapter 2: Money Laundering Risks and Methods, page 43
1: Structuring Cash Deposits, Withdrawals, & Transactions Risk, Golding & Golding
2: Structuring - Wikipedia
CAMS-CN Exam Question 33
一家美國貨幣服務企業 (MSB) 的新反洗錢官員正在起草有關需要進一步審查的活動類型的程序。應該包括哪些?(選兩個。)
Correct Answer: A,E
A customer visiting multiple branches of the MSB on the same day in order to transfer funds internationally is a potential indicator of structuring, which is a technique used by money launderers to avoid reporting thresholds or detection by authorities. A customer attempting to buy money orders under $3,000 USD in cash multiple times a day is also apossible sign of structuring, as well as an attempt to evade the identification and recordkeeping requirements for MSBs. Both scenarios should be included in the procedures for further review by the AML Officer.
:
BSA/AML Risk Assessment for Money Services Businesses (MSBs), section "Risk Factors", sub-section
"Structuring": "Structuring is the practice of conducting financial transactions in a specific pattern calculated to avoid the creation of certain records and reports required by the BSA and/or 31 CFR Chapter X.
Structuring is illegal and is often indicative of money laundering or other illicit activity." Money Services Business (MSB) - AML Compliance Guide, section "AML Compliance Requirements for MSBs", sub-section "Identification and Recordkeeping": "MSBs must verify the identity of any person who conducts a transaction of $3,000 or more. They must also keep records of the transaction, including the name, address, date of birth, and identification number of the customer, as well as the amount, date, and method of payment."
:
BSA/AML Risk Assessment for Money Services Businesses (MSBs), section "Risk Factors", sub-section
"Structuring": "Structuring is the practice of conducting financial transactions in a specific pattern calculated to avoid the creation of certain records and reports required by the BSA and/or 31 CFR Chapter X.
Structuring is illegal and is often indicative of money laundering or other illicit activity." Money Services Business (MSB) - AML Compliance Guide, section "AML Compliance Requirements for MSBs", sub-section "Identification and Recordkeeping": "MSBs must verify the identity of any person who conducts a transaction of $3,000 or more. They must also keep records of the transaction, including the name, address, date of birth, and identification number of the customer, as well as the amount, date, and method of payment."
CAMS-CN Exam Question 34
FATF 式的區域機構 (FSRB) 更新應包含哪些原則?(選兩個。)
Correct Answer: A,C
According to the Anti-Money Laundering Specialist (the 6th edition) resources, FSRBs are regional organizations that help the FATF implement its global AML/CFT policy and standards in over 200 affiliated countries1. FSRBs have their own high-level principles and objectives that govern their relationship with the FATF and their members2. Among these principles and objectives, two that should be included in a FSRB update are:
* Issue country-specific Mutual Evaluation reports. This is the process by which FSRBs assess the compliance and effectiveness of their members' AML/CFT systems, based on the FATF standards and methodology3. Mutual Evaluation reports provide an in-depth analysis of the strengths and weaknesses of each jurisdiction, as well as recommendations for improvement4.
* Identify jurisdictions with weak AML/CFT regimes. This is the process by which FSRBs, in coordination with the FATF, monitor and publicly list the countries that pose a risk to the international financial system due to their strategic deficiencies in AML/CFT. This process aims to encourage and assist these jurisdictions to address their gaps and enhance their cooperation with the global network.
The other three options are incorrect because:
* Address AML/CFT technical assistance of individual members is not a principle that should be included in a FSRB update, as it is not a core function of FSRBs. FSRBs may facilitate or coordinate technical assistance, but they are not the primary providers or funders of such assistance.
* Establish AML/CFT standards and typologies is not a principle that should be included in a FSRB update, as it is not a role of FSRBs. FSRBs are expected to adopt and implement the FATF standards, not to create their own. Typologies are the methods and trends of money laundering and terrorist financing, which are identified and analyzed by the FATF and FSRBs through research and workshops.
* Protect the reputation and standing of FATF is not a principle that should be included in a FSRB update, as it is not a responsibility of FSRBs. FSRBs are autonomous and independent organizations that have their own governance and accountability mechanisms. FSRBs are expected to cooperate and coordinate with the FATF, but not to act as its agents or representatives.
:
1: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 64 2: FATF, High-Level Principles for the Relationship between the FATF and the FATF-Style Regional Bodies, February 2019, 3 3: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 65 4: FATF, FATF Methodology for Assessing Technical Compliance with the FATF Recommendations and the Effectiveness of AML/CFT Systems, February 2013 (updated October 2019), [12] : ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 66 : FATF, High-Risk and Other Monitored Jurisdictions, 4 : FATF, High-Level Principles for the Relationship between the FATF and the FATF-Style Regional Bodies, February 2019, 3, p. 4 : FATF, High-Level Principles for the Relationship between the FATF and the FATF-Style Regional Bodies, February 2019, 3, p. 2 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 67 : FATF, High-Level Principles for the Relationship between the FATF and the FATF-Style Regional Bodies, February 2019, 3, p. 3 : FATF, High-Level Principles for the Relationship between the FATF and the FATF-Style Regional Bodies, February 2019, 3, p. 5 : FATF, FATF Methodology for Assessing Technical Compliance with the FATF Recommendations and the Effectiveness of AML/CFT Systems, February 2013 (updated October 2019), [12], p. 9 : FATF, High-Risk and Other Monitored Jurisdictions, 4, p. 1 Reference: https://www.fatf-gafi.org/media/fatf/documents/High-Level%20Principles%20and%
20Objectives%20for%20FATF%20and%20FSRBs.pdf
* Issue country-specific Mutual Evaluation reports. This is the process by which FSRBs assess the compliance and effectiveness of their members' AML/CFT systems, based on the FATF standards and methodology3. Mutual Evaluation reports provide an in-depth analysis of the strengths and weaknesses of each jurisdiction, as well as recommendations for improvement4.
