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ACAMS Certified Anti-Money Laundering Specialists (the 6th edition) Sample Questions (Q173-Q178):
NEW QUESTION # 173
Financial Intelligence Units (FIUs) are responsible for:
- A. receiving confirmed reports about committed crimes from accountable and reporting institutions.
- B. the timely dissemination of cases to law enforcement agencies.
- C. sharing evidence with other FIUs.
- D. responding to requests from law enforcement agencies for information contained in regulatory reports.
Answer: B
Explanation:
Financial Intelligence Units (FIUs) are national agencies that collect, analyze, and disseminate information on suspicious or unusual financial activity, such as money laundering and terrorist financing, to relevant authorities. One of their main functions is to disseminate the results of their analysis to law enforcement agencies in a timely manner, so that they can initiate investigations or prosecutions. This is also one of the standards set by the Financial Action Task Force (FATF), the global body that sets the anti-money laundering and counter-terrorist financing (AML/CFT) policies and recommendations. The other options are not the primary responsibilities of FIUs, although they may perform them as part of their mandate or in cooperation with other agencies.
References:
* What are Financial Intelligence Units (FIUs)? | Dow Jones
* Financial Intelligence Units: An Overview - IMF
* Financial Intelligence Units - Egmont Group
* FATF Recommendation 29 - Financial Intelligence Units (page 17)
Reference: https://knowledgehub.transparency.org/assets/uploads/helpdesk/Financial-Intelligence- Units_Design-Mandate-Powers_2019_PR.pdf
NEW QUESTION # 174
What does the Financial Action Task Force (FATF) urge its members and all other jurisdictions to do when a jurisdiction is identified as having lax anti-money laundering / counter financing of terrorism controls?
- A. Apply economic sanctions until otherwise notified by FATF
- B. Consider customers from that jurisdiction as high risk
- C. Apply counter-measures to that jurisdiction
- D. Cease doing business with that jurisdiction immediately
Answer: C
Explanation:
The FATF is an inter-governmental body that sets standards and promotes effective implementation of legal, regulatory and operational measures to combat money laundering, terrorist financing and other related threats to the integrity of the international financial system1. The FATF identifies jurisdictions with serious strategic deficiencies in their anti-money laundering / counter financing of terrorism (AML/CFT) regimes and issues public statements to warn the international community of the risks emanating from these jurisdictions2. These jurisdictions are also known as high-risk jurisdictions subject to a call for action, or the "black list" in external sources2. The FATF urges its members and all other jurisdictions to apply counter-measures to protect themselves from the money laundering and terrorist financing risks posed by these jurisdictions2. Counter-measures are enhanced due diligence or restrictive measures that go beyond the normal AML/CFT requirements, such as requiring additional information or documentation, rejecting transactions, restricting business relationships, or terminating correspondent banking relationships3. The FATF also provides guidance on the types and levels of counter-measures that may be appropriate, depending on the specific risks and circumstances of each jurisdiction3.
Reference:
1: What is the FATF? | FATF
2: High-Risk Jurisdictions subject to a Call for Action | FATF
3: Guidance on Counter Proliferation Financing - The Implementation of Financial Provisions of United Nations Security Council Resolutions to Counter the Proliferation of Weapons of Mass Destruction | FATF
NEW QUESTION # 175
Which is most relevant when examining transactions suspected of being associated with money laundering via real estate?
- A. The currency used for payment
- B. The beneficial owner of the asset
- C. The financial institutions involved in the transaction
- D. The asset's location
Answer: B
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 # 176
Bank A is located in Country A. A wire transfer from Bank B located in Country B is processes by Bank A,where the funds are being moved to a customer at Bank C located in Country C. The wire transfer isdeemed suspicious by Bank A.
- A. The transaction in Country A.
- B. Bank B in Country A.
- C. Bank C in Country C.
- D. The transaction in Country B.
Answer: A
Explanation:
According to the BSA/AML Manual1, a financial institution is required to file a SAR for any transaction conducted or attempted by, at, or through the institution that involves or aggregates at least $5,000 in funds or other assets, and the institution knows, suspects, or has reason to suspect that the transaction (or a pattern of transactions of which the transaction is a part): (a) involves funds derived from illegal activity or is intended or conducted in order to hide or disguise funds or assets derived from illegal activity; (b) is designed to evade any requirements of the BSA or its implementing regulations; has no business or apparent lawful purpose or is not the sort in which the particular customer would normally be expected to engage, and the institution knows of no reasonable explanation for the transaction after examining the available facts, including the background and possible purpose of the transaction; or (d) involves use of the institution to facilitate criminal activity. In this case, Bank A is the institution that processes the wire transfer and deems it suspicious, based on its own assessment of the transaction and the customer. Therefore, Bank A is responsible for filing a SAR for the transaction in Country A, where it is located and where the transaction takes place. Bank A does not need to file a SAR for the transaction in Country B or Country C, as it does not have jurisdiction or authority over those countries or the other banks involved. However, Bank A may share information about the suspicious transaction with Bank B or Bank C, subject to certain conditions and limitations, as described in the BSA/AML Manual1.
References:
BSA/AML Manual1
Suspicious Activity Reporting - Overview2
Suspicious Activity Report (SAR) Basics3
From Microsoft Start Partners
Another simpler way of looking at the problem is by seeing this case as a Correspondent Banking relationship:
-A is the primary correspondent bank.
-B is the respondent bank.
-C is the receiving bank (of the wire transfer).
Since A is conducting the transaction on behalf of B's customer via the correspondent relationship deemed suspicious, it is the transaction in Country A by the correspondent bank that files the STR. Also, per the regular process, it is on the transaction, not the bank, that the STR is filed against.
NEW QUESTION # 177
A high-volume dealer of precious metals and stones in a high-risk jurisdiction is approached by a new customer interested in selling gold worth $200,000. The customer was referred by a longtime family friend of the dealer and provides no indication ofbackground or business purpose for the sale. The dealer agrees to make the purchase based solely on the reference.
What is the money laundering red flag?
- A. A new customer is selling gold worth $200,000 to a high volume dealer
- B. The precious metals dealer is operating in a high-risk jurisdiction
- C. The customer provides no background information or business purpose for the transaction
- D. The customer was referred by a longtime friend of the dealer
Answer: C
Explanation:
This is when a customer or a transaction does not provide sufficient or credible information about their identity, source of funds, business activity, or purpose of the transaction. Lack of transparency can indicate that the customer or the transaction is trying to conceal the origin, ownership, or destination of illicit funds, or to evade regulatory scrutiny or reporting obligations. Lack of transparency is a common risk factor for money laundering and terrorist financing, especially in high-risk jurisdictions or sectors.
The other options are not necessarily red flags, although they may increase the risk or require further due diligence depending on the circumstances and the risk profile of the customers and countries involved. Option A describes a referral by a longtime friend of the dealer, which may be a legitimate source of trust or business relationship, but it does not substitute the need for proper customer identification and verification. Option B describes the location of the precious metals dealer, which may be a high-risk jurisdiction due to factors such as weak governance, corruption, crime, or sanctions, but it does not imply that the dealer or the customer is involved in money laundering. Option C describes the amount and nature of the transaction, which may be unusual or large, but it does not necessarily indicate money laundering, as long as the customer can provide a reasonable explanation and evidence for the source and use of funds.
:
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 3, pages 64-65: https://www.acams.org/wp-content/uploads/2019/09/ACAMS-CAMS-Study-Guide-6th-Edition-Chapter-3.
pdf
NEW QUESTION # 178
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