CAMS-CN Exam Question 386
某個組織使用自動監控系統來產生大量反洗錢警報。與去年相比,每月的警報量增加,導致合規人員嚴重落後於警報審查。因此,正在審查系統設定以確定它們是否合適。
系統設定的評估應包括哪些操作?
系統設定的評估應包括哪些操作?
Correct Answer: C
Reviewing parameter settings based on the latest risk assessment should be included in the evaluation of system settings for anti-money laundering alert surveillance. This is because parameter settings determine the thresholds and criteria for generating alerts based on the risk profile of the customers, products, services, channels, and jurisdictions involved in the transactions. A risk assessment is a periodic and comprehensiveanalysis of the potential money laundering and terrorist financing risks faced by an organization, and it should inform the design and implementation of an effective anti-money laundering program, including the alert surveillance system. By aligning the parameter settings with the risk assessment, an organization can ensure that the system is capturing the most relevant and high-risk transactions, and reducing the number of false positives or irrelevant alerts.
CAMS Study Guide 6th Edition, page 37-38.
Implementing AML Transaction Monitoring Systems: Critical Considerations, page 2-3.
3 techniques to improve AML transaction monitoring strategies, page 2.
CAMS Study Guide 6th Edition, page 37-38.
Implementing AML Transaction Monitoring Systems: Critical Considerations, page 2-3.
3 techniques to improve AML transaction monitoring strategies, page 2.
CAMS-CN Exam Question 387
一家金融機構正在進行企業範圍風險評估 (EWRA),並發現由於客戶的淨值高且財務結構複雜,其私人銀行部門存在很高的固有洗錢風險。然而,該機構已經實施了嚴格的客戶盡職調查 (CDD) 和加強盡職調查 (EDD) 程序,以及複雜的交易監控系統。
這些控制措施將如何影響剩餘風險的評估?
這些控制措施將如何影響剩餘風險的評估?
Correct Answer: A
In anEnterprise-Wide Risk Assessment (EWRA),residual riskis the level of risk that remains after applying mitigating controls to theinherent risk(the risk present before controls are applied).
In this scenario, theinherent risk is highdue to the nature of private banking-high net worth clients,cross- border transactions,complex ownership structures, andhigh-value financial products. However, the institution has implementedrobust CDD and EDD, as well asadvanced transaction monitoring systems.
According to the CAMS Study Guide - 6th Edition, wheneffective and properly implemented controlsare in place, they cansignificantly reducethe residual risk-even in high-risk business areas like private banking.
However, no control framework caneliminate all riskentirely.
Option Ais correct: Controls can significantly reduce the residual risk when strong, effective systems and procedures are in place.
Option Bis partially true but suggests inadequacy, which is not indicated here.
Option Cincorrectly assumes residual risk cannot be lowered even with controls.
Option Dis incorrect because residual riskcannot be eliminated entirely.
Reference: ACAMS CAMS Study Guide - 6th Edition, Chapter:Enterprise-Wide Risk Assessment (EWRA)- Section:Inherent Risk vs. Residual Risk and the Role of Controls
In this scenario, theinherent risk is highdue to the nature of private banking-high net worth clients,cross- border transactions,complex ownership structures, andhigh-value financial products. However, the institution has implementedrobust CDD and EDD, as well asadvanced transaction monitoring systems.
According to the CAMS Study Guide - 6th Edition, wheneffective and properly implemented controlsare in place, they cansignificantly reducethe residual risk-even in high-risk business areas like private banking.
However, no control framework caneliminate all riskentirely.
Option Ais correct: Controls can significantly reduce the residual risk when strong, effective systems and procedures are in place.
Option Bis partially true but suggests inadequacy, which is not indicated here.
Option Cincorrectly assumes residual risk cannot be lowered even with controls.
Option Dis incorrect because residual riskcannot be eliminated entirely.
Reference: ACAMS CAMS Study Guide - 6th Edition, Chapter:Enterprise-Wide Risk Assessment (EWRA)- Section:Inherent Risk vs. Residual Risk and the Role of Controls
CAMS-CN Exam Question 388
執法部門正在對一家金融機構 (FI) 進行調查,並提交了過於寬泛且過度侵入性的請求。佛羅裡達州最合適的答案是什麼?