* Identify jurisdictions with weak AML/CFT regimes. This is the process by which FSRBs, in coordination with the FATF, monitor and publicly list the countries that pose a risk to the international financial system due to their strategic deficiencies in AML/CFT. This process aims to encourage and assist these jurisdictions to address their gaps and enhance their cooperation with the global network.
The other three options are incorrect because:
* Address AML/CFT technical assistance of individual members is not a principle that should be included in a FSRB update, as it is not a core function of FSRBs. FSRBs may facilitate or coordinate technical assistance, but they are not the primary providers or funders of such assistance.
* Establish AML/CFT standards and typologies is not a principle that should be included in a FSRB update, as it is not a role of FSRBs. FSRBs are expected to adopt and implement the FATF standards, not to create their own. Typologies are the methods and trends of money laundering and terrorist financing, which are identified and analyzed by the FATF and FSRBs through research and workshops.
* Protect the reputation and standing of FATF is not a principle that should be included in a FSRB update, as it is not a responsibility of FSRBs. FSRBs are autonomous and independent organizations that have their own governance and accountability mechanisms. FSRBs are expected to cooperate and coordinate with the FATF, but not to act as its agents or representatives.
:
1: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 64 2: FATF, High-Level Principles for the Relationship between the FATF and the FATF-Style Regional Bodies, February 2019, 3 3: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 65 4: FATF, FATF Methodology for Assessing Technical Compliance with the FATF Recommendations and the Effectiveness of AML/CFT Systems, February 2013 (updated October 2019), [12] : ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 66 : FATF, High-Risk and Other Monitored Jurisdictions, 4 : FATF, High-Level Principles for the Relationship between the FATF and the FATF-Style Regional Bodies, February 2019, 3, p. 4 : FATF, High-Level Principles for the Relationship between the FATF and the FATF-Style Regional Bodies, February 2019, 3, p. 2 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 67 : FATF, High-Level Principles for the Relationship between the FATF and the FATF-Style Regional Bodies, February 2019, 3, p. 3 : FATF, High-Level Principles for the Relationship between the FATF and the FATF-Style Regional Bodies, February 2019, 3, p. 5 : FATF, FATF Methodology for Assessing Technical Compliance with the FATF Recommendations and the Effectiveness of AML/CFT Systems, February 2013 (updated October 2019), [12], p. 9 : FATF, High-Risk and Other Monitored Jurisdictions, 4, p. 1 Reference: https://www.fatf-gafi.org/media/fatf/documents/High-Level%20Principles%20and%
20Objectives%20for%20FATF%20and%20FSRBs.pdf
CAMS-CN Exam Question 35
透過多個帳戶進行交易的術語是什麼,其中個人產生抵銷利潤和損失,並透過似乎不受共同控制的帳戶轉移頭寸?
Correct Answer: D
Wash trading is the term for trading through multiple accounts, where an individual generates offsetting profits and losses and transfers of positions through accounts that do not appear to be commonly controlled.
Wash trading is a form of market manipulationthat creates artificial trading activity and volume, and may be used to evade taxes, inflate prices, or launder money. Wash trading can also involve the use of third parties or intermediaries to conceal the true identity and source of funds of the trader.: = The main references for this question are the following sources:
The document titled "Money Laundering and Terrorist Financing Typologies and Trends in Canadian Securities Dealers" published by the Investment Industry Regulatory Organization of Canada (IIROC) in December 2019. You can access it by clicking here. This document states that "Wash trading is a form of market manipulation where an individual simultaneously sells and buys the same financial instruments to create misleading, artificial activity in the marketplace. Wash trading is illegal under securities law because it misleads investors and regulators about the true supply and demand of the securities involved. Wash trading can also be used to evade taxes, inflate prices, or launder money." The document titled "Market Manipulation" published by the Financial Industry Regulatory Authority (FINRA). You can access it by clicking here. This document states that "Wash sales are a form of market manipulation in which an investor simultaneously sells and buys the same security to create misleading, artificial activity in the marketplace. Wash sales are illegal under Section 9(a)(1)(A) of the Securities Exchange Act of 1934. Wash sales can be used to manipulate the price of a security, evade taxes, or launder money."
Wash trading is a form of market manipulationthat creates artificial trading activity and volume, and may be used to evade taxes, inflate prices, or launder money. Wash trading can also involve the use of third parties or intermediaries to conceal the true identity and source of funds of the trader.: = The main references for this question are the following sources:
The document titled "Money Laundering and Terrorist Financing Typologies and Trends in Canadian Securities Dealers" published by the Investment Industry Regulatory Organization of Canada (IIROC) in December 2019. You can access it by clicking here. This document states that "Wash trading is a form of market manipulation where an individual simultaneously sells and buys the same financial instruments to create misleading, artificial activity in the marketplace. Wash trading is illegal under securities law because it misleads investors and regulators about the true supply and demand of the securities involved. Wash trading can also be used to evade taxes, inflate prices, or launder money." The document titled "Market Manipulation" published by the Financial Industry Regulatory Authority (FINRA). You can access it by clicking here. This document states that "Wash sales are a form of market manipulation in which an investor simultaneously sells and buys the same security to create misleading, artificial activity in the marketplace. Wash sales are illegal under Section 9(a)(1)(A) of the Securities Exchange Act of 1934. Wash sales can be used to manipulate the price of a security, evade taxes, or launder money."
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