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The Certified Anti-Money Laundering Specialist (CAMS) is a globally recognized certification exam that equips professionals with the skills and knowledge required to identify and prevent money laundering activities. Money laundering is a criminal activity that involves disguising the proceeds of illegal activities as legitimate funds. The CAMS certification is designed to help professionals in the financial services industry to combat this growing problem and to protect their organizations from financial risks.
NEW QUESTION # 245
In which two ways does a government Financial Intelligence Unit interact with public and private sectors?
(Choose two.)
- A. It receives and analyzes disclosures filed by financial and non-bank institutions
- B. It disseminates information and the results of its analysis to competent authorities
- C. It mediates disputes between financial institutions and investigative authorities
- D. It governs the methods of investigation used by competent authorities
Answer: A,B
NEW QUESTION # 246
When a government imposes economic sanctions on a target the purpose is to:
- A. interests encourage non-governmental organizations to increase the provision of humanitarian and charitable aid to the target
- B. alter the behavior of the state or non-state target that threatens the interests of that government or violates international norms
- C. indicate that the use of military force is likely unless the state or non-state target complies with the government's
- D. protect the rights of the citizens of the state target against their own government and improve financial stability in the region.
Answer: B
NEW QUESTION # 247
Which three conduits for moving terrorist-related funds do terrorist financing generally favor? Choose 3 answers
- A. Banks and/or other formal financial systems
- B. Cash couriers
- C. Informal financial systems
- D. Currency exchange firms
Answer: B,C,D
NEW QUESTION # 248
Based on the AML principles outlined by the Wolfsberg Group, what do private and correspondent banks have in common when monitoring for terrorist financing?
- A. Numbered or alternate name accounts will only be accepted if the bank has established the identity of the client and beneficial owner.
- B. Transaction monitoring examines the relationship between due diligence information and account closings.
- C. Account and transactional activity are monitored after the proper identification and verification of customers.
- D. Cash access from a pre-paid card increases the potential that the card will be used for money laundering purposes.
Answer: C
Explanation:
According to the Wolfsberg Group, a global association of leading banks that develops guidance and standards for the management of financial crime risks, both private and correspondent banks should monitor account and transactional activity after the proper identification and verification of customers, as part of their anti-money laundering and counter-terrorist financing (AML/CTF) measures12. This is consistent with the FATF Recommendation 10, which requires financial institutions to conduct ongoing due diligence on their business relationships, including scrutinising transactions to ensure that they are consistent with the customer's risk profile and source of funds3. Monitoring account and transactional activity is a key component of the risk-based approach, as it enables banks to detect and report suspicious or unusual transactions, identify changes in customer behaviour or circumstances, and update customer information and risk assessments accordingly4.
Reference:
1: Wolfsberg Anti-Money Laundering Principles for Private Banking (2012)
2: Wolfsberg Correspondent Banking Due Diligence Questionnaire (2017)
3: The FATF Recommendations - Financial Action Task Force
4: Risk-Based Approach for the Banking Sector - Financial Action Task Force
NEW QUESTION # 249
The Financial Intelligence Unit (FIU) in a country has received a suspicious activity report (SAR) which involves significant suspicious fund transfers, not only within its jurisdiction but also in a foreign country.
Further information is required from the foreign country to determine whether the matter needs to be referred for prosecution locally.
Which of the following statements is true in this scenario?
- A. Countries that are members of the Egmont Group can request assistance for information from each other
- B. It is against international laws on data protection to access information from foreign countries
- C. Any information related to money laundering can be received from any organization at any time regardless of jurisdiction
- D. Sovereignty of nations means that information cannot be accessed from foreign countries
Answer: A
Explanation:
Countries that are members of the Egmont Group can securely exchange information between their Financial Intelligence Units (FIUs) to support money laundering and terrorist financing investigations, even when the activity involves multiple jurisdictions.
NEW QUESTION # 250
One of the red flags of microstructuring is:
- A. single activity in an account immediately following the opening of the account.
- B. frequent visits to make cash deposits of nominal amounts.
- C. check deposits followed by ATM withdrawals using debt card in retail store.
- D. depositing sequentially numbered checks.
