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ACAMS Certified Anti-Money Laundering Specialists Sample Questions (Q552-Q557):
NEW QUESTION # 552
Law enforcement is confidentially investigating 20 individuals suspected of belonging to a criminal network allegedly involved in laundering tens of millions of euros for cybercriminals. Which actions need to be taken by the AML Specialist at a bank upon learning the alert? (Select Two.)
- A. Respond to law enforcement that their request without a judicial order would breach the bank's General Data Protection Regulation duty with respect to its clients.
- B. Perform a search on the bank's client data platform to determine if the bank has had any business with the named individuals.
- C. Report findings back to law enforcement only if they are of any significance.
- D. Involve the bank's legal and compliance function to address the gravity of the matter.
- E. N Send out an email to all of the bank's client advisors to request information on any of the individuals.
Answer: B,D
Explanation:
According to the ACAMS CAMS Study Guide, 6th Edition, Chapter 4, Section 4.2, the AML Specialist at a bank should take the following actions upon receiving a confidential alert from law enforcement about suspected money launderers:
Involve the bank's legal and compliance function to address the gravity of the matter and ensure that the bank's response is appropriate and lawful. The legal and compliance function can also advise on the bank's obligations and rights under the relevant laws and regulations, such as the General Data Protection Regulation (GDPR), the Bank Secrecy Act (BSA), and the USA PATRIOT Act.
Perform a search on the bank's client data platform to determine if the bank has had any business with the named individuals or any related parties. The search should include current and past accounts, transactions, wire transfers, and other relevant records. The AML Specialist should also review any existing customer due diligence (CDD) and enhanced due diligence (EDD) information on the potential suspects and update them as necessary.
The other options are not recommended or required actions for the AML Specialist at a bank in this scenario:
Sending out an email to all of the bank's client advisors to request information on any of the individuals could compromise the confidentiality of the alert and expose the bank to legal and reputational risks. It could also alert the suspects or their associates and hinder the law enforcement investigation.
Reporting findings back to law enforcement only if they are of any significance is not sufficient or compliant with the bank's obligations to cooperate with law enforcement and report any suspicious activity. The AML Specialist should report any relevant information or findings to law enforcement as soon as possible, regardless of their significance, and follow the established procedures and protocols for information sharing and reporting.
Responding to law enforcement that their request without a judicial order would breach the bank's GDPR duty with respect to its clients is not accurate or helpful. The GDPR does not prohibit the bank from sharing personal data with law enforcement for the purposes of preventing, detecting, or investigating money laundering or other criminal activities, as long as the bank has a legal basis and safeguards for doing so. The bank should consult with its legal and compliance function to determine the best way to respond to the law enforcement request and balance its GDPR obligations with its anti-money laundering (AML) duties.
Reference:
ACAMS CAMS Study Guide, 6th Edition, Chapter 4, Section 4.2
General Data Protection Regulation (GDPR)
Bank Secrecy Act (BSA)
USA PATRIOT Act
NEW QUESTION # 553
The ultimate goal of economic sanctions is to:
- A. reduce the profits of sanctioned countries.
- B. protect national security.
- C. prevent terrorists from profiting from trade.
- D. protect the reputation of the country.
Answer: B
Explanation:
Economic sanctions are penalties imposed by one or more countries against another country, group, or individual for violatinginternational norms or threatening national interests1. The ultimate goal of economic sanctions is to protect national security by changing the behavior or policies of the target, or by weakening its capabilities or resources2. Sanctions can be used to advance various foreignpolicy objectives, such as counterterrorism, nonproliferation, democracy promotion, human rights protection, conflict resolution, and cybersecurity1. Sanctions can take different forms, such as travel bans, asset freezes, trade embargoes, arms restrictions, and aid reductions1. Sanctions can be applied unilaterally by one country, or multilaterally by a coalition of countries or an international organization, such as the United Nations or the European Union1.
1: What Are Economic Sanctions? | Council on Foreign Relatio
2: How Economic Sanctions Work - Investopedia
Reference: https://www.investopedia.com/articles/economics/10/economic-sanctions.asp
NEW QUESTION # 554
A junior account manager within an international private bank in Country A was asked by one of his valued customers, who has held an account for several years in the institution, about depositing a large sum of cash into her account. The junior account manager informed his customer that his bank does not accept cash. The junior account manager later reviewed a customer activity report and noticed a number of smaller dollar wires from banks in neighboring Country B, which has lax currency controls, that totaled about as much as the customer intended to deposit.
What should the junior account manager do?
