CAMS-CN Exam Question 261
委託調查將用於從哪個網關獲取來自另一個國家的資訊?
Correct Answer: B
A commission rogatory, also known as a letter rogatory or a letter of request, is a formal request from a court in one country to a court in another country for some type of judicial assistance, such as service of process, taking of evidence, or enforcement of judgments1. A commission rogatory would be used in the context of a mutual legal assistance treaty (MLAT) request, which is a bilateral or multilateral agreement that enables countries to cooperate and provide legal assistance to each other in criminal matters2. MLATs are one of the main gateways for obtaining information from another country, especially when the information is not available through other means, such as financial intelligence units (FIUs), supervisory authorities, or international organizations3. FIUs are national agencies that collect, analyze, and disseminate financial information related to money laundering and terrorist financing, and they can exchange information with their counterparts in other countries under the Egmont principles. Supervisory authorities are regulators that oversee the compliance of financial institutions and other entities with anti-money laundering and counter- terrorism financing (AML/CFT) obligations, and they can share information with their peers in other jurisdictions through supervisory channels, such as the Basel Committee on Banking Supervision. The Financial Action Task Force (FATF) is an inter-governmental body that sets standards and monitors the implementation of AML/CFT measures, and it can provide information and guidance to its members and other jurisdictions, but it does not have the authority to request or compel information from them.
1: Letters rogatory - Wikipedia
2: Mutual Legal Assistance Treaties and Letters Rogatory: A Guide for Judges | Federal Judicial Center
3: How US Authorities Obtain Foreign Evidence in Cross-Border Investigations | Global Investigations Review What is an FIU? | Egmont Group of Financial Intelligence Units Basel Committee on Banking Supervision | Bank for International Settlements What is the FATF? | FATF
1: Letters rogatory - Wikipedia
2: Mutual Legal Assistance Treaties and Letters Rogatory: A Guide for Judges | Federal Judicial Center
3: How US Authorities Obtain Foreign Evidence in Cross-Border Investigations | Global Investigations Review What is an FIU? | Egmont Group of Financial Intelligence Units Basel Committee on Banking Supervision | Bank for International Settlements What is the FATF? | FATF
CAMS-CN Exam Question 262
根據巴塞爾委員會的《銀行客戶盡職調查》文件,了解你的客戶 (KYC) 標準的基本要素是什麼?
Correct Answer: B
The correct answer is B, as a customer acceptance policy is an essential element of KYC standards according to the Basel Committee's Customer Due Diligence for Bankspaper1. A customer acceptance policy defines the types of customers that the bank is willing to accept, and the conditions and limitations that apply to such relationships. A customer acceptance policy helps the bank to avoid customers who are likely to pose a higher than average risk of money laundering or terrorist financing, or who are not willing to provide sufficient information for identification and verification purposes1.
1: Customer due diligence for banks - Bank for International Settlements, page 9.
Reference:https://www.bis.org/publ/bcbs77.pdf
1: Customer due diligence for banks - Bank for International Settlements, page 9.
Reference:https://www.bis.org/publ/bcbs77.pdf
CAMS-CN Exam Question 263
一家小型銀行的反洗錢專家發現,該鎮某地區的一家分行有可疑活動,該地區已知有毒販子活動。對此活動的調查顯示,可疑交易發生在過去 3 個月內,並由同一櫃員(收銀員)處理。出納員(出納員)沒有提交有關這些交易異常活動的內部報告。專家在查閱人事檔案時發現,該櫃員(出納員)已是值得信賴的員工,工作時間超過15年,工作記錄無可挑剔,並參加過多次反洗錢培訓課程。這位專家最近意識到該員工的女兒患有一種罕見的疾病,正在接受非常昂貴的治療計劃。對於出納員(出納員)未能向機構報告異常活動,專家應建議
Correct Answer: C
The specialist should recommend directing the teller (cashier) to file a suspicious transaction report (STR). This is because the teller (cashier) has failed to comply with thebank's internal policies and procedures for reporting unusual or suspicious activity, which is a key component of an effective anti-money laundering (AML) program1. The teller (cashier) should have filed an internal report of unusual activity assoon as he or she noticed the suspicious transactions, regardless of the personal circumstances or the length of service of the customer involved2. Failing to do so could expose the bank to regulatory sanctions, reputational damage, or legal liability3.
The other options are not appropriate recommendations for the specialist to make in this situation. Continuing to monitor the accounts is not sufficient, as it does not address the past non-compliance or the potential money laundering risk posed by the suspicious transactions. Refreshing anti-money laundering training for the teller (cashier) is not enough, as it does not ensure that the teller (cashier) will report the suspicioustransactions or prevent future violations. Suspending the teller's (cashier's) employment is too harsh, as it does not take into account the teller's (cashier's) long and exemplary work record, the personal hardship faced by the teller's (cashier's) family, or the possibility of remedial actions or corrective measures4.
1: Internal Controls | FinCEN.gov1 2: Reporting Suspicious Transactions - ACAMS2 3: The Consequences of Non-Compliance with AML Regulations - Blog | Unit213 4: Employee Discipline in the Workplace: A Guide for Managers4
The other options are not appropriate recommendations for the specialist to make in this situation. Continuing to monitor the accounts is not sufficient, as it does not address the past non-compliance or the potential money laundering risk posed by the suspicious transactions. Refreshing anti-money laundering training for the teller (cashier) is not enough, as it does not ensure that the teller (cashier) will report the suspicioustransactions or prevent future violations. Suspending the teller's (cashier's) employment is too harsh, as it does not take into account the teller's (cashier's) long and exemplary work record, the personal hardship faced by the teller's (cashier's) family, or the possibility of remedial actions or corrective measures4.
