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Question #311

What does designing a country as being of “prime money laundering concern” allow the U.S. government to do?

A . Obtain transactional information from U.S.-owned subsidiary banks located outside the U.S.
B . Close some or all correspondent or payable-through accounts
C . Ensure the inclusion of that country onto FATF’s Non-Cooperative Country and Territory list
D . Ensure the inclusion of that country into the office of Foreign Asset Control country sanctions programs

Question #312

A division anti-money laundering officer for a financial institution has been conducting a monthly self-assessment.

The officer reviews the accounts opened for compliance with a long standing Know Your Customer policy.

The self-assessment for the latest month shows a significant increase in compliance deficiencies for the first time in more than a year.

Which of the following is the next course of action for the anti-money laundering officer to take?

A . Inform the Board promptly of the Know Your Customer policy trend over the last 6 months.
B . Determine if there is a readily identifiable cause for the deficiencies.
C . Implement a revision to the account-opening training program.
D . Revise the policy to simplify Know Your Customer compliance before the report is issued.

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Question #313

After review of the financial institution’s enterprise-wide anti-money laundering risk assessment, the new compliance officer identifies several deficiencies that need attention.

Which deficiency could lead to the highest potential for unmitigated risk?

A . The risk assessment is several years old and does not cover all current products and services.
B . The risk assessment is revisited too frequently thereby diverting critical resources from other compliance tasks.
C . The risk assessment is managed by a different team from the previous assessment therefore disrupting continuity of institutional knowledge.
D . The risk assessment does not anticipate potential risks even though the financial institution has no immediate plans involving those risks.

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Question #314

Which situation would require enhanced due diligence be performed on a customer?

A . A customer closes their store location and opens a new store location across town.
B . A prospective customer recently started and incorporated a new business.
C . Company ownership is held in bearer share form.
D . The low-risk rating for a customer has not changed since the relationship was established 5 years ago.

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Question #315

A foreign bank maintains a correspondent account in the US. According to an investigation carried out by US authorities, the specific correspondent account seems to have facilitated a transaction involving tainted funds.

Which allows the US authorities to seize the funds of the foreign bank held with the US bank?

A . The Financial Crimes Enforcement Network Customer Due Diligence Final Rule
B . The 6th EU AML Directive
C . Regulations of the Office of Foreign Assets Control, US Department of Treasury
D . The USA PATRIOT Act

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Question #316

Respondent’s location, in particular the existence of a real physical presence.

A . 1, 2, and 3 only
B . 1, 2, and 4 only
C . 1, 3, and 4 only
D . 2, 3, and 4 only

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Richtige Antwort: C
C

Explanation:

These are the information that can help the correspondent bank to assess the risk profile, the regulatory compliance, and the operational capacity of the respondent bank, and to verify its identity and legitimacy. The correspondent bank should obtain and verify the following information about the respondent bank:

Respondent’s management, nature of license, and major business activity. This can help the correspondent bank to understand the governance, the legal status, and the core functions of the respondent bank, and to evaluate its reputation, integrity, and competence.

The quality of supervision in the home country. This can help the correspondent bank to determine the level of oversight and regulation that the respondent bank is subject to, and to identify any potential gaps or weaknesses in the anti-money laundering and counter-terrorist financing (AML/CTF) framework of the home country.

Respondent’s location, in particular the existence of a real physical presence. This can help the correspondent bank to verify the actual existence and operation of the respondent bank, and to avoid dealing with shell banks or banks located in high-risk or non-cooperative jurisdictions.

The other option is not necessarily information that should be included to establish a rigorous “Know Your Respondent” procedure, although it may have some relevance or importance depending on the circumstances and the nature of the correspondent relationship.

Option 2 describes computer equipment and software capability, which may be useful to assess the technical and operational compatibility and efficiency of the respondent bank, but it is not essential to evaluate its risk or compliance level.

Reference: ACAMS CAMS Certification Video Training Course – 6th Edition1

Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)2 ACAMS CAMS Study Guide – 6th Edition, Chapter 7, pages 154-155

: https://www.acams.org/wp-content/uploads/2019/09/ACAMS-CAMS-Study-Guide-6th-Edition-Chapter-7.pdf

Question #316

Respondent’s location, in particular the existence of a real physical presence.

A . 1, 2, and 3 only
B . 1, 2, and 4 only
C . 1, 3, and 4 only
D . 2, 3, and 4 only

Lösung einblenden Lösung ausblenden

Richtige Antwort: C
C

Explanation:

These are the information that can help the correspondent bank to assess the risk profile, the regulatory compliance, and the operational capacity of the respondent bank, and to verify its identity and legitimacy. The correspondent bank should obtain and verify the following information about the respondent bank:

Respondent’s management, nature of license, and major business activity. This can help the correspondent bank to understand the governance, the legal status, and the core functions of the respondent bank, and to evaluate its reputation, integrity, and competence.

