CAMS-CN Exam Question 141
合規官員應如何回應執法機構要求提供接受調查的客戶資訊的請求?
Correct Answer: A
A compliance officer should cooperate with the law enforcement inquiry as much as possible, but also ensure that the request is valid, lawful, and does not violate any confidentiality or privacy obligations. Therefore, the compliance officer should collaboratewith the FI's designated department, such as the legal counsel, the senior management, or the board of directors, to determine the appropriate course of action to comply withthe request12. The compliance officer should also ensure that all communication, written and oral, is funneled through a centralized place, and that the FI maintains a record of the request and the response12.
1: Requests by Law Enforcement for Financial Institutions to Maintain Accounts, FinCEN, 2014
2: Best Practices for Compliance and Enforcement-Related Information Requests, EPA, 2018 Reference: https://www.acams.org/en/resources/aml-glossary-of-terms
1: Requests by Law Enforcement for Financial Institutions to Maintain Accounts, FinCEN, 2014
2: Best Practices for Compliance and Enforcement-Related Information Requests, EPA, 2018 Reference: https://www.acams.org/en/resources/aml-glossary-of-terms
CAMS-CN Exam Question 142
健全的客戶盡職調查計畫的三個要素是什麼?
Correct Answer: A,B,C
A sound Customer Due Diligence Program (CDD) is a key component of an effective anti-money laundering and counter-terrorism financing (AML/CFT) framework. According to the Financial Action Task Force (FATF), the global standard-setter for AML/CFT, CDD involves the following elements1:
Identifying the customer and verifying their identity using reliable, independent sources of information or documents.
Identifying the beneficial owner and taking reasonable measures to verify their identity, so that the financial institution understands who ultimately owns or controls the customer or the funds.
Understanding and obtaining information on the purpose and intended nature of the business relationship.
Conducting ongoing due diligence on the business relationship and scrutinizing transactions to ensure that they are consistent with the financial institution's knowledge of the customer, their business and risk profile, and the source of funds.
Therefore, the three elements of a sound CDD program that are listed in the question are:
Determination of what type of customer the financial institution will accept: This involves defining the customer acceptance policy and risk appetite of the financial institution, and applying appropriate risk-based measures to accept or reject customers based on their risk profile and the financial institution's ability to manage and mitigate those risks2.
Training as to how and to what extent to identify prospective customers: This involves providing adequate and regular training to the staff who are responsible for conducting CDD, and ensuring that they are aware of the legal and regulatory requirements, the internal policies and procedures, the risk indicators, the verification methods, and the reporting obligations3.
Obtaining date of birth and address of a prospective customer: This is part of the basic information that is required to identify and verify the customer's identity, and to establish their risk profile and the source of funds. The date of birth and address can also be used to check against various databases and watchlists to detect any potential matches with sanctioned or high-risk individuals or entities4.
The element that is not part of a sound CDD program is:
Determination of who in the institution should be assigned to the prospective customer as a liaison: This is not a mandatory or essential element of CDD, although it may be a good practice to assign a dedicated relationship manager or contact person to each customer, especially for high-risk or complex customers, to ensure effective communication, monitoring, and service delivery.
FATF Guidance on Customer Due Diligence and Financial Inclusion 1
ACAMS Study Guide for the CAMS Certification Examination (6th Edition), Chapter 2: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) 2 ACAMS Study Guide for the CAMS Certification Examination (6th Edition), Chapter 4: Developing an AML
/CFT Program 3
ACAMS Study Guide for the CAMS Certification Examination (6th Edition), Chapter 5: Conducting and Supporting the Investigation Process 4 Wolfsberg Group Guidance on Customer Due Diligence (CDD)
Identifying the customer and verifying their identity using reliable, independent sources of information or documents.
Identifying the beneficial owner and taking reasonable measures to verify their identity, so that the financial institution understands who ultimately owns or controls the customer or the funds.
Understanding and obtaining information on the purpose and intended nature of the business relationship.
Conducting ongoing due diligence on the business relationship and scrutinizing transactions to ensure that they are consistent with the financial institution's knowledge of the customer, their business and risk profile, and the source of funds.
Therefore, the three elements of a sound CDD program that are listed in the question are:
Determination of what type of customer the financial institution will accept: This involves defining the customer acceptance policy and risk appetite of the financial institution, and applying appropriate risk-based measures to accept or reject customers based on their risk profile and the financial institution's ability to manage and mitigate those risks2.
Training as to how and to what extent to identify prospective customers: This involves providing adequate and regular training to the staff who are responsible for conducting CDD, and ensuring that they are aware of the legal and regulatory requirements, the internal policies and procedures, the risk indicators, the verification methods, and the reporting obligations3.
