CAMS-CN Exam Question 106
購買奢侈品的哪種付款方式是潛在洗錢的危險信號?
Correct Answer: B
According to the Financial Action Task Force (FATF), the use of large amounts of cash is a common method for money launderers to move illicit funds [1]. Purchasing luxury items with cash can indicate an attempt to convert illegal funds into tangible assets that can be easily resold or moved across borders. As a result, businesses that deal with luxury items are required to implement enhanced due diligence measures, including monitoring transactions involving large amounts of cash [1].
Reference: [1] Financial Action Task Force. (2013). Money Laundering & Terrorist Financing Through the Real Estate Sector. https://www.fatf-gafi.org/media/fatf/documents/reports/ML-TF-through-real-estate.pdf
Reference: [1] Financial Action Task Force. (2013). Money Laundering & Terrorist Financing Through the Real Estate Sector. https://www.fatf-gafi.org/media/fatf/documents/reports/ML-TF-through-real-estate.pdf
CAMS-CN Exam Question 107
客戶進入金融機構並存入大量現金。他以前從未這樣做過。當被問及押金時,他表示他最近賣掉了一輛二手車並收到了現金。
他不信任付款方式,並對偽造的匯票持謹慎態度。銀行該做什麼?
他不信任付款方式,並對偽造的匯票持謹慎態度。銀行該做什麼?
Correct Answer: B
A large cash deposit is a potential indicator of money laundering, especially if it is inconsistent with the customer's profile or behavior. Therefore, the bank should ask the customer about the source and purpose of the funds, and verify the information if possible. In this case, the customer claims to have sold a used car and received cash, which may be a reasonable explanation. However, the bank should not rely solely on the customer's statement, but should also monitor the account for any further cash transactions or suspicious activity that may indicate money laundering. For example, the bank should check if the customer withdraws the cash soon after the deposit, transfers the funds to other accounts or jurisdictions, or engages in structuring or smurfing to avoid reporting thresholds.
The bank should not do nothing, as this may expose the bank to regulatory or reputational risks, or facilitate money laundering. The bank should also not file a Suspicious Transaction Report (STR) unless there are other grounds to suspect money laundering, as this may be premature or unnecessary. The bank should not close the account before another issues arise, as this may be disproportionate or discriminatory, and may also alert the customer to the bank's suspicion.
[ACAMS Study Guide for the CAMS Certification Examination, 6th Edition], Chapter 4: Conducting or Supporting the Investigation Process, pp. 103-104, 107-108.
Customer Identification Program - Overview, Federal Financial Institutions Examination Council, April 2018, pp. 1-2, 4-5.
Suspicious Activity Reporting - Overview, Federal Financial Institutions Examination Council, April 2018, pp. 1-2, 4-5.
18 AML Analyst Interview Questions (With Example Answers), ResumeCat, accessed on February 9, 2024.
The bank should not do nothing, as this may expose the bank to regulatory or reputational risks, or facilitate money laundering. The bank should also not file a Suspicious Transaction Report (STR) unless there are other grounds to suspect money laundering, as this may be premature or unnecessary. The bank should not close the account before another issues arise, as this may be disproportionate or discriminatory, and may also alert the customer to the bank's suspicion.
[ACAMS Study Guide for the CAMS Certification Examination, 6th Edition], Chapter 4: Conducting or Supporting the Investigation Process, pp. 103-104, 107-108.
Customer Identification Program - Overview, Federal Financial Institutions Examination Council, April 2018, pp. 1-2, 4-5.
Suspicious Activity Reporting - Overview, Federal Financial Institutions Examination Council, April 2018, pp. 1-2, 4-5.
18 AML Analyst Interview Questions (With Example Answers), ResumeCat, accessed on February 9, 2024.
CAMS-CN Exam Question 108
哪些危險訊號與透過資本市場洗錢最相關?
Correct Answer: A
Money laundering through capital markets often involves pump-and-dump schemes, wash trading, and layering funds through rapid trading activity.
Option A (Correct): A sudden spike in demand for a low-priced security is a red flag for pump-and-dump schemes, where criminals manipulate the market to inflate stock prices artificially before selling off shares for a profit.
Option B (Incorrect): A gradual decline in trading volume and price does not indicate suspicious activity related to money laundering.
Option C (Incorrect): An increase in demand for ETFs is common and not necessarily linked to money laundering.
Option D (Incorrect): Holding securities in one specific emerging market may indicate a geographic investment strategy, not necessarily money laundering.
Common Money Laundering Typologies in Capital Markets:
Pump-and-Dump Schemes - Fraudulently inflating stock prices to cash out illicit funds.
Wash Trading - Conducting self-trades to create an illusion of high market activity.
Layering Funds Through Rapid Trading - Engaging in frequent buy-and-sell orders to obfuscate the origin of funds.
Best Practices for AML in Capital Markets:
Monitor unusual trading volume and price fluctuations.
Use AI-driven surveillance systems to detect manipulative behavior.
Investigate transactions involving offshore brokers or shell entities.
