CAMS PDF Exam Material 2026 Realistic CAMS Dumps Questions
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To become a CAMS certified professional, candidates must pass a rigorous exam that consists of 120 multiple-choice questions. CAMS exam is divided into four sections, and candidates are required to score at least 75% in each section to pass the exam. CAMS exam is computer-based and can be taken at various testing centers around the world. Certified Anti-Money Laundering Specialists (the 6th edition) certification is valid for three years, after which professionals are required to renew their certification by completing continuing education courses.
NEW QUESTION # 416
the Financing of Terrorism (CFT)]
AU.S. bank recently received a regulatory order to remediate its AML programs, which includedseveral violations of law.
Whatdegree of accountabilityis it possible for thebank's senior management and employees to face?
- A. The bank's designated AML compliance officer is likely to face criminal prosecution because the bank received a regulatory order.
- B. The bank's designated AML compliance officer and senior management may face personal liability if they failed to take actions while aware of AML violations at the bank.
- C. The bank's designated AML compliance officer and senior management can face civil prosecution but not criminal prosecution for violation of AML laws.
- D. The bank's designated AML compliance officer is the only individual in the company's senior management team that can face personal liability for violation of AML laws.
Answer: B
Explanation:
Senior management and AML officers may face personal liability if they knowingly allow AML violations to persist.
* Option A (Correct):If senior management or the AML officer was aware of violations and failed to act, they could face regulatory or criminal liability.
* Option B (Incorrect):Criminal liability depends on intent and negligence-an AML officer is not automatically prosecuted because a bank receives a regulatory order.
* Option C (Incorrect):Liability extends beyond the AML officer-other senior executives can also be held accountable.
* Option D (Incorrect):Violations can result in both civil and criminal prosecution, depending on the severity.
Legal Risks for AML Compliance Failures:
* Civil penalties (fines and sanctions) for AML program deficiencies.
* Criminal charges if executives knowingly ignore violations.
* Regulatory enforcement actions leading to license revocation.
Reference:
USA PATRIOT Act Section 352 (AML Compliance Program Requirements)
FinCEN Guidelines on AML Compliance Officer Liability
FATF Recommendation 35 (Sanctions for AML Non-Compliance)
NEW QUESTION # 417
When should a financial institution (FI) exit a relationship? (Choose two.)
- A. The FI's stated policies and procedures for closing an account
- B. The suspicious conduct of the account holder
- C. The reputational risk to the FI posed by closing the account
- D. The request from law enforcement to close the account
- E. The FI's requirements for opening an account
Answer: A,B
Explanation:
A financial institution (FI) should exit a relationship when the suspicious conduct of the account holder or the FI's stated policies and procedures for closing an account warrant such action. A FI has the right and responsibility to terminate a customer relationship that poses an unacceptable level of risk to the FI or violates its AML/CFT program. A FI should have clear and consistent criteria for exiting a relationship, such as the number and severity of SARs filed, the nature and extent of due diligence conducted, the availability and effectiveness of mitigating controls, and the alignment of the customer profile with the FI's risk appetite. A FI should also document the rationale and process for exiting a relationship, communicate the decision to the customer and relevant stakeholders, and monitor the account until closure.
The reputational risk to the FI posed by closing the account or the request from law enforcement to close the account are not valid reasons for exiting a relationship by themselves. A FI should consider the potential reputational impact of closing an account, but it should not outweigh the legal and regulatory obligations of the FI to prevent and detect money laundering and terrorist financing. A FI should also cooperate with law enforcement requests, but it should not automatically close an account based on such requests, as they may interfere with ongoing investigations or intelligence gathering. A FI should exercise its own judgment and discretion in deciding whether to exit a relationship, based on its own policies and procedures and the facts and circumstances of each case.
Exiting Relationships: Ten Steps to a Successful Client Exit Strategy
De-risking your SARs: Building SAR relationship exit strategies into your AML/CFT program Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations
NEW QUESTION # 418
In addition to monitoring for suspicious activity, what are electronic monitoring systems also valuable for?
- A. Proving to the Board of Directors that the FIU is doing its job
- B. Meeting mandatory regulatory requirements for system implementation
- C. Highlighting the skills of the system analysts
- D. Identifying how customers are using products
Answer: B
NEW QUESTION # 419
Combating the Financing of Terrorism (CFT)]
A customer comes into a financial institution and deposits a large amount of cash. He has never done that before. When asked about the deposit, he indicates he recently sold a used car and received cash.
