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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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Question #322

A bank located in Arizona is considering a loan application for a new client. The collateral for the loan is a property in Florida.

The loan will be in the name of a limited company (LLC) whose ownership is not disclosed to the bank. The LLC was established by a New York-based attorney.

The loan will be repaid by the LLC in monthly wire transfers of $9,000 which is more than the required monthly payment.

Which aspect indicates potential for money laundering?

A . The LLC’s ownership is not disclosed to the bank
B . The collateral, a property in Florida, is not located in Arizona
C . The repayment in the amount of $9,000 indicates potential structuring
D . The attorney associated with the account is outside the bank’s lending area

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Question #323

Which three entities does the Third European Union Money Laundering Directive apply to?

A . Financial Institutions
B . Defense Attorneys
C . Casinos
D . Real Estate Agents

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Richtige Antwort: ACD
ACD

Explanation:

The Third European Union Money Laundering Directive (3MLD) is a legal framework that aims to prevent the use of the financial system for the purposes of money laundering and terrorist financing. It was adopted in 2005 and repealed by the Fourth European Union Money Laundering Directive (4MLD) in 2015. The 3MLD applies to a range of entities that are considered to be exposed to the risk of money laundering and terrorist financing, such as:

Financial institutions, which include credit institutions, financial intermediaries, insurance companies, investment firms, and payment service providers.

Casinos, which include both online and offline gambling services that involve wagering a stake with monetary value.

Real estate agents, which include both natural and legal persons that act as intermediaries in the buying and selling of real property or rights over it.

The 3MLD requires these entities to implement a number of measures to prevent and detect money laundering and terrorist financing, such as:

Conducting customer due diligence, which involves identifying and verifying the customer and the beneficial owner, understanding the purpose and nature of the business relationship, and applying enhanced or simplified measures depending on the level of risk.

Keeping records of customer and transaction data for at least five years after the end of the business relationship or the execution of the transaction.

Reporting suspicious transactions or activities to the competent authorities without delay and without tipping off the customer.

Establishing internal policies, procedures, and controls to ensure compliance with the 3MLD, and providing adequate training and awareness to staff.

Cooperating with the relevant supervisory and regulatory authorities and financial intelligence units. The 3MLD does not apply to defense attorneys, as they are not considered to be obliged entities under the directive. However, the 3MLD does apply to other legal professionals, such as notaries, lawyers, and accountants, when they perform certain activities on behalf of their clients, such as: Buying and selling of real property or business entities Managing of client money, securities, or other assets Opening or managing bank, savings, or securities accounts Organizing contributions for the creation, operation, or management of companies Creating, operating, or managing trusts, companies, foundations, or similar structures

Reference: THE THIRD EU DIRECTIVE ON MONEY LAUNDERING AND TERRORIST FINANCING, page 11-12

Anti-money laundering and countering the financing of terrorism legislative package, page 1

CAMS Study Guide – 6th Edition, Chapter 1, Section 1.2, page 11

Question #324

Which constitute red flags in connection with a company involved in illegal logging? (Select Three.)

A . Business registry activities state promotion of environmental protection
B . High number of transactions through company’s connected bank accounts
C . Paper packaging demand production
D . Expeditious shipment of wood to far away jurisdictions
E . Use of heavy machinery in non-protected areas
F . Executive’s association with politically exposed persons

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Question #325

When an institution files an STR with regard to a particular account, what steps should the institution take visa account?

A . The institution should close the account due to the obvious risk it represents
B . The institution should keep the account open due to the need to continue to monitor the account
C . The institution should consult its counsel and AML compliance officer and determine whether closing the account is in accord with the institution’s procedures
D . The institution should not close the account due to the risk of tipping off the customer and upsetting the criminal investigation

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Question #326

Which factors should lead to a reassessment of the current AML program? (Select Two.)

A . Expansion of business to new territories
B . Appointment of a new Chief Financial Officer
C . Change of company name
D . Change of internal audit team members
E . New product offering

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Richtige Antwort: A E
A E

Explanation:

According to the ACAMS CAMS Study Guide, 6th Edition, Chapter 2, Section 2.1, the AML program should be reassessed periodically or when there are significant changes in the business environment, such as:

Expansion of business to new territories: This could expose the business to new risks, regulations, and customers that require different AML policies, procedures, and controls. The AML program should be updated to reflect the new jurisdictions and their AML requirements, as well as to conduct appropriate risk assessments and due diligence on the new markets and customers.

