Under the Wolfsberg Correspondent Banking Principles, which action is considered an enhanced due diligence obligation to correspondent banking clients that present greater risks?
Correct Answer: C
Explanation 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)
CAMS Exam Question 232
Which two mechanisms should be implemented to assist with cross-border money laundering investigations? (Choose two.)
Correct Answer: A,C
CAMS Exam Question 233
Which actions are involved when a prosecutor instructs a bank to freeze the assets and bank accounts held by one of its clients? (Choose three.)
Correct Answer: C,E,F
When a prosecutor instructs a bank to freeze the assets and bank accounts held by one of its clients, the bank must take the following actions: Ensure the client and beneficiaries are unable to access any frozen assets during the freeze order. This means the bank must prevent any withdrawals, transfers, payments, or other transactions from the frozen accounts or assets. The bank must also notify the client and beneficiaries of the freeze order and the reason for it. The bank must comply with the freeze order until it is lifted by the court or the prosecutor12. An affidavit must accompany the freeze order for the bank to comply with the request. An affidavit is a sworn statement that provides the legal basis and evidence for the freeze order. The affidavit must specify the name of the client, the amount and location of the assets to be frozen, the nature and source of the funds, the suspected criminal activity, and the legal authority for the freeze order3 . The institution should obtain a copy of the court order to freeze the assets of the named individuals. A court order is a legal document that authorizes the bank to freeze the assets and accounts of the client. The court order must be signed by a judge or a magistrate and must include the same information as the affidavit. The bank should keep a copy of the court order for its records and to verify its validity . References: Frozen Bank Account: Here's What You Need to Know Why Is My Bank Account Frozen? - Investopedia What Is a Frozen Account? What Causes It and How to Unfreeze It [Freezing Orders - Practical Law] [Freezing Orders - The Law Society] [Freezing Orders - LexisNexis]
CAMS Exam Question 234
Which approach ensures the successful implementation of a transaction monitoring system?
Correct Answer: B
A transaction monitoring system (TMS) is a tool that helps financial institutions detect and report suspicious activities related to money laundering, terrorist financing, and other financial crimes. A TMS needs to be implemented carefully and effectively to ensure its accuracy, reliability, and compliance with regulatory requirements. One of the best practices for implementing a TMS is to perform systems integration testing (SIT) at key steps of development and user acceptance testing (UAT) prior to going live with the TMS. SIT is a process of verifying that the TMS can interact with other systems and data sources correctly and efficiently. UAT is a process of validating that the TMS meets the functional and operational expectations of the end-users and stakeholders. By conducting SIT and UAT, the financial institution can identify and resolve any issues or defects in the TMS before it is deployed in the production environment. This can help avoid potential problems such as data quality issues, false positives, false negatives, system errors, performance issues, and regulatory breaches. Performing SIT and UAT can also help ensure that the TMS is aligned with the financial institution's risk assessment, policies, procedures, and controls. References: Step 1 - Transaction Monitoring Implementation Best Practices Anti-money laundering transaction monitoring system implementation considerations ACAMS CAMS Certification Study Guide 6th Edition
CAMS Exam Question 235
On who does the ultimate responsibility for an institution's anti-money laundering program rest?