Answer: B
NEW QUESTION # 251
Which red flag should a compliance officer prioritize first for investigation?
- A. A customer has 20 monthly transactions that are repetitive but less than $500 USD per transaction.
- B. A convenience store cashes government checks for its customers in amounts less than $1,000 USD per day.
- C. A loan is paid off in full with cash after the sale of the vehicle that was used as collateral for the loan.
- D. Several cross-border transfers are received and immediately wired to another beneficiary.
Answer: D
Explanation:
This is a common red flag of money laundering that involves layering, which is the process of moving funds through multiple accounts or entities to conceal their origin and ownership. Layering often involves cross-border transfers, especially to high-risk jurisdictions, and rapid movement of funds to avoid detection or tracing. A compliance officer should prioritize this red flag for investigation, as it may indicate a complex money laundering scheme or the financing of terrorism or proliferation.
References:
AML Red Flags - What are the Top 10 Indicators? - ComplyAdvantage, section "Red flags related to transaction patterns" AML 101: The 10 Most Common Red Flags - KYC-Chain, section "Red flag indicators related to geographical risks" Anti-money laundering red flags, page 2, bullet point 5
NEW QUESTION # 252
What is the primary action a financial institution should take before formulating its anti-money laundering program?
- A. It should ensure that its training modules for all employees cover all relevant AML issues
- B. It should consult with its correspondent banks to determine the nature and extent of their AML programs
- C. It should determine how extensive and well-trained the compliance staff is
- D. It should perform a comprehensive risk analysis
Answer: D
Explanation:
A comprehensive risk analysis is the first and most important step in developing an effective anti-money laundering program. A risk analysis helps a financial institution identify and assess its exposure to money laundering and terrorist financing risks, based on its products, services, customers, geographic locations, and other factors. A risk analysis also enables a financial institution to tailor its policies, procedures, controls, and training to mitigate the specific risks it faces. A risk analysis should be conducted periodically and updated as necessary to reflect changes in the institution's risk profile.
References:
* ACAMS Study Guide for the CAMS Certification Examination, 6th Edition, Chapter 2: Compliance
* Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), Section 2.1: Risk-Based Approach, p. 29-30
* ACAMS Risk Assessment, What is Anti-Money Laundering (AML) Risk Assessment?
* How to Conduct an AML Risk Assessment - Assess Key Risk Drivers
NEW QUESTION # 253
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. The transaction in Country B.
- D. Bank C in Country C.
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 # 254
A relationship manager in a bank has had a private banking customer for 10 years. The customer has business accounts and investments and seeks advice on the creation of a company overseas. The relationship manager refers the customer to the commercial banking manager and vouches for the customer. Which of the following risk factors is the most important?
- A. The company wants to transfer funds in large, even amounts.
- B. The proposed offshore jurisdiction is known for its strong privacy laws limiting access to customer information by law enforcement.
- C. The customer does not want to provide more information than when the first account was opened.
- D. Entities that are to receive funds from this company are located in the same country.
Answer: B
Explanation:
The most important risk factor in this scenario is the proposed offshore jurisdiction that is known for its strong privacy laws limiting access to customer information by law enforcement. This indicates that the customer may be trying to evade tax, hide the source or destination of funds, or engage in other illicit activities that could expose the bank to money laundering or terrorist financing risks. Offshore jurisdictions are often used by criminals to create complex corporate structures that obscure the beneficial ownership and control of the entities involved. The bank should conduct enhanced due diligence on the customer, the offshore company, and the nature and purpose of the transactions.
Reference:
ACAMS CAMS Certification Study Guide, 6th Edition, Chapter 2, page 35-36, 38-39 ACAMS CAMS Certification Video Training Course, Module 2, Lesson 2.3, Offshore Financial Centers
1, CAMS Certification Package - 6th Edition | ACAMS, Offshore Financial Centers and Money Laundering
2, CAMS Certifications: How to Get CAMS Certified | ACAMS, CAMS Exam Outline, Domain 2, Task 2.3
NEW QUESTION # 255
Which type of sanctions are most likely to be used in order to avoid escalating violent conflicts and/or proliferation of weapons?