Obtaining date of birth and address of a prospective customer: This is part of the basic information that is required to identify and verify the customer's identity, and to establish their risk profile and the source of funds. The date of birth and address can also be used to check against various databases and watchlists to detect any potential matches with sanctioned or high-risk individuals or entities4.
The element that is not part of a sound CDD program is:
Determination of who in the institution should be assigned to the prospective customer as a liaison: This is not a mandatory or essential element of CDD, although it may be a good practice to assign a dedicated relationship manager or contact person to each customer, especially for high-risk or complex customers, to ensure effective communication, monitoring, and service delivery.
FATF Guidance on Customer Due Diligence and Financial Inclusion 1
ACAMS Study Guide for the CAMS Certification Examination (6th Edition), Chapter 2: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) 2 ACAMS Study Guide for the CAMS Certification Examination (6th Edition), Chapter 4: Developing an AML
/CFT Program 3
ACAMS Study Guide for the CAMS Certification Examination (6th Edition), Chapter 5: Conducting and Supporting the Investigation Process 4 Wolfsberg Group Guidance on Customer Due Diligence (CDD)
CAMS-CN Exam Question 143
哪一種私人銀行業務狀況需要根據沃爾夫斯堡集團的反洗錢原則實施盡職調查行動?
Correct Answer: C
this situation requires enhanced due diligence actions according to the AML principles of the Wolfsberg group. The Wolfsberg group is an association of 13 global banks that aims to develop standards and best practices for AML and CFT in the private banking sector. The group has issued a set of principles and guidance on how to conduct due diligence on private banking customers, especially those who pose higher risks, such as politically exposed persons (PEPs), customers from high-risk countries, and customers with complex or opaque structures. According to the Wolfsberg group, private banks should apply a risk-based approach to customer due diligence and perform enhanced measures for high-risk customers, such as obtaining senior management approval, verifying the identity and source of wealth of the customer and the beneficial owner, understanding the purpose and nature of the relationship, and conducting ongoing monitoring and review.
ACAMS Study Guide 6th Edition, Chapter 4, Section 4.5, page 118: "The Wolfsberg Group".
ExamTopics, Question 466: "Which private banking situation requires due diligence actions to be implemented according to the AML principles of the Wolfsberg group?"
ACAMS Study Guide 6th Edition, Chapter 4, Section 4.5, page 118: "The Wolfsberg Group".
ExamTopics, Question 466: "Which private banking situation requires due diligence actions to be implemented according to the AML principles of the Wolfsberg group?"
CAMS-CN Exam Question 144
根據沃爾夫斯堡代理銀行原則,哪種行為被視為對存在更大風險的代理銀行客戶的強化盡職調查義務?
Correct Answer: C
Under the Wolfsberg Correspondent Banking Principles, conducting enhanced due diligence (EDD) is an obligation for correspondent banking clients that present greater risks. This may include conducting additional research and analysis of the client's background, ownership structure, and transactions. EDD may also involve obtaining additional documentation, verifying the client's identity, and conducting periodic reviews to ensure ongoing compliance. The level of EDD required should be commensurate with the level of risk posed by the correspondent banking relationship. Therefore, option B and D are incorrect. Option A is not specific enough to address the question. Option C is the correct answer as it highlights the importance of senior management approval for high-risk relationships, which is a key component of EDD.
Reference: Certified Anti-Money Laundering Specialist (the 6th edition) Study Guide, Chapter 7, page 12.
Wolfsberg Correspondent Banking Principles (2014)
Reference: Certified Anti-Money Laundering Specialist (the 6th edition) Study Guide, Chapter 7, page 12.
Wolfsberg Correspondent Banking Principles (2014)
CAMS-CN Exam Question 145
從國際標準角度來看,歐盟和金融行動特別工作小組都認為資料共享是有效反洗錢措施的重要組成部分,因為資料共享:
Correct Answer: A
Data sharingbetween financial institutions, FIUs, and law enforcement is essential toAML compliance.
Option A (Correct):Transparent financial systemsdetermoney laundering and terrorist financing.
Option B (Incorrect):FIUsdo not impose sanctions; theycollect and analyze data.
Option C (Incorrect):While data analysis is valuable, thekey goal is financial transparency.
Option D (Incorrect):In many jurisdictions,data sharing is encouraged, withsome restrictions.
Reference:FATF Recommendation 40 (International Cooperation), GDPR and AMLD Regulations, Wolfsberg Group Information Sharing Principles.
Option A (Correct):Transparent financial systemsdetermoney laundering and terrorist financing.
Option B (Incorrect):FIUsdo not impose sanctions; theycollect and analyze data.
Option C (Incorrect):While data analysis is valuable, thekey goal is financial transparency.
Option D (Incorrect):In many jurisdictions,data sharing is encouraged, withsome restrictions.
Reference:FATF Recommendation 40 (International Cooperation), GDPR and AMLD Regulations, Wolfsberg Group Information Sharing Principles.
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