CAMS-CN Exam Question 271
《沃爾夫斯堡私人銀行原則》列出了需要額外盡職調查的情況,包括涉及以下哪三種選擇的活動?
Correct Answer: A,B,C
The Wolfsberg Principles for Private Banking are a set of guidelines for private banking relationships that aim to prevent and detect money laundering and terrorist financing risks. The Principles state that the bank should conduct additional due diligence on clients and beneficial owners in certain circumstances that may indicate a higher risk of money laundering or terrorist financing. Among the options given, A, B, and C are the correct choices that reflect the circumstances listed in the Principles.
Foreign jurisdictions are countries or territories other than the one where the bank operates or where the client or beneficial owner resides. The Principles state that the bank should conduct additional due diligence on clients and beneficial owners who are connected to foreign jurisdictions, especially those that have weak or inadequate anti-money laundering standards, or that are subject to sanctions, embargoes, or similar measures.
High Risk Countries are countries or territories that are identified by credible sources, such as the Financial Action Task Force (FATF), as having inadequate anti-money laundering standards, or as being a source, transit, or destination of illicit funds. The Principles state that the bank should conduct additional due diligence on clients and beneficial owners who are connected to high risk countries, and apply enhanced measures to mitigate the risks.
High Risk activities are activities that involve clients and beneficial owners whose source of wealth or funds originates from sectors or industries that are known to be vulnerable to money laundering, such as cash- intensive businesses, gambling, arms trade, precious metals and stones, or art and antiquities. The Principles state that the bank should conduct additional due diligence on clients and beneficial owners who are engaged in high risk activities, and verify the legitimacy and origin of their wealth and funds.
= The main reference for this question is the document titled "Wolfsberg Anti-Money Laundering Principles for Private Banking (2012)" published by the Wolfsberg Group. You can access it by clicking here. You can also find more information about the Wolfsberg Principles and their application on the Wolfsberg Group website and the Lexology website.
Foreign jurisdictions are countries or territories other than the one where the bank operates or where the client or beneficial owner resides. The Principles state that the bank should conduct additional due diligence on clients and beneficial owners who are connected to foreign jurisdictions, especially those that have weak or inadequate anti-money laundering standards, or that are subject to sanctions, embargoes, or similar measures.
High Risk Countries are countries or territories that are identified by credible sources, such as the Financial Action Task Force (FATF), as having inadequate anti-money laundering standards, or as being a source, transit, or destination of illicit funds. The Principles state that the bank should conduct additional due diligence on clients and beneficial owners who are connected to high risk countries, and apply enhanced measures to mitigate the risks.
High Risk activities are activities that involve clients and beneficial owners whose source of wealth or funds originates from sectors or industries that are known to be vulnerable to money laundering, such as cash- intensive businesses, gambling, arms trade, precious metals and stones, or art and antiquities. The Principles state that the bank should conduct additional due diligence on clients and beneficial owners who are engaged in high risk activities, and verify the legitimacy and origin of their wealth and funds.
= The main reference for this question is the document titled "Wolfsberg Anti-Money Laundering Principles for Private Banking (2012)" published by the Wolfsberg Group. You can access it by clicking here. You can also find more information about the Wolfsberg Principles and their application on the Wolfsberg Group website and the Lexology website.
CAMS-CN Exam Question 272
根據沃爾夫斯堡集團概述的反洗錢原則,私人銀行和代理銀行在監控恐怖主義融資方面有什麼共同點?
Correct Answer: B
According to the Wolfsberg Group, a global association of leading banks that develops guidance and standards for the management of financial crime risks, both private and correspondent banks should monitor account and transactional activity after the proper identification and verification of customers, as part of their anti-money laundering and counter-terrorist financing (AML/CTF) measures12. This is consistent with the FATF Recommendation 10, which requires financial institutions to conduct ongoing due diligence on their business relationships, including scrutinising transactions to ensure that they are consistent with the customer's risk profile and source of funds3. Monitoring account and transactional activity is a key component of the risk-based approach, as it enables banks to detect and report suspicious or unusual transactions, identify changes in customer behaviour or circumstances, and update customer information and risk assessments accordingly4.