He does not trust forms of payment and is wary of counterfeit money orders. What should the bank do?
- A. The institution should close the account before another issues arise
- B. While the explanation may be plausible, the institute should nonetheless file a Suspicious Transaction Report to protect itself
- C. While the explanation appears plausible, the institution should, for a period of time, monitor the account for cash transactions and suspicious activity
- D. The bank has received a plausible explanation, so it should do nothing
Answer: C
Explanation:
A large cash deposit is a potential indicator of money laundering, especially if it is inconsistent with the customer's profile or behavior. Therefore, the bank should ask the customer about the source and purpose of the funds, and verify the information if possible. In this case, the customer claims to have sold a used car and received cash, which may be a reasonable explanation. However, the bank should not rely solely on the customer's statement, but should also monitor the account for any further cash transactions or suspicious activity that may indicate money laundering. For example, the bank should check if the customer withdraws the cash soon after the deposit, transfers the funds to other accounts or jurisdictions, or engages in structuring or smurfing to avoid reporting thresholds.
The bank should not do nothing, as this may expose the bank to regulatory or reputational risks, or facilitate money laundering. The bank should also not file a Suspicious Transaction Report (STR) unless there are other grounds to suspect money laundering, as this may be premature or unnecessary. The bank should not close the account before another issues arise, as this may be disproportionate or discriminatory, and may also alert the customer to the bank's suspicion.
:
[ACAMS Study Guide for the CAMS Certification Examination, 6th Edition], Chapter 4: Conducting or Supporting the Investigation Process, pp. 103-104, 107-108.
Customer Identification Program - Overview, Federal Financial Institutions Examination Council, April 2018, pp. 1-2, 4-5.
Suspicious Activity Reporting - Overview, Federal Financial Institutions Examination Council, April 2018, pp. 1-2, 4-5.
18 AML Analyst Interview Questions (With Example Answers), ResumeCat, accessed on February 9, 2024.
NEW QUESTION # 420
Which is most relevant when examining transactions suspected of being associated with money laundering via real estate?
- A. The beneficial owner of the asset
- B. The financial institutions involved in the transaction
- C. The asset's location
- D. The currency used for payment
Answer: A
Explanation:
Money laundering through real estate transactions involves integrating illicit funds into the legitimate financial system while providing a relatively "safe" property investment. In this context, the most relevant factor to examine is the beneficial owner of the asset. Identifying the true owner behind a property helps uncover potential money laundering schemes. Criminals often use third parties, shell companies, or complex ownership structures to distance the transaction from the source of illicit funds. Investigating the beneficial owner's identity is crucial for detecting and preventing real estate-related money laundering12.
References:
Understanding money laundering through real estate transactions
What Is Money Laundering? - Investopedia
NEW QUESTION # 421
the Financing of Terrorism (CFT)]
Which is a characteristic of the Financial Action Task Force (FATF) 40 recommendations?
- A. They comprise global standards for countering money laundering, recognized by government bodies across the world.
- B. They provide a list of mandatory requirements for an effective AML regulatory framework.
- C. They enable FATF's active engagement in law enforcement matters, investigations, or prosecutions.
- D. They are automatically transposed into local law across the EU member states and the US.
Answer: A
Explanation:
The characteristic of the Financial Action Task Force (FATF) 40 recommendations is that they comprise global standards for countering money laundering, recognized by government bodies across the world. The FATF 40 recommendations provide a comprehensive framework of measures that countries should implement to combat money laundering and terrorist financing. The recommendations are not mandatory, but are widely recognized and followed by countries across the globe. The recommendations cover a range of areas, including customer due diligence, record-keeping, suspicious activity reporting, and international cooperation.
