A company contracts a life insurance policy with a savings feature of 100,000 USD for an individual in a high-risk country. The policy receives monthly cash deposits from unknown third parties. A minimal part of the deposit is invested and the rest is withdrawn by the end of the month. Which are the circumstances to consider as a risk for money laundering? (Select Two.)
Correct Answer: A,B
According to the ACAMS CAMS Study Guide (the 6th edition), one of the common methods of money laundering in the insurance sector is to purchase policies with illicit funds, overpay premiums, and then cancel or surrender the policies to receive refunds or payouts1. This allows criminals to move and disguise the source of their funds through the insurance company. Therefore, the regular withdrawals from the policy by the end of the month could indicate a money laundering scheme. Moreover, the FATF Guidance for a Risk-Based Approach for the Life Insurance Sector states that unidentified third parties depositing cash to the policy could also pose a high money laundering risk, as cash transactions are difficult to trace and third parties may act as intermediaries or nominees for the real beneficiaries2. Therefore, the insurance company should conduct enhanced due diligence on the policyholder and the third parties, and monitor the transactions for any suspicious activity. References: ACAMS CAMS Study Guide (the 6th edition), Chapter 2: Money Laundering Risks and Methods, page 671 FATF Guidance for a Risk-Based Approach for the Life Insurance Sector, pages 18-192
CAMS Exam Question 252
An organization is developing a comprehensive anti-money laundering (AML) framework. Which of the following statements best describes the relationship between AML policies and procedures?
Correct Answer: A
CAMS Exam Question 253
Which of the following provides anti-money laundering specialists information related to money laundering trends? 1. Egmont Group's 100 Cases 2. Financial Action Task Force Typologies 3. FinCEN's SAR Activity Review 4. The Wolfsberg Principles
Correct Answer: A
The Egmont Group's 100 Cases1, the Financial Action Task Force Typologies2, and FinCEN's SAR Activity Review3 are all sources of information related to money laundering trends, methods, and risks. They provide examples, analysis, and guidance on how to detect, prevent, and report money laundering and other financial crimes. The Wolfsberg Principles4, on the other hand, are a set of global standards for the prevention of moneylaundering in the correspondent banking and private banking sectors. They are not intended to provide information on money laundering trends, but rather to establish best practices and minimum requirements for financial institutions to comply with anti-money laundering regulations and expectations. Egmont Group's 100 Cases1 Financial Action Task Force Typologies2 FinCEN's SAR Activity Review3 The Wolfsberg Principles4
CAMS Exam Question 254
An AML training program should include which requirement?
Correct Answer: C
According to the Anti-Money Laundering Specialist (the 6th edition) study guide, an AML training program should include the requirement that new staff receive training during employee orientation or shortly thereafter on bank procedures. This is because new staff need to be aware of the bank's policies and procedures for complying with the money laundering regulations, such as customer due diligence, transaction monitoring, record-keeping, and reporting of suspicious activities. Training new staff as soon as possible also helps to reduce the risk of human errors or oversights that could facilitate money laundering or terrorist financing. ACAMS, CAMS Certification Package - 6th Edition, Chapter 5, page 143 ACAMS, CAMS Certification Package - 6th Edition, Chapter 5, page 144 Technical factsheet Anti-money laundering (AML) training: frequently asked questions, page 1
CAMS Exam Question 255
A non-US bank is implementing a sanctions compliance program. Which extraterritorial reach of Office of Foreign Assets Control (OFAC) regulations would matter the most to the foreign bank?
Correct Answer: D
This includes civil monetary penalties, criminal prosecution, and other enforcement actions. These penalties can be enforced against foreign individuals, regardless of whether the individual is located within the US or abroad. Additionally, OFAC has the authority to impose sanctions on foreign countries and foreign individuals, including individuals and entities located outside of the US.