References:
1: Wolfsberg Anti-Money Laundering Principles for Private Banking (2012)
2: Wolfsberg Correspondent Banking Due Diligence Questionnaire (2017)
3: The FATF Recommendations - Financial Action Task Force
4: Risk-Based Approach for the Banking Sector - Financial Action Task Force
References:
1: Wolfsberg Anti-Money Laundering Principles for Private Banking (2012)
2: Wolfsberg Correspondent Banking Due Diligence Questionnaire (2017)
3: The FATF Recommendations - Financial Action Task Force
4: Risk-Based Approach for the Banking Sector - Financial Action Task Force
CAMS-CN Exam Question 273
一份關於汽車經銷商安排存款的可疑交易報告啟動了刑事調查。經銷商更換了分支機構,並開始與經銷商贈送大量禮物的第一線員工進行交易。
該員工負責處理經銷商的所有結構性存款,並且不會在內部報告可疑活動。
主管機關已建議反洗錢專家在調查結束前避免向該員工舉報。
專家接下來該採取什麼行動?
該員工負責處理經銷商的所有結構性存款,並且不會在內部報告可疑活動。
主管機關已建議反洗錢專家在調查結束前避免向該員工舉報。
專家接下來該採取什麼行動?
Correct Answer: C
it describes the action that the anti-money laundering specialist should take next, which is to consult with senior management and the legal advisor. This is because the specialist needs to seek guidance and approval from the higher authorities and the legal experts on how to handle the situation without compromising the ongoing criminal investigation or violating the anti-money laundering laws and regulations. The specialist also needs to ensure that the institution's internal policies and procedures are followed andthat the appropriate measures are taken to mitigate the risks and protect the reputation of the institution.
The other options are not necessarily actions that the anti-money laundering specialist should take next, although they may be considered or implemented later depending on the outcome of the consultation and the investigation. Option A describes a possible consequence for the employee, which is to recommend the immediate termination of the employee, but this may not be the best course of action at this stage, as it may alert the employee or the dealer of the investigation, or it may be premature or disproportionate without sufficient evidence or due process. Option B describes a possible measure for the dealer, which is to advise that the dealer's accounts should be closed, but this may not be feasible or advisable at this stage, as it may also tip off the dealer or the employee of the investigation, or it may interfere with the collection of evidence or the prosecution of the case. Option D describes a possible reporting obligation for the institution, which is to inform the institution's regulatory agency of the situation, but this may not be required or appropriate at this stage, as it may conflict with the instructions of the competent authority or the confidentiality of the investigation, or it may expose the institution to legal or regulatory liabilities or sanctions.
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 6, pages 132-133
https://www.acams.org/wp-content/uploads/2019/09/ACAMS-CAMS-Study-Guide-6th-Edition-Chapter-6.pdf
The other options are not necessarily actions that the anti-money laundering specialist should take next, although they may be considered or implemented later depending on the outcome of the consultation and the investigation. Option A describes a possible consequence for the employee, which is to recommend the immediate termination of the employee, but this may not be the best course of action at this stage, as it may alert the employee or the dealer of the investigation, or it may be premature or disproportionate without sufficient evidence or due process. Option B describes a possible measure for the dealer, which is to advise that the dealer's accounts should be closed, but this may not be feasible or advisable at this stage, as it may also tip off the dealer or the employee of the investigation, or it may interfere with the collection of evidence or the prosecution of the case. Option D describes a possible reporting obligation for the institution, which is to inform the institution's regulatory agency of the situation, but this may not be required or appropriate at this stage, as it may conflict with the instructions of the competent authority or the confidentiality of the investigation, or it may expose the institution to legal or regulatory liabilities or sanctions.
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 6, pages 132-133
https://www.acams.org/wp-content/uploads/2019/09/ACAMS-CAMS-Study-Guide-6th-Edition-Chapter-6.pdf
CAMS-CN Exam Question 274
銀行合規官員發現董事會主席個人帳戶中的現金存款活動與預期和歷史現金活動不一致。現金活動的結構似乎是為了避免大額現金交易的當地法律備案要求,並提交了可疑交易報告(STR)。
合規官應如何向董事會報告 STR 的備案情況,而不向主體透露該備案的存在?