NEW QUESTION # 422
While all employees need AML awareness training, which three groups within the institution should receive targeted AML training? Choose 3 answers
- A. Senior Management and the human resources staff
- B. The AML officer and the compliance staff
- C. The Board of Directors and Senior Management
- D. Employees who have contact with customers or transactions
Answer: A,B,D
NEW QUESTION # 423
What are three indicators of money laundering associated with using electronic funds transfers? Choose 3 answers
- A. Funds transfers are received or sent from the same person to or from different accounts
- B. Funds transfers to or from a financial secrecy haven without an apparent business reason
- C. Payment or receipts with no apparent link to legitimate contracts, goods or services
- D. Regular and frequent transfers from the account of a large company said to be payment for goods bought on credit
Answer: A,B,C
Explanation:
According to the Anti-Money Laundering Specialist (the 6th edition) resources, electronic funds transfers (EFTs) are transactions that involve the movement of funds electronically from one account to another, either within the same financial institution or across different institutions, domestically or internationally1. EFTs can be used for legitimate purposes, such as facilitating trade, commerce, and remittances, but they can also be exploited by money launderers to conceal the origin, ownership, and destination of illicit funds2. Some of the indicators of money laundering associated with using EFTs are:
Funds transfers to or from a financial secrecy haven without an apparent business reason. Financial secrecy havens are jurisdictions that offer a high degree of banking secrecy, low or no taxes, lax regulation and supervision, and weak or non-existent anti-money laundering and counter-terrorist financing (AML/CTF) measures3. Money launderers may use these havens to hide their illicit funds, evade taxes, and avoid scrutiny from authorities. Funds transfers to or from these havens without a clear or plausible explanation may indicate an attempt to launder money or finance terrorism.
Funds transfers are received or sent from the same person to or from different accounts. This may indicate a layering technique, which is the process of moving funds through multiple accounts, institutions, or jurisdictions to obscure the audit trail and the source and ownership of the funds4. Money launderers may use this technique to avoid detection, reporting, or freezing of their funds by authorities or financial institutions.
Payment or receipts with no apparent link to legitimate contracts, goods or services. This may indicate a trade-based money laundering technique, which is the process of using trade transactions to disguise the movement of illicit funds, either by over- or under-invoicing, misrepresenting the quantity or quality of goods, or falsifying documents. Money launderers may use this technique to transfer value across borders, evade taxes or customs duties, or justify the movement of funds that have no legitimate origin or purpose.
The other option is incorrect because:
Regular and frequent transfers from the account of a large company said to be payment for goods bought on credit is not necessarily an indicator of money laundering associated with using EFTs. This may be a normal business practice for some companies that have a high volume of transactions or a long-term relationship with their suppliers or customers. However, this may also be a red flag if the company is not well-known, has no physical presence, has no apparent business activity, or is located in a high-risk jurisdiction. Therefore, this option requires further investigation and verification before concluding that it is an indicator of money laundering.
Reference:
1: ACAMS, CAMS Study Guide, 6th Edition, Chapter 5, p. 104 2: ACAMS, CAMS Study Guide, 6th Edition, Chapter 5, p. 105 3: ACAMS, CAMS Study Guide, 6th Edition, Chapter 5, p. 107 4: ACAMS, CAMS Study Guide, 6th Edition, Chapter 5, p. 106 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 5, p. 108
NEW QUESTION # 424
A multinational corporation is considering expanding into a new market with a history of political instability and corruption.
Which strategy would be most effective in mitigating reputational risk from a financial crime perspective associated with such an expansion?
- A. Ensuring the company has strong ties with local government officials to influence policy and avoid negative scrutiny
- B. Minimizing the company's direct presence in the country to reduce exposure to potential risks
- C. Partnering with established local businesses to leverage their knowledge and connections while sharing risks
- D. Committing to open communication, ethical practices, and community engagement to build trust with stakeholders
- E. Ensure the jurisdiction risks and other relevant factors have been taken into consideration in the EWRA and the residual risks are within the corporation's risk appetite
Answer: E
Explanation:
The most effective strategy is to ensure that jurisdictional and other relevant risks are assessed through the Enterprise-Wide Risk Assessment (EWRA), and that any residual risks fall within the corporation's defined risk appetite. This structured, risk-based approach supports informed decision-making and protects against reputational damage related to financial crime.
NEW QUESTION # 425
Which of the following ate efficient approaches lo performing horizon scanning? (Select Two.)
