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Question #271

The Wolfsberg Principles for Private Banking list circumstances that would require additional due diligence, including activities that involve which three of these choices?

A . Foreign jurisdictions
B . High Risk Countries, including those identified by credible sources as having inadequate Anti-Money Laundering standards
C . High Risk activities, involving clients and beneficial owners whose source of wealth originates from activities known to be vulnerable to money laundering
D . Public officials, including those individuals who have or had positions of public trust

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Richtige Antwort: A B C
A B C

Explanation:

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.

Reference: = 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.

Question #272

Which of the following are risk factors a financial institution should examine when onboarding a new corporate customer? (Select Three.)

A . The type of business the corporate customer is engaged in.
B . The employment profiles of all employees of the new customer.
C . All the financial institutions where the new customer currently banks or has banked previously.
D . The identity of senior managing officials and all individuals authorized to operate the account.
E . The country or location where the customer is from or conducts business.

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Question #273

An anti-money laundering specialist at a large institution is responsible for information senior management about the status of the anti-money laundering program across the organization.

Which report is the most useful?

A . The total credit exposure for non-cooperative countries and territories
B . Results of related audits and examinations
C . Details on inquires received from law enforcement
D . Notification of management changes in the different major divisions

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Question #274

Which key factor would result in the decision for a financial institution (FI) to exit a client relationship?

A . After assessing all risk factors the level of residual client risk exceeds the FI’s risk appetite.
B . The client is a registered charity known to remit funds to high risk geographies where there is limited due diligence information available.
C . Closing the client accounts will help reduce the number of transaction monitoring alerts.
D . Client transactions generate ongoing transaction monitoring alerts that did not result in any
SAR/STR filings.

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Richtige Antwort: A
A

Explanation:

The key factor that would result in the decision for a financial institution (FI) to exit a client relationship is when the level of residual client risk exceeds the FI’s risk appetite. Residual client risk is the remaining risk after applying the FI’s risk mitigation measures, such as customer due diligence, transaction monitoring, and suspicious activity reporting. Risk appetite is the level and type of risk that the FI is willing and able to accept in pursuit of its business objectives. If the residual client risk is higher than the risk appetite, the FI may decide to terminate the relationship to avoid potential regulatory, reputational, or operational consequences.

The other options are not necessarily key factors for exiting a client relationship, because:

The client is a registered charity known to remit funds to high risk geographies where there is limited due diligence information available. This option may indicate a higher level of inherent client risk, but it does not necessarily mean that the FI should exit the relationship. The FI may be able to apply enhanced due diligence, ongoing monitoring, and risk-based controls to mitigate the risk and comply with the regulatory requirements. The FI may also consider the nature and purpose of the client’s activities, the source and destination of the funds, and the potential impact on the client’s beneficiaries.

Closing the client accounts will help reduce the number of transaction monitoring alerts. This option may suggest a possible benefit of exiting the relationship, but it is not a key factor for making the decision. The FI should not base its decision solely on the volume of transaction monitoring alerts, but rather on the quality and relevance of the alerts, the results of the investigation, and the risk assessment of the client. The FI should also ensure that its transaction monitoring system is properly calibrated and validated to avoid generating excessive or false alerts.

Client transactions generate ongoing transaction monitoring alerts that did not result in any SAR/STR filings. This option may indicate a need for reviewing and improving the transaction monitoring system or the investigation process, but it does not necessarily imply that the FI should exit the relationship. The FI should not assume that the absence of SAR/STR filings means that the client is low risk or that the alerts are irrelevant. The FI should conduct a thorough and timely investigation of the alerts and document the rationale for filing or not filing a SAR/STR. The FI should also consider the overall risk profile of the client and the nature and frequency of the transactions.

Reference: ACAMS Study Guide for the CAMS Certification Examination – 6th Edition, Chapter 3: AML Programs, Section 3.2: AML Program Components, Subsection 3.2.2: Risk Assessment, pp. 77-79 FFIEC BSA/AML Examination Manual, Section: Assessing Compliance with BSA Regulatory Requirements, Subsection: Suspicious Activity Reporting, pp. 4-5 Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations, Question 2, pp. 2-3

Question #275

Which step should financial institutions take when complying with sanctions requirements?