- A. File a suspicious transaction report with the Financial Intelligence Unit
- B. Close the account
- C. Offer the customer a more secure method of depositing in the hope of learning something more during the conversation
- D. Notify the anti-money laundering specialist of his bank, but do not call the customer
Answer: A
Explanation:
The junior account manager should file a suspicious transaction report (STR) with the Financial Intelligence Unit (FIU) of Country A, as he has reasonable grounds to suspect that the customer is involved in money laundering or terrorist financing. The customer's attempt to deposit a large sum of cash, followed by a series of smaller wire transfers from a high-risk jurisdiction, indicates a possible case of structuring or smurfing, which are techniques used by criminals to avoid detection and reporting thresholds. The junior account manager should not close the account, as this could alert the customer and disrupt the investigation by the FIU or law enforcement. The junior account manager should also not notify the anti-money laundering specialist of his bank, as this could create a conflict of interest or breach of confidentiality, unless the bank's policy requires such notification. The junior account manager should also not offer the customer a more secure method of depositing, as this could be seen as facilitating or condoning the customer's illicit activities, or exposing the bank to legal or reputational risks.
:
CAMS Study Guide, pages 97-98, 103-104, 107-108.
CAMS Exam Questions and Free Practice Test, Question 272.
NEW QUESTION # 555
A local law enforcement officer, who is conducting a criminal investigation, requests information about a customer.
Which two actions should the bank take? (Choose two.)
- A. File a suspicious transaction report
- B. Review the money laundering risk posed by the account
- C. Close the account immediately
- D. Monitor the account for suspicious activity
Answer: A,D
Explanation:
According to the Anti-Money Laundering Specialist (the 6th edition) study guide, when a financial institution receives a law enforcement inquiry, it should cooperate as much as possible and respond to all formal requests for information, unless there is a valid objection that can and should be made1. The institution should also file a suspicious transaction report (STR) if the inquiry or the customer's activity triggers any red flags or indicators of money laundering or other financial crimes2. Additionally, the institution should monitor the account for suspicious activity and review the money laundering risk posed by the account, as these are part of the ongoing due diligence and risk assessment processes3. Closing the account immediately is not a recommended action, as it may alert the customer or interfere with the investigation4.
1: ACAMS, CAMS Certification Package - 6th Edition, Chapter 4, page 121
2: ACAMS, CAMS Certification Package - 6th Edition, Chapter 4, page 122
3: ACAMS, CAMS Certification Package - 6th Edition, Chapter 4, page 123
4: ACAMS, CAMS Certification Package - 6th Edition, Chapter 4, page 124
NEW QUESTION # 556
What are the roles of a government Financial Intelligence Unit (FIU)? (Select Three.)
- A. Investigate and, where appropriate, prosecute all suspicious transaction and suspicious activity reports received from reporting institutions or obliged institutions.
- B. Disseminate analysis of suspicious transaction and suspicious activity reports to foreign judicial systems to enhance their anti-money laundering and terrorist financing investigations and prosecutions.
- C. Disseminate the analysis of suspicious transaction and suspicious activity reports to local law enforcement agencies and foreign FIUs to combat money laundering.
- D. Receive reports of suspicious transactions and suspicious activities from reporting institutions or obliged institutions.
- E. Analyze all suspicious transaction and suspicious activity reports received from reporting institutions or obliged institutions.
Answer: C,D,E
Explanation:
Financial Intelligence Units (FIUs) serve as national centers for collecting, analyzing, and disseminating AML/CFT information.
Option B (Correct): FIUs analyze SARs and STRs to detect money laundering and terrorist financing risks.
Option D (Correct): FIUs disseminate financial intelligence to local and international law enforcement agencies and other FIUs.
Option E (Correct): FIUs receive SARs/STRs from financial institutions, which form the basis for their analysis.
Why Other Options Are Incorrect:
Option A (Incorrect): FIUs do not prosecute cases; they refer findings to law enforcement agencies.
Option C (Incorrect): FIUs share intelligence, but prosecution is handled by judicial authorities, not FIUs.
Best Practices for FIUs:
Enhance data-sharing agreements with domestic and international agencies.
Use AI and analytics tools to detect suspicious financial patterns.
Ensure secure handling of sensitive AML/CFT data.
Reference:
FATF Recommendation 29 (FIU Role & Responsibilities)
Egmont Group Guidelines on FIU Information Sharing
EU 6th AML Directive (6AMLD) on Financial Intelligence Functions
NEW QUESTION # 557
......
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