- A. Relying on information and insights from peers and working groups
- B. Regularly contacting the regulator to inquire about updates and future developments
- C. Subscribing lo a regulators' newsletter
- D. Using a specific provider for regulatory horizon scanning
Answer: C,D
NEW QUESTION # 426
What should be part of an institution's monitoring and STR filing process? Choose 3 answers
- A. Periodic training on the identification of red flags
- B. Review of STR filing trends and typologies
- C. Requirement that the Board of Directors approve the filing of an STR
- D. Review on a regular basis of all high-risk accounts and transactions
Answer: A,B,D
NEW QUESTION # 427
An anti-money laundering specialist has been asked to create internal anti-money laundering policies, procedures and controls for a recently chartered offshore financial institution.
Which three should be included? Choose 3 answers
- A. Compliance requirement of host and charting countries
- B. A training program for senior management and staff
- C. Basel Committee on Banking Supervision's capital adequacy requirements for the host country
- D. An anti-money laundering compliance program, internal audit program, and procedure manual
Answer: A,B,D
Explanation:
these are the essential components of an effective anti-money laundering program for any financial institution, especially an offshore one. According to the CAMS Study Guide, 6th Edition, an anti-money laundering program should include the following elements1:
* A risk assessment that identifies and evaluates the money laundering and terrorist financing risks faced by the institution, and the measures taken to mitigate them.
* A compliance program that establishes policies, procedures, and controls to prevent, detect, and report money laundering and terrorist financing activities, and to comply with the applicable laws and regulations of the host and chartering countries.
* A designated compliance officer who is responsible for overseeing the implementation and maintenance of the compliance program, and for liaising with the relevant authorities and stakeholders.
* A training program that provides regular and appropriate education and awareness to senior
* management and staff on their roles and responsibilities in relation to anti-money laundering and terrorist financing, and on the latest trends and typologies in these areas.
* An independent audit function that reviews and tests the adequacy and effectiveness of the compliance program, and reports the findings and recommendations to senior management and the board of directors.
The Basel Committee on Banking Supervision's capital adequacy requirements for the host country (answer A) are not directly related to anti-money laundering, but rather to the prudential regulation and supervision of banks. They are important for ensuring the financial soundness and stability of banks, but they are not sufficient to prevent or combat money laundering and terrorist financing2.
References:
1: CAMS Study Guide, 6th Edition, Chapter 5: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), page 139-140. 2: Basel Committee on Banking Supervision, Bank for International Settlements.
NEW QUESTION # 428
After evaluating recent changes to international standards, an anti-money laundering specialist should consider enhanced due diligence on accounts held by
1. lawyers.
2. foreign exchange dealers.
3. retail account holders.
4. precious metal dealers.
- A. 1, 3, and 4 only
- B. 1, 2, and 3 only
- C. 1, 2, and 4 only
- D. 2, 3, and 4 only
Answer: C
Explanation:
Enhanced due diligence (EDD) is a higher level of customer due diligence that is required for customers or accounts that pose a higher risk of money laundering or terrorist financing. According to the FATF Recommendations, EDD measures may include obtaining additional information on the customer, the beneficial owner, the intended nature and purpose of the business relationship, the source and destination of funds, and the reasons for transactions. EDD is also required for customers or accounts that are from or in countries that do not have adequate AML/CFT systems or are subject to sanctions or embargoes.
Among the four categories of customers or accounts listed in the question, lawyers, foreign exchange dealers, and precious metal dealers are considered as high-risk by the FATF and other international standards, and therefore require EDD. Lawyers may be involved in transactions that conceal the origin or ownership of illicit funds, such as creating shell companies, trusts, or foundations. Foreign exchange dealers may facilitate the movement of illicit funds across borders or jurisdictions, or provide anonymous or pseudonymous services.
Precious metal dealers may deal with high-value goods that are easily convertible into cash, or may be used to launder proceeds of crime or evade sanctions.
Retail account holders, on the other hand, are generally considered as low-risk customers or accounts, unless they exhibit unusual or suspicious behavior or transactions. Therefore, they do not require EDD by default, but only when there are specific indicators of higher risk.
[ACAMS Study Guide for the CAMS Certification Examination, 6th Edition], Chapter 3: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), pp. 75-76,
79-80.
FATF Guidance on Correspondent Banking Services, October 2016, pp. 7-8, 12-13.
Customer Due Diligence - Overview, Federal Financial Institutions Examination Council, April 2018, pp. 1-2,
5-6.
Customer due diligence, The Law Society, accessed on February 9, 2024.