1: Internal Controls | FinCEN.gov1 2: Reporting Suspicious Transactions - ACAMS2 3: The Consequences of Non-Compliance with AML Regulations - Blog | Unit213 4: Employee Discipline in the Workplace: A Guide for Managers4
CAMS-CN Exam Question 264
在審查貨幣服務企業 (MSB) 的業務運作時,下列哪些活動被視為洗錢危險訊號? (選兩個。)
Correct Answer: D,E
MSBsarehigh-risk for financial crime, requiringstrict AML controls.
* Option D (Correct):Hesitancy to provide beneficiary informationis astrong indicator of illicit financial activity.
* Option E (Correct):Using multiple accounts under different namesis aknown money laundering technique.
* Option A (Incorrect):Currency exchange is common in MSBs, thoughadditional factors must be assessed.
* Option B (Incorrect):Large cash deposits are normal for cash-based businesses, butneed further scrutiny.
* Option C (Incorrect):Frequent small remittancesare normal, unless linked tostructuring or smurfing.
Reference:FATF Red Flags for MSBs, Wolfsberg Group MSB Risk-Based Approach, FinCEN Money Services Business AML Guidelines.
* Option D (Correct):Hesitancy to provide beneficiary informationis astrong indicator of illicit financial activity.
* Option E (Correct):Using multiple accounts under different namesis aknown money laundering technique.
* Option A (Incorrect):Currency exchange is common in MSBs, thoughadditional factors must be assessed.
* Option B (Incorrect):Large cash deposits are normal for cash-based businesses, butneed further scrutiny.
* Option C (Incorrect):Frequent small remittancesare normal, unless linked tostructuring or smurfing.
Reference:FATF Red Flags for MSBs, Wolfsberg Group MSB Risk-Based Approach, FinCEN Money Services Business AML Guidelines.
CAMS-CN Exam Question 265
根據美國愛國者法案對代理帳戶的要求,「證明」一詞是指由代理帳戶提供的書面陳述
Correct Answer: D
it describes the word "certification" as a written representation by a respondent bank, certifying that they do not do business with shell banks. This is one of the requirements for correspondent accounts in the USA PATRIOT Act, which is a law enacted in 2001 to enhance the anti-money laundering and counter-terrorist financing (AML/CTF) measures in the United States. The USA PATRIOT Act requires that correspondent banks, which are banks that provide services to other banks, such as clearing, settlement, or cash management, to obtain a certification from their respondent banks, which are banks that receive services from correspondent banks, to ensure that they are not involved in money laundering or terrorist financing activities.
One of the elements of the certification is that the respondent bank does not do business with shell banks, which are banks that have no physical presence or meaningful supervision in any jurisdiction, and are often used by money launderers and other criminals to hide their identity and funds.
The other options are not necessarily the word "certification" as a written representation by a respondent bank under the USA PATRIOT Act, although they may have some relevance or importance depending on the circumstances and the nature of the correspondent relationship. Option A describes a possible certification by a federal receiver, which is a person appointed by a court to take custody and control of the assets of a failed bank, but this is not related to the correspondent accounts requirements in the USA PATRIOT Act. Option B describes a possible certification by a respondent bank, certifying that they do not do business with politically exposed persons (PEPs), which are individuals who hold or have held prominent public positions or their close associates or family members, and who may pose a higher risk of money laundering or corruption, but this is not a mandatory element of the certification under the USA PATRIOT Act, although itmay be a good practice or a risk-based measure. Option C describes a possible certification by a correspondent bank, certifying that they do not open correspondent accounts for alternative remittance companies, which are businesses that provide money transfer or payment services outside the formal banking system, and which may pose a higher risk of money laundering or terrorist financing, but this is not a requirement for the respondent bank under the USA PATRIOT Act, although it may be a regulatory obligation or a risk-based measure for the correspondent bank.
ACAMS CAMS Certification Video Training Course - 6th Edition1
Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)2 ACAMS CAMS Study Guide - 6th Edition, Chapter 7, pages 156-157
https://www.acams.org/wp-content/uploads/2019/09/ACAMS-CAMS-Study-Guide-6th-Edition-Chapter-7.pdf
One of the elements of the certification is that the respondent bank does not do business with shell banks, which are banks that have no physical presence or meaningful supervision in any jurisdiction, and are often used by money launderers and other criminals to hide their identity and funds.
The other options are not necessarily the word "certification" as a written representation by a respondent bank under the USA PATRIOT Act, although they may have some relevance or importance depending on the circumstances and the nature of the correspondent relationship. Option A describes a possible certification by a federal receiver, which is a person appointed by a court to take custody and control of the assets of a failed bank, but this is not related to the correspondent accounts requirements in the USA PATRIOT Act. Option B describes a possible certification by a respondent bank, certifying that they do not do business with politically exposed persons (PEPs), which are individuals who hold or have held prominent public positions or their close associates or family members, and who may pose a higher risk of money laundering or corruption, but this is not a mandatory element of the certification under the USA PATRIOT Act, although itmay be a good practice or a risk-based measure. Option C describes a possible certification by a correspondent bank, certifying that they do not open correspondent accounts for alternative remittance companies, which are businesses that provide money transfer or payment services outside the formal banking system, and which may pose a higher risk of money laundering or terrorist financing, but this is not a requirement for the respondent bank under the USA PATRIOT Act, although it may be a regulatory obligation or a risk-based measure for the correspondent bank.
ACAMS CAMS Certification Video Training Course - 6th Edition1
Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)2 ACAMS CAMS Study Guide - 6th Edition, Chapter 7, pages 156-157
https://www.acams.org/wp-content/uploads/2019/09/ACAMS-CAMS-Study-Guide-6th-Edition-Chapter-7.pdf
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