A . Adopt automatic screening systems to detect designated persons and entities.
B . Conduct enhanced due diligence for prohibited entities on the sanctions list.
C . Change the risk profile to "high-risk" if an existing customer becomes a sanctioned entity and continue monitoring further transactions.
D . Freeze the funds or assets of designated persons and entities once this decision is approved by the Board.

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Richtige Antwort: D
D

Explanation:

The financial institution should freeze the funds or assets of designated persons and entities once this decision is approved by the Board. This is to comply with the obligation to implement targeted financial sanctions imposed by the United Nations Security Council (UNSC) or other relevant authorities. Freezing means preventing any access, use, transfer, or disposal of the funds or assets by the designated persons and entities or by any other person on their behalf. The financial institution should also report the freezing action to the competent authority and the relevant sanctions committee12.

Option A is not a sufficient step to comply with sanctions requirements, but rather a tool to facilitate compliance. Adopting automatic screening systems to detect designated persons and entities can help the financial institution to identify potential matches and flag them for further investigation.

However, screening systems are not infallible and may generate false positives or false negatives. Therefore, the financial institution should also conduct manual checks and verification of the screening results13.

Option B is not a relevant step to comply with sanctions requirements, but rather a measure to mitigate money laundering and terrorist financing risks. Conducting enhanced due diligence for prohibited entities on the sanctions list may be useful to obtain more information about the nature and purpose of the business relationship, the source and destination of the funds, and the beneficial ownership and control structure of the entity. However, enhanced due diligence does not replace the obligation to freeze the funds or assets of the designated persons and entities14.

Option C is not an appropriate step to comply with sanctions requirements, but rather a violation of the obligation to freeze the funds or assets of the designated persons and entities. Changing the risk profile to “high-risk” if an existing customer becomes a sanctioned entity and continuing to monitor further transactions may expose the financial institution to legal and reputational risks, as well as potential sanctions evasion or circumvention. The financial institution should terminate the business relationship with the designated person or entity and freeze their funds or assets without delay1.

Reference: 1: ACAMS (2020), Study Guide for the Certification Examination, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams-certification-package-6th-edition, pp. 47-49. 2: ACAMS (2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams-certification-package-6th-edition, Module 2, Section 2.4.1. 3: ACAMS (2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams-certification-package-6th-edition, Module 2, Section 2.4.2. 4: ACAMS (2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams-certification-package-6th-edition, Module 2, Section 2.4.3.: ACAMS

(2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams-certification-package-6th-edition, Module 2, Section 2.4.4.

Question #276

The Wolfsberg Group has issued a number of documents since its inception aiming to:

A . provide a standardized process amongst its bank members for combatting money laundering and terrorist financing in private banking.
B . prevent money laundering or terrorist financing by establishing consistent regulatory standards across the EU.
C . provide advice to regulators around the world on the due diligence requirements for politically exposed persons.
D . provide financial institutions with an industry perspective on effective financial crime risk management.

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Question #277

According to the Financial Action Task Force (FATF) methodology, which situations would require a financial institution (FI) to consider filing a Suspicious Activity Report (SAR)?

A . A FI is unable to verify the relevant customer due diligence (CDD) documents.
B . A beneficiary of a transaction is a politically exposed person (PEP).
C . A FI identifies the payer as a dealer in precious metals or stones.
D . A transaction involves funds exchanged from crypto to fiat currencies.

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Question #278

What is the appropriate compliance control for identifying politically exposed persons (PEPs) according to the Basel Committee’s paper on Customer Due Diligence for Banks?

A . Determining that a local figure is a PEP
B . Reviewing when a relationship is established
C . Reviewing relationships at account opening and on a periodic basis
D . Requiring that the customer discloses that they are a PEP or an associate of a PEP

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Question #279

The bank’s internal financial intelligence unit (FIU) has reviewed activity related to a politically exposed person (PEP); the activity in the account contains a large, round number, one time wire to an obscure organization.

Which would not be a sufficient reason to file a SAR/STR?

A . Beneficiary is largely unknown
B . Maintain the bank’s reputation
C . Wire is a large amount
D . Customer activity is unreasonable

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Question #280

What is true regarding disclosure to a law enforcement agency by a financial institution of the supporting documentation for a suspicious transaction report?

A . Documentation must be provided as quickly as possible using email
B . The financial institution may notify the account holder of the request
C . Confirm that the request originated from a representative of the law enforcement agency
D . A copy of all the documentation released must also be provided to the account holder’s attorney

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