Anti-Money Laundering (AML) Source Tool for Broker-Dealers, U.S. Securities and Exchange Commission, May 16, 2022, pp. 1-2, 5-6.
NEW QUESTION # 429
An auction house dealing in fine art and antiques sells a well-known painting at a price of $12 million to an agent bidding for a group of local investors. The same painting sold ten years prior at auction for $5 million. The auction house receives payment for the painting via wire transfer from an account maintained in an offshore jurisdiction by the investor group. No beneficial ownership information is available for the account.
What are the two money laundering red flags? (Choose two.)
- A. An agent bids on the painting for a group of investors.
- B. Lack of beneficial ownership details for the originating account.
- C. Payment is received from an account in an offshore jurisdiction.
- D. The payment is received via wire transfer.
- E. The painting has more than doubled its value in ten years.
Answer: B,C
Explanation:
The payment received from an account in an offshore jurisdiction and the lack of beneficial ownership details for the originating account are two money laundering red flags. Offshore jurisdictions are often used by money launderers to hide the source and destination of their funds, as they typically have low transparency and weak regulatory oversight. The absence of beneficial ownership information makes it difficult to identify the true owners and controllers of the funds, and to assess the legitimacy and risk of the transaction. These factors increase the possibility that the payment is related to money laundering, tax evasion, or other illicit activities.
Reference:
ACAMS CAMS Certification Study Guide, 6th Edition, page 33
ACAMS CAMS Certification Exam Outline, 6th Edition, Domain 1, Task 1.2
ACAMS CAMS Certification Video Training Course, Module 1, Lesson 1.2
Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition), Question 315
NEW QUESTION # 430
Combating the Financing of Terrorism (CFT)]
According to the Financial Action Task Force, financial institutions should exit the relationship with a client in which case?
- A. The client is a politically exposed person.
- B. There is a change in ownership structure.
- C. The country of incorporation has been elevated to high-risk.
- D. The client refuses to update information.
Answer: D
Explanation:
According to the Financial Action Task Force (FATF), financial institutions should apply a risk-based approach to customer due diligence (CDD), which includes obtaining and updating information on the identity, beneficial ownership, and business activities of their clients. If a client refuses to provide or update such information, or provides false or misleading information, the financial institution should consider this as a red flag for potential money laundering or terrorist financing, and should exit the relationship with the client, unless the circumstances warrant otherwise. Exiting the relationship with a client who refuses to update information is also consistent with the FATF's Recommendation 10, which requires financial institutions to terminate the business relationship if they are unable to perform CDD measures.
References:
1: This document contains the FATF's 40 Recommendations, which are the international standards for combating money laundering and terrorist financing. Recommendation 10 covers the CDD requirements for financial institutions, and paragraph 22 states that "If the financial institution is unable to comply with paragraphs 10 to 12, 15 and 17, it should not open the account, commence business relations or perform the transaction; or should terminate the business relationship; and should consider making a suspicious transactions report in relation to the customer."
2: This document provides guidance on the implementation of the FATF's Recommendations on transparency and beneficial ownership, which are relevant for CDD purposes. It explains the definition of beneficial owner, the risks associated with legal persons and arrangements, and the effective mechanisms to combat the misuse of such entities. It also provides examples of situations where financial institutions should exit the relationship with a client, such as when the client refuses to provide or update information on beneficial ownership or control, or when the client is a shell company or a trust with no legitimate economic purpose.
NEW QUESTION # 431
A large international bank has detected potentially suspicious activity in one of its customer accounts. Following an investigation, the bank has determined the activity to be typical of suspected money laundering.
To which entity should this activity be reported on a suspicious transaction report according to Financial Action Task Force?
- A. National Security Council
- B. Local law enforcement agency
- C. Federal law enforcement agency
- D. Financial Intelligence Unit
Answer: D
NEW QUESTION # 432
A customer puts high-denomination cash notes into a poker machine at a casino. Without placing any bets, the customer collected winnings in the form of a check from the casino.
Which money laundering threats could result from the customer's activities?
- A. Micro-structuring cash
- B. Misuse of money service business
- C. Legitimizing illicit funds
- D. Obscured beneficial ownership
Answer: A
Explanation:
1. A. Micro-structuring cash:
The customer's behavior of putting high-denomination cash notes into a poker machine without placing bets and then collecting winnings in the form of a check resembles "structuring" or "smurfing." Structuring involves breaking down large sums of money into smaller transactions to avoid detection. In this case, the customer may be attempting to legitimize illicit funds by converting them into casino winnings1.