Correct Answer: D
Financial institutions (FIs) are required to cooperate with law enforcement agencies (LEAs) in their investigations of money laundering, terrorist financing, and other financial crimes. However, sometimes LEAs may submit requests for information or documents that are overly broad, unduly intrusive, or unreasonable in scope or volume. Such requests may pose challenges or risks for FIs, such as violating customer privacy, compromising data security, disrupting business operations, or incurring excessive costs.
The most appropriate response for an FI in such a situation is to narrow the request through a prompt response to the LEA. This means that the FI should communicate with the LEA as soon as possible to clarify the purpose, scope, and relevance of the request, and to negotiate a more reasonable and proportionate request that meets the LEA's needs and the FI's capabilities. The FI should also explain the potential difficulties or consequences of complying with the original request, and propose alternative or additional sources of information that may be more useful or accessible. The FI should document the communication and the agreed terms of the request, and comply with the request in a timely and accurate manner.
By narrowing the request through a prompt response, the FI can demonstrate its good faith and willingness to cooperate with the LEA, while also protecting its own interests and obligations. This can help avoid or resolve any conflicts or misunderstandings between the FI and the LEA, and facilitate a more efficient and effective investigation.
References:
Requests by Law Enforcement for Financial Institutions to Maintain Accounts EFFECTIVE SUPERVISION AND ENFORCEMENT BY AML/CFT SUPERVISORS OF THE FINANCIAL SECTOR AND LAW ENFORCEMENT Bank Secrecy Act/Anti-Money Laundering: Requests by Law Enforcement for Financial Institutions to Maintain Accounts Support of Law Enforcement ACAMS CAMS Certification Study Guide 6th Edition
The most appropriate response for an FI in such a situation is to narrow the request through a prompt response to the LEA. This means that the FI should communicate with the LEA as soon as possible to clarify the purpose, scope, and relevance of the request, and to negotiate a more reasonable and proportionate request that meets the LEA's needs and the FI's capabilities. The FI should also explain the potential difficulties or consequences of complying with the original request, and propose alternative or additional sources of information that may be more useful or accessible. The FI should document the communication and the agreed terms of the request, and comply with the request in a timely and accurate manner.
By narrowing the request through a prompt response, the FI can demonstrate its good faith and willingness to cooperate with the LEA, while also protecting its own interests and obligations. This can help avoid or resolve any conflicts or misunderstandings between the FI and the LEA, and facilitate a more efficient and effective investigation.
References:
Requests by Law Enforcement for Financial Institutions to Maintain Accounts EFFECTIVE SUPERVISION AND ENFORCEMENT BY AML/CFT SUPERVISORS OF THE FINANCIAL SECTOR AND LAW ENFORCEMENT Bank Secrecy Act/Anti-Money Laundering: Requests by Law Enforcement for Financial Institutions to Maintain Accounts Support of Law Enforcement ACAMS CAMS Certification Study Guide 6th Edition
CAMS-CN Exam Question 389
為了確保遵守其經營所在地政府當局製定的經濟制裁,金融機構要求在入職時以及之後每季對所有新舊客戶進行篩選。
此步驟是否足以確保合規?
此步驟是否足以確保合規?
Correct Answer: A
Screening customers at onboarding and quarterly thereafter is not sufficient to ensure compliance with economic sanctions, as sanctions lists may change frequently and the financial institution may not be aware of the latest updates. Screening should occur promptly after list updates to ensure that the financial institution is not dealing with a sanctioned individual or entity, or facilitating a prohibited transaction. This is recommended by the international guidance from the Financial Action Task Force (FATF) and the Wolfsberg Group12. Screening and performing enhanced due diligence on new relationships is also important, but not the only step to ensure compliance.
CAMS Certification Package - 6th Edition | ACAMS, Chapter 3: Sanctions, page 86 The Wolfsberg Group Correspondent Banking Due Diligence Questionnaire 2014, Section 5: Sanctions Policy, page 12 ACAMS CAMS Certification Video Training Course - Exam-Labs, Video 3.1: Sanctions Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition), Question 109 The European Union Fourth Anti-Money Laundering Directive (4th AMLD) is a legal framework that aims to prevent the use of the Union's financial system for the purposes of money laundering and terrorist financing.