New product offering: This could introduce new vulnerabilities, opportunities, and challenges for the AML program. The AML program should be revised to incorporate the new product features, benefits, and risks, as well as to ensure compliance with any applicable AML rules and standards for the new product.

The other options are not factors that would necessarily lead to a reassessment of the current AML program, unless they have a material impact on the AML risks, objectives, or performance of the business:

Appointment of a new Chief Financial Officer: This could affect the AML program if the new CFO has a different vision, strategy, or approach to AML than the previous one, or if the new CFO has a significant role or responsibility in the AML program. However, the appointment of a new CFO alone does not trigger a reassessment of the AML program, unless there are other changes or issues that warrant a review.

Change of company name: This could affect the AML program if the change of name reflects a change of ownership, structure, or nature of the business that could alter the AML risks, obligations, or expectations. However, the change of name alone does not necessitate a reassessment of the AML program, unless there are other implications or consequences that affect the AML program. Change of internal audit team members: This could affect the AML program if the new internal audit team members have different qualifications, skills, or experiences than the previous ones, or if the new internal audit team members have a different scope, methodology, or frequency of auditing the AML program. However, the change of internal audit team members alone does not require a reassessment of the AML program, unless there are other factors or findings that indicate a need for a review.

Reference: ACAMS CAMS Study Guide, 6th Edition, Chapter 2, Section 2.1 ACAMS CAMS Certification Video Training Course – Exam-Labs

Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)

Question #327

According to Basel Committee guidelines, which level of the organization should determine whether or not to enter business relationships with higher risk customers?

A . First-level management
B . Senior management
C . Account opening staff
D . Middle management

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Question #328

A suspicious transaction report has been filed on an account owned by the wife of the bank’s Chief Executive Officer.

Which of the following is the most important consideration when deciding whether to recommend closing the account?

A . The institution’s anti-money laundering policy
B . Requests from the competent authority
C . Customer relations
D . Chief Executive’s reputational risk

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Question #329

After a FATF mutual evaluation process, which are resulting actions for jurisdictions that are determined to have strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing? (Choose two.)

A . Expect private statements from FATF regarding the level of compliance of the jurisdiction, when insufficient progress is made.
B . Appeal to FATF for a technical compliance re-rating based on the jurisdiction’s own experts criteria.
C . Demonstrate a high-level commitment to swiftly resolve the identified deficiencies in the FATF mutual evaluation report.
D . Request FATF for an extension of deadlines in order to provide local awareness on the improvements that are necessary to solve the deficiencies.
E . Report to FATF on the implementation of their progress under the enhanced follow-up mechanism.

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Richtige Antwort: C, E
C, E

Explanation:

According to the FATF Procedures for the Fourth Round of AML/CFT Mutual Evaluations1, jurisdictions that are determined to have strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing are subject to the FATF’s International Cooperation Review Group (ICRG) process. The ICRG process involves the following actions for such jurisdictions:

Demonstrate a high-level commitment to swiftly resolve the identified deficiencies in the FATF mutual evaluation report. This commitment should be made in writing to the FATF President and should include an action plan with specific deadlines and milestones to address the deficiencies. Report to FATF on the implementation of their progress under the enhanced follow-up mechanism. The FATF will monitor the progress of the jurisdiction through regular reports and on-site visits, and will decide whether the jurisdiction has made sufficient progress to exit the ICRG process or whether further actions are required, such as public statements, counter-measures, or suspension of membership.

The other options are not resulting actions for jurisdictions with strategic deficiencies, as they are either not part of the FATF procedures or not consistent with the FATF’s objectives and principles. For example, the FATF does not issue private statements regarding the level of compliance of a jurisdiction, nor does it allow a jurisdiction to appeal for a technical compliance re-rating based on its own criteria. The FATF also does not grant extensions of deadlines for jurisdictions to improve their regimes, as this would undermine the credibility and effectiveness of the mutual evaluation process.

Reference: 1: Mutual Evaluations – Financial Action Task Force

2: Procedures for the FATF Fourth Round of AML/CFT Mutual Evaluations

Reference: https://www.fatf-gafi.org/publications/high-risk-and-other-monitored-jurisdictions/documents/increased-monitoring-june-2021.html

Question #330

In addition to monitoring for suspicious activity, what are electronic monitoring systems also valuable for?

A . Identifying how customers are using products
B . Highlighting the skills of the system analysts
C . Proving to the Board of Directors that the FIU is doing its job
D . Meeting mandatory regulatory requirements for system implementation

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