2. B. Legitimizing illicit funds:
By using the poker machine to convert cash into a check, the customer is potentially legitimizing illicit funds.
The casino winnings obtained through this process may appear legitimate, even though the initial source of the cash remains suspicious1.
A: Micro-structuring cash:
The customer's actions of repeatedly inserting high-denomination cash notes into the poker machine without placing bets and then collecting winnings in the form of a check resemble structuring. Structuring involves deliberately breaking down large amounts of cash into smaller transactions to avoid detection. Money launderers engage in structuring to obscure the origin of funds and make them appear legitimate. In this case, the customer's behavior raises red flags and warrants further investigation.
B: Legitimizing Illicit Funds:
By converting cash into casino winnings (in the form of a check), the customer may be attempting to legitimize illicit funds. The casino winnings obtained through this process could be used to create a veneer of legitimacy, even though the initial source of the cash remains suspicious. Casinos are attractive for money launderers due to the anonymity and fluidity of transactions, making it challenging to trace the origin of funds1.
References: 1: Anti-Money Laundering Specialist (6th edition), ACAMS, Chapter 3: "Money Laundering and Terrorist Financing Methods," Section 3.1.2: "Structuring."
NEW QUESTION # 433
A high-profile, successful entrepreneur has been a client of a Swiss private bank for more than a decade. Recently, the entrepreneur launched a political career, with rather extremist political views. On which grounds can the bank terminate the client's bank relationship? (Select Two.)
- A. The client is not able (or willing) to provide documentary evidence of tax compliance.
- B. The client has made his/her fortune in the mining and excavation industry, which the bank has deemed as a high-risk industry.
- C. Continuing the client relationship poses an increasing reputational risk, which could negatively affect the bank's future business.
- D. The client's account has an increase in unusual and significant monthly inflows.
- E. A business partner of the account holder requests an asset freeze, stating a business dispute and disagreement over the quality of goods and services sold to the partner.
Answer: A,C
Explanation:
1. Tax Compliance: Banks have a responsibility to ensure that their clients comply with tax regulations. If a client fails to provide evidence of tax compliance or is unwilling to do so, the bank may terminate the relationship to avoid legal and regulatory risks.
2. Reputational Risk: High-profile clients with extremist political views can create reputational risks for the bank. If the client's political activities or views could harm the bank's reputation, the bank may choose to terminate the relationship.
Reference:
1. ACAMS Certification Package, 6th Edition.
2. The right to terminate a banking relationship unilaterally.
3. A bank's right to terminate its relationship.
NEW QUESTION # 434
the Financing of Terrorism (CFT)]
Bank A is a non-United States (U.S.) bank that has $5 million in a correspondent account at a bank in New York City. The Worldwide Terrorist Syndicate (WTS) has $1 million in its account at a non-US branch of Bank A. The U.S. government has initiated forfeiture action against the WTS.
Which potential action can the U.S. take under the USA PATRIOT ACT pursuant to the issuance seizure warrant?
- A. Seize Bank A's $5 million correspondent account in the U.S.
- B. Seize $1 million from Bank A's correspondent account in the U.S.
- C. Seize $5 million from the non-U.S. branch of Bank A where the WTS' account is located.
- D. Seize WTS' $1 million account at the non-U.S. branch of Bank A.
Answer: B
Explanation:
This potential action is authorized by Section 319 of the USA PATRIOT ACT, which allows the U.S.
government to seize funds from a foreign bank's correspondent account in the U.S. if the foreign bank refuses to cooperate with a request for records relating to an investigation of money laundering or terrorist financing.
The U.S. government can seize an amount equal to the funds in the account of the target of the investigation, regardless of whether those funds are actually in the correspondent account. In this case, the U.S. government can seize $1 million from Bank A's correspondent account in the U.S. because Bank A holds $1 million in the account of the WTS, which is the target of the forfeiture action.
The other potential actions are not authorized by the USA PATRIOT ACT or other U.S. laws. The U.S.
government cannot seize Bank A's entire $5 million correspondent account in the U.S. because that would exceed the amount in the WTS's account andwould violate the principle of proportionality. The U.S.
government cannot seize the WTS's $1 million account at the non-U.S. branch of Bank A because that would require the cooperation of the foreign jurisdiction where the branch is located, which may not be forthcoming.
