A bank sells reloadable open-loop prepaid cards to both customers and non-customers. What is a red flag associated with these cards that may indicate money laundering?
Correct Answer: B
According to the CAMS Study Guide, page 191, "Reloadable open-loop prepaid cards are a high-risk product for money laundering because they can be used to store and move large amounts of funds anonymously. They can also be used to access cash at ATMs or through cash-back transactions at merchants." Therefore, option B is a red flag that may indicate money laundering, as a non-bank customer who regularly loads large amounts of cash onto several prepaid cards may be trying to avoid identification, verification, or transaction reporting requirements. CAMS Study Guide, page 1911
CAMS Exam Question 57
When a financial institution is requested to provide data and information to a law enforcement agency for matters related to financing of terrorism, assistance:
Correct Answer: C
When a financial institution is requested to provide data and information to a law enforcement agency for matters related to the financing of terrorism, assistance cannot be refused on the grounds of tipping-off. Tipping-off refers to disclosing to a customer or any third party that a suspicious activity report (SAR) has been filed. However, in this specific context, the obligation to provide information to law enforcement takes precedence over any concerns related to tipping-off. Financial institutions must cooperate fully with law enforcement agencies in such cases to combat money laundering and terrorist financing12. References: 31 CFR 1010.520 (a) (2) FinCEN: Fact Sheet on the Rapid Response Program (RRP) FinCEN.gov Federal Financial Institutions Examination Council (FFIEC) BSA/AML Examination Manual
CAMS Exam Question 58
Which activity associated with new or developing technologies does the Financial Action Task Force recommend financial institutions pay special attention to?
Correct Answer: D
The Financial Action Task Force (FATF) recommends that financial institutions pay special attention to non- face-to-face business relationships or transactions when dealing with new or developing technologies. These include digital channels, online platforms, and virtual interactions. The increased use of technology for remote transactions poses unique risks related to customer identification, authentication, and due diligence. Financial institutions must implement robust controls to mitigate these risks and ensure compliance with anti-money laundering (AML) and counter-terrorist financing (CFT) requirements12. References: FATF Opportunities and Challenges of New Technologies for AML/CFT FATF: New Technologies for AML/CFT FATF Recommendation 15: New technologies
CAMS Exam Question 59
Which of the following entities could potentially pose a higher money laundering risk and require additional review prior to onboarding? (Select Two.)
Correct Answer: C,D
Higher-risk customer profilesoften include businesses that: * Regularly handle large volumes of cash * Operate in sectors withhistorical vulnerabilities to money laundering * Are involved invirtual assets or unregulated financial activities Option C - A local used car sale lot that allows cash payments: This business type is consideredcash-intensive, and accepting monthly payments in cash raises concerns about the source of funds, potential structuring, or placement of illicit proceeds. Option D - A Virtual Asset Service Provider (VASP): VASPs involved inpeer-to-peer crypto transactionspresent elevated AML risks due to theanonymity, speed, and borderless natureof virtual assets. These institutions are often subject toenhanced due diligence requirements. Option Ais incorrect: A large multinational with documented transactions and transparency typically poseslower inherent risk, though still subject to review. Option Bmay be reviewed, buton-site ATM replenishment using store cashis not automatically a red flag without other risk indicators. Reference: ACAMS CAMS Study Guide - 6th Edition, Chapter:Customer Risk Profiling- Section:Higher- Risk Business Types and Entities
CAMS Exam Question 60
What are two sources for maintaining up-to-date sanctions information? (Choose two.)
Correct Answer: B,D
The U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals. OFAC publishes lists of individuals and entities that are subject to various sanctions programs, such as the Specially Designated Nationals and Blocked Persons List (SDN List), the Sectoral Sanctions Identifications List (SSI List), and the Foreign Sanctions Evaders List (FSE List). These lists are updated frequently and can be accessed through OFAC's website or other sources12. The Financial Action Task Force (FATF) is an inter-governmental body that sets standards and promotes effective implementation of legal, regulatory and operational measures for combating money laundering, terrorist financing and other related threats to the integrity of the international financial system. FATF publishes lists of jurisdictions that have strategic deficiencies in their anti-money laundering and counter- terrorist financing (AML/CTF) regimes, and calls on its members and other countries to apply enhanced due diligence or counter-measures to protect themselves from the risks emanating from these jurisdictions. These lists are updated periodically and can be accessed through FATF's website or other sources34. 1: CAMS Certification Package - 6th Edition | ACAMS, Chapter 3: Sanctions, p. 63-64 2: U.S. Department of theTreasury Office of Foreign Assets Control, https://home.treasury.gov/policy-issues/financial-sanctions 3: CAMS Certification Package - 6th Edition | ACAMS, Chapter 4: FATF Recommendations, p. 77-78 4: Financial Action Task Force, http://www.fatf-gafi.org/countries/#high-risk Reference:https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_lists.aspx#search