One of the provisions of the 4th AMLD is to lower the currency threshold for cash payments from €15,000 to
€10,000. This means that any person who makes or receives cash payments of €10,000 or more, whether in a single transaction or in several linked transactions, is subject to customer due diligence and record-keeping obligations. The 4th AMLD also extends its applicability to providers of gambling services, which are now listed as 'obliged entities'.
References:
Directive - 2015/849 - EN - Fourth Anti-Money Laundering Directive - EUR-Lex, Article 11 and Recital 23.
EUR-Lex - 02015L0849-20210630 - EN - EUR-Lex, Article 11 and Recital 23.
Key elements of the 4th EU Anti-Money Laundering Directive, Section: Cash payments.
Anti-money laundering and countering the financing of terrorism legislative package, Section: New EU AML
/CFT Regulation.
CAMS Certification Package - 6th Edition | ACAMS, Chapter 3: Sanctions, page 86 The Wolfsberg Group Correspondent Banking Due Diligence Questionnaire 2014, Section 5: Sanctions Policy, page 12 ACAMS CAMS Certification Video Training Course - Exam-Labs, Video 3.1: Sanctions Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition), Question 109 The European Union Fourth Anti-Money Laundering Directive (4th AMLD) is a legal framework that aims to prevent the use of the Union's financial system for the purposes of money laundering and terrorist financing.
One of the provisions of the 4th AMLD is to lower the currency threshold for cash payments from €15,000 to
€10,000. This means that any person who makes or receives cash payments of €10,000 or more, whether in a single transaction or in several linked transactions, is subject to customer due diligence and record-keeping obligations. The 4th AMLD also extends its applicability to providers of gambling services, which are now listed as 'obliged entities'.
References:
Directive - 2015/849 - EN - Fourth Anti-Money Laundering Directive - EUR-Lex, Article 11 and Recital 23.
EUR-Lex - 02015L0849-20210630 - EN - EUR-Lex, Article 11 and Recital 23.
Key elements of the 4th EU Anti-Money Laundering Directive, Section: Cash payments.
Anti-money laundering and countering the financing of terrorism legislative package, Section: New EU AML
/CFT Regulation.
CAMS-CN Exam Question 390
一位反洗錢專家剛剛制定並實施了反洗錢計劃。
評估計劃有效性最有效的資源是什麼?
評估計劃有效性最有效的資源是什麼?
Correct Answer: D
A qualified independent party/auditor is the most effective resource to evaluate the effectiveness of an anti- money laundering program. This is because an independent auditor can provide an objective and unbiased assessment of the program, identify any weaknesses or gaps, and make recommendations for improvement.
An independent auditor can also verify the compliance of the program with the relevant regulations and best practices, and test the adequacy and functionality of the internal controls, customer due diligence processes, and transaction monitoring systems. An independent auditor can also help an organization prepare for regulatory examinations and audits, and avoid potential penalties or sanctions.
= The main references for this question are the following sources:
The document titled "Frequently Asked Questions Conducting Independent Reviews of Money Services Business Anti-Money Laundering Programs" published by the Financial Crimes Enforcement Network (FinCEN) in July 2010. You can access it by clicking here.
The document titled "AML Audit: How to Effectively Assess Your Compliance Program" published by Alessa in May 2023. You can access it by clicking here.
The document titled "Mutual Evaluations" published by the Financial Action Task Force (FATF). You can access it by clicking here.
An independent auditor can also verify the compliance of the program with the relevant regulations and best practices, and test the adequacy and functionality of the internal controls, customer due diligence processes, and transaction monitoring systems. An independent auditor can also help an organization prepare for regulatory examinations and audits, and avoid potential penalties or sanctions.
= The main references for this question are the following sources:
The document titled "Frequently Asked Questions Conducting Independent Reviews of Money Services Business Anti-Money Laundering Programs" published by the Financial Crimes Enforcement Network (FinCEN) in July 2010. You can access it by clicking here.
The document titled "AML Audit: How to Effectively Assess Your Compliance Program" published by Alessa in May 2023. You can access it by clicking here.
The document titled "Mutual Evaluations" published by the Financial Action Task Force (FATF). You can access it by clicking here.
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