合規官應如何向董事會報告 STR 的備案情況,而不向主體透露該備案的存在?
Correct Answer: B
The best option for the compliance officer is to follow the financial institution's established STR reporting policy, which should include procedures for reporting suspicious activity involving senior management or board members. This would ensure that the compliance officer acts in accordance with the bank's internal controls and governance, and avoids any potential conflicts of interest or breaches of confidentiality. The other options are not advisable because they could either compromise the integrity of the STR filing, expose the compliance officer to legal or reputational risks, or alert the subject of the investigation.
ACAMS Study Guide for the CAMS Certification Examination, 6th Edition, Chapter 4, page 1401 ACAMS CAMS Certification Video Training Course, Module 4, Lesson 22 ACAMS CAMS Certification Practice Exam, Question 843
ACAMS Study Guide for the CAMS Certification Examination, 6th Edition, Chapter 4, page 1401 ACAMS CAMS Certification Video Training Course, Module 4, Lesson 22 ACAMS CAMS Certification Practice Exam, Question 843
CAMS-CN Exam Question 275
對於向客戶提供線上服務的金融機構來說,最大的洗錢風險是什麼?
Correct Answer: A
One of the key components of an effective anti-money laundering (AML) program is customer due diligence (CDD), which involves verifying the identity of the customer, understanding the nature and purpose of the customer's relationship with the financial institution (FI), and assessing the risk of money laundering or terrorist financing that the customer poses. CDD is essential for preventing and detecting the misuse of the FI' s services by criminals, and for complying with the relevant laws and regulations.
However, CDD can be challenging for FIs that offer online services to customers, as there is a greater difficulty in matching the customer with the provided identification documentation. Unlike face-to-face interactions, online services rely on electronic or remote methods of identification and verification, such as scanned copies of documents, biometric data, digital signatures, or third-party verification services. These methods may not be as reliable or secure as physical verification, and may expose the FI to the risk of identity fraud, document forgery, or impersonation. Moreover, online services may attract customers from different jurisdictions, which may have different standards and requirements for identification and verification, and may pose different levels of risk.
Therefore, FIs that offer online services to customers should implement enhanced due diligence (EDD) measures to mitigate the risk of money laundering, such as obtaining additional information or documentation from the customer, applying more stringent verification procedures, conducting more frequent and intensive monitoring of the customer's transactions and behavior, and restricting or limiting the types or amounts of transactions that the customer can perform online.
CAMS Study Guide - 6th Edition, Chapter 3, Section 3.4, page 82
Anti-Money Laundering in a Nutshell, Chapter 4, Section 4.2, page 63
Guidance on Digital Identity, Section 2, page 8
Anti-Money Laundering, The Basics: Installment 1, Section 3.2, page 5
However, CDD can be challenging for FIs that offer online services to customers, as there is a greater difficulty in matching the customer with the provided identification documentation. Unlike face-to-face interactions, online services rely on electronic or remote methods of identification and verification, such as scanned copies of documents, biometric data, digital signatures, or third-party verification services. These methods may not be as reliable or secure as physical verification, and may expose the FI to the risk of identity fraud, document forgery, or impersonation. Moreover, online services may attract customers from different jurisdictions, which may have different standards and requirements for identification and verification, and may pose different levels of risk.
Therefore, FIs that offer online services to customers should implement enhanced due diligence (EDD) measures to mitigate the risk of money laundering, such as obtaining additional information or documentation from the customer, applying more stringent verification procedures, conducting more frequent and intensive monitoring of the customer's transactions and behavior, and restricting or limiting the types or amounts of transactions that the customer can perform online.
CAMS Study Guide - 6th Edition, Chapter 3, Section 3.4, page 82
Anti-Money Laundering in a Nutshell, Chapter 4, Section 4.2, page 63
Guidance on Digital Identity, Section 2, page 8
Anti-Money Laundering, The Basics: Installment 1, Section 3.2, page 5
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