The U.S. government cannot seize $5 million from the non-U.S. branch of Bank A where the WTS's account is located because that would also require the cooperation of the foreign jurisdiction and would exceed the amount in the WTS's account.
:
CAMS Certification Package - 6th Edition | ACAMS, Chapter 3: International Standards and Global Initiatives, pp. 67-68 CAMS Certifications: How to Get CAMS Certified | ACAMS, CAMS Study Guide, pp. 54-55 How Does the Patriot Act Affect Criminal Investigations? | Nolo, Section 319: Forfeiture of Funds in United States Interbank Accounts The USA PATRIOT Act at 20: Sneak and Peek Searches - CRS Reports, Section 319: Forfeiture of Funds in United States Interbank Accounts
NEW QUESTION # 435
An anti-money laundering specialist is concerned that several suspicious transaction reports will discuss potential illegal activity of bank employees. In this situation, which of the following is the immediate concern for the institution?
- A. Ensuring no delay in informing the Board.
- B. Prohibiting distribution of suspicious transaction report copies to the Board.
- C. The type of form to be used when reporting to the Board.
- D. The timing of the presentation of suspicious transaction reports to the competent authority.
Answer: A
NEW QUESTION # 436
After several months of research, the Director of Marketing and the Managing Director of Business Development received approval to launch a branded, stored-value card that will be marketed to the diverse, primarily non-resident population that comprises the bank's current customer demographics. The Chief Credit Officer and the Risk Officer have also been involved in the efforts to develop the card. After the card is launched, the anti-money laundering officer is consulted. The anti-money laundering officer should advise the bank that compliance should have been involved
- A. During product development to perform a risk assessment of the product.
- B. During product development to develop reports for the Board.
- C. After product development to confer with the legal department.
- D. After product development to perform an assessment of the product.
Answer: A
Explanation:
The anti-money laundering officer should advise the bank that compliance should have been involved during product development to perform a risk assessment of the product. This is because stored-value cards are considered high-risk products for money laundering and terrorist financing, as they can be used to store, transfer, or access funds anonymously, across borders, or through third parties. A risk assessment would help the bank identify and mitigate the potential vulnerabilities and threats associated with the product, such as customer due diligence, transaction monitoring, record keeping, reporting, and training. A risk assessment would also help the bank comply with the regulatory requirements and expectations for offering such products, as well as the industry best practices and standards.
Reference:
ACAMS CAMS Certification Study Guide, 6th Edition, Chapter 5, Section 5.3.2, p. 140-1411 ACAMS CAMS Certification Exam Outline, 6th Edition, Domain 1, Task 1.1, p. 42 FATF Guidance on the Risk-Based Approach for Prepaid Cards, Mobile Payments and Internet-Based Payment Services, June 2013, p. 9-103
NEW QUESTION # 437
In performing a risk analysis, which factor(s) should a financial institution review?
- A. The adequacy and completeness of its STR filings
- B. Its customer base, location, products and services
- C. Recent regulatory actions against financial institutions of comparable size
- D. The level of its gross revenue
Answer: B
Explanation:
these are the main factors that determine the inherent money laundering risk of a financial institution. The customer base, location, products and services of a financial institution affect the type, volume, and complexity of transactions that it processes, as well as the exposure to high-risk customers, jurisdictions, and activities12. A financial institution should review these factors regularly and conduct a comprehensive risk assessment to identify, measure, and mitigate its money laundering risk34.
Anti Money Laundering Risk Assessment - Financial Crime Academy1
Anti-Money-Laundering (AML) Risk Approach Explained | Okta2
Anti-Money Laundering (AML) Risk Assessment | ACAMS4
2024 National Money Laundering Risk Assessment (NMLRA)5
NEW QUESTION # 438
......
The Certified Anti-Money Laundering Specialist (CAMS) exam is a globally recognized certification program designed to equip individuals with the necessary knowledge and skills to prevent and detect money laundering and terrorist financing. The CAMS certification is administered by the Association of Certified Anti-Money Laundering Specialists (ACAMS), a leading international organization dedicated to the fight against financial crime.
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