Reference:
FATF Report on Money Laundering in Capital Markets
SEC and FINRA Guidance on Market Manipulation Risks
Wolfsberg Group Principles for Capital Markets AML Compliance
Option A (Correct): A sudden spike in demand for a low-priced security is a red flag for pump-and-dump schemes, where criminals manipulate the market to inflate stock prices artificially before selling off shares for a profit.
Option B (Incorrect): A gradual decline in trading volume and price does not indicate suspicious activity related to money laundering.
Option C (Incorrect): An increase in demand for ETFs is common and not necessarily linked to money laundering.
Option D (Incorrect): Holding securities in one specific emerging market may indicate a geographic investment strategy, not necessarily money laundering.
Common Money Laundering Typologies in Capital Markets:
Pump-and-Dump Schemes - Fraudulently inflating stock prices to cash out illicit funds.
Wash Trading - Conducting self-trades to create an illusion of high market activity.
Layering Funds Through Rapid Trading - Engaging in frequent buy-and-sell orders to obfuscate the origin of funds.
Best Practices for AML in Capital Markets:
Monitor unusual trading volume and price fluctuations.
Use AI-driven surveillance systems to detect manipulative behavior.
Investigate transactions involving offshore brokers or shell entities.
Reference:
FATF Report on Money Laundering in Capital Markets
SEC and FINRA Guidance on Market Manipulation Risks
Wolfsberg Group Principles for Capital Markets AML Compliance
CAMS-CN Exam Question 109
保險業洗錢活動中哪一事件最常發生?
Correct Answer: A
One of the most common methods of money laundering in the insurance industry is to purchase a policy with illicit funds and then request a refund of the premiums, either partially or fully, before the policy matures.
This way, the money launderer can receive a legitimate payment from the insurance company, effectively washing the dirty money. This technique is also known as premium fraud or early surrender12 According to the Financial Crimes Enforcement Network (FinCEN), the most significant money laundering and terrorist financing risks in the insurance industry are found in life insurance and annuity products, because such products allow a customer to place largeamounts of funds into the financial system and seamlessly transfer such funds to disguise their true origin34 Some indicators of potential money laundering through insurance products are: 12
* The customer pays the premiums with cash, cashier's checks, money orders, or other anonymous or unusual payment methods.
* The customer overpays the premiums or makes multiple payments in excess of the required amount.
* The customer cancels the policy during the free-look or grace period and requests a refund to a different account or a third party.
* The customer purchases a policy that is inconsistent with their income, age, or risk profile.
* The customer shows little interest in the benefits or terms of the policy, but is more concerned about the cancellation or surrender options.
1: AML in Insurance: How to Detect & Combat Money Laundering, ComplyAdvantage, 2022
2: Anti Money Laundering (AML) In Insurance Industry In 2021, Financial Crime Academy, 2023
3: Money laundering in the insurance industry, Insurance Commission, 2022
4: Money laundering in the insurance industry, Atty. Dennis B. Funa, Business Mirror, 2016
[5]: Anti-Money Laundering Requirements: FAQs for Insurance Companies, FinCEN, 2005
This way, the money launderer can receive a legitimate payment from the insurance company, effectively washing the dirty money. This technique is also known as premium fraud or early surrender12 According to the Financial Crimes Enforcement Network (FinCEN), the most significant money laundering and terrorist financing risks in the insurance industry are found in life insurance and annuity products, because such products allow a customer to place largeamounts of funds into the financial system and seamlessly transfer such funds to disguise their true origin34 Some indicators of potential money laundering through insurance products are: 12
* The customer pays the premiums with cash, cashier's checks, money orders, or other anonymous or unusual payment methods.
* The customer overpays the premiums or makes multiple payments in excess of the required amount.
* The customer cancels the policy during the free-look or grace period and requests a refund to a different account or a third party.
* The customer purchases a policy that is inconsistent with their income, age, or risk profile.
* The customer shows little interest in the benefits or terms of the policy, but is more concerned about the cancellation or surrender options.
1: AML in Insurance: How to Detect & Combat Money Laundering, ComplyAdvantage, 2022
2: Anti Money Laundering (AML) In Insurance Industry In 2021, Financial Crime Academy, 2023
3: Money laundering in the insurance industry, Insurance Commission, 2022
4: Money laundering in the insurance industry, Atty. Dennis B. Funa, Business Mirror, 2016
[5]: Anti-Money Laundering Requirements: FAQs for Insurance Companies, FinCEN, 2005
CAMS-CN Exam Question 110
私人投資公司可能容易受到洗錢的影響,因為:
Correct Answer: A
Private investment companies (PICs) are potentially vulnerable to money laundering due to the difficulty in identifying the ultimate beneficial owners. PICs are often used to hold and manage private wealth, making them attractive targets for money launderers. Since these entities are privately held and not publicly traded, it can be challenging to identify the individuals who ultimately control or benefit from them. This makes it easier for money launderers to use them to disguise the origins of illicit funds.
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