The quality of supervision in the home country. This can help the correspondent bank to determine the level of oversight and regulation that the respondent bank is subject to, and to identify any potential gaps or weaknesses in the anti-money laundering and counter-terrorist financing (AML/CTF) framework of the home country.

Respondent’s location, in particular the existence of a real physical presence. This can help the correspondent bank to verify the actual existence and operation of the respondent bank, and to avoid dealing with shell banks or banks located in high-risk or non-cooperative jurisdictions.

The other option is not necessarily information that should be included to establish a rigorous “Know Your Respondent” procedure, although it may have some relevance or importance depending on the circumstances and the nature of the correspondent relationship.

Option 2 describes computer equipment and software capability, which may be useful to assess the technical and operational compatibility and efficiency of the respondent bank, but it is not essential to evaluate its risk or compliance level.

Reference: ACAMS CAMS Certification Video Training Course – 6th Edition1

Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)2 ACAMS CAMS Study Guide – 6th Edition, Chapter 7, pages 154-155

: https://www.acams.org/wp-content/uploads/2019/09/ACAMS-CAMS-Study-Guide-6th-Edition-Chapter-7.pdf

Question #316

Respondent’s location, in particular the existence of a real physical presence.

A . 1, 2, and 3 only
B . 1, 2, and 4 only
C . 1, 3, and 4 only
D . 2, 3, and 4 only

Lösung einblenden Lösung ausblenden

Richtige Antwort: C
C

Explanation:

These are the information that can help the correspondent bank to assess the risk profile, the regulatory compliance, and the operational capacity of the respondent bank, and to verify its identity and legitimacy. The correspondent bank should obtain and verify the following information about the respondent bank:

Respondent’s management, nature of license, and major business activity. This can help the correspondent bank to understand the governance, the legal status, and the core functions of the respondent bank, and to evaluate its reputation, integrity, and competence.

The quality of supervision in the home country. This can help the correspondent bank to determine the level of oversight and regulation that the respondent bank is subject to, and to identify any potential gaps or weaknesses in the anti-money laundering and counter-terrorist financing (AML/CTF) framework of the home country.

Respondent’s location, in particular the existence of a real physical presence. This can help the correspondent bank to verify the actual existence and operation of the respondent bank, and to avoid dealing with shell banks or banks located in high-risk or non-cooperative jurisdictions.

The other option is not necessarily information that should be included to establish a rigorous “Know Your Respondent” procedure, although it may have some relevance or importance depending on the circumstances and the nature of the correspondent relationship.

Option 2 describes computer equipment and software capability, which may be useful to assess the technical and operational compatibility and efficiency of the respondent bank, but it is not essential to evaluate its risk or compliance level.

Reference: ACAMS CAMS Certification Video Training Course – 6th Edition1

Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)2 ACAMS CAMS Study Guide – 6th Edition, Chapter 7, pages 154-155

: https://www.acams.org/wp-content/uploads/2019/09/ACAMS-CAMS-Study-Guide-6th-Edition-Chapter-7.pdf

Question #319

What should countries do to help prevent non-profit organizations from being abused for the financing of terrorism according to the Financial Action Task Force 40 Recommendations?

A . Allow for freezing assets of non-profit organizations
B . Require all non-profit organizations to register with the country’s financial intelligence unit
C . Ensure non-profit organizations cannot be used to conceal or obscure the diversion of funds intended for legitimate purposes to terrorists’ organizations
D . Create laws that forbid non-profit organizations from completing cross-border transactions without first
running them through known terrorist data bases

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Question #320

An account officer who maintains an excellent relationship with the finance manager for a correspondent bank customer learns that many records for the correspondent bank have been requested by law enforcement. In the interest of maintaining a good relationship with the customer, the account officer sets up a meeting to discuss the legal request with the customer. The account officer intends to discuss points related to the investigation during the meeting.

What should an anti-money laundering specialist recommend?

A . Discuss all the points being investigated by law enforcement to ensure the correspondent bank is well prepared when approached
B . Let the account manager’s manager know what conversations have taken place with the customer and document the account file accordingly
C . Limit discussions about the investigation with the customer and by satisfied that the account manager has provided proper notice to the customer
D . Cancelled the meeting as he has already behaved inappropriately by alerting to the investigation

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