- A. Arms and related materials embargo
- B. Export and import restrictions
- C. Asset freeze
- D. Financial prohibitions
Answer: C
Explanation:
Reference: https://collections.unu.edu/eserv/UNU:6431/UNSanctionsandPreventionConflict-Aug-2017.pdf (3)
NEW QUESTION # 256
Which three are the most commonly used risk criteria?
- A. Product and Service Risk
- B. Customer Risk
- C. Country Risk
- D. Reputation Risk
Answer: A,B,C
Explanation:
According to the CAMS Study Guide, the most commonly used risk criteria for assessing the money laundering and terrorist financing risks are country risk, customer risk, and product and service risk. These criteria are based on the FATF Recommendations and the Basel Committee's guidance on sound management of risks related to money laundering and financing of terrorism.
Country risk refers to the level of exposure to potential money laundering and terrorist financing activities in a specific jurisdiction, based on factors such as the quality of its AML/CFT regime, its level of corruption, its political and economic stability, its involvement in illicit activities, and its cooperation with international bodies.
Customer risk refers to the level of exposure to potential money laundering and terrorist financing activities associated with a specific customer or customer segment, based on factors such as the nature and purpose of the business relationship, the source and destination of funds, the type and volume of transactions, the customer's profile and behavior, and the customer's geographic location.
Product and service risk refers to the level of exposure to potential money laundering and terrorist financing activities associated with a specific product or service offered by a financial institution, based on factors such as the complexity, transparency, anonymity, and accessibility of the product or service, the delivery channels and payment methods used, and the degree of oversight and monitoring applied.
Reputation risk is not a risk criterion for assessing the money laundering and terrorist financing risks, but rather a potential consequence of failing to manage those risks effectively. Reputation risk refers to the potential damage to the public trust and confidence in a financial institution due to its involvement or association with money laundering and terrorist financing activities, whether directly or indirectly.
CAMS Study Guide, 6th Edition, Chapter 2: Risk Assessments, pp. 41-461
FATF Recommendations, Recommendation 1: Assessing Risks and Applying a Risk-Based Approach2 Basel Committee on Banking Supervision, Sound management of risks related to money laundering and financing of terrorism, June 2017, pp. 9-143
NEW QUESTION # 257
A bank received a subpoena regarding one of its clients. The financial intelligence unit of the bank should review the subpoena and:
- A. perform a transaction review and respond fully to the subpoena.
- B. close the client's account by informing the client of the subpoena.
- C. adjust the client's risk score and close the case.
- D. file a suspicious activity report (SAR), including the receipt of the subpoena in the SAR narrative.
Answer: B
Explanation:
A subpoena is a legal order that requires a person or an entity to produce documents, information, or testimony related to a legal matter. A financial intelligence unit (FIU) is a specialized unit within a financial institution that is responsible for detecting, analyzing, and reporting suspicious activities and transactions.
When a bank receives a subpoena regarding one of its clients, the FIU should review the subpoena and perform a transaction review to determine if there is any evidence of money laundering, terrorist financing, fraud, or other criminal activity involving the client. The FIU should also respond fully to the subpoena by providing the requested information and documents, unless there is a valid reason to object or seek a protective order. The FIU should not adjust the client's risk score, file a SAR, or close the client's account based solely on the receipt of the subpoena, as these actions may be premature, inappropriate, or illegal.
Adjusting the client's risk score may require further investigation and due diligence. Filing a SAR may be unnecessary or misleading if the subpoena does not indicate any suspicious activity. Closing the client's account may violate the bank's contractual obligations, customer service standards, or anti-discrimination laws. Moreover, these actions may alert the client or the subject of the investigation to the existence of the subpoena, which may interfere with the legal process or jeopardize the safety of the bank or its employees.
References:
Subpoena Responses for Financial Institutions
Requests by Law Enforcement for Financial Institutions to Maintain Accounts SUBPOENA COMPLIANCE UPDATE
[ACAMS Study Guide, 6th Edition, Chapter 5, p. 140]
NEW QUESTION # 258
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. Offer the customer a more secure method of depositing in the hope of learning something moreduring the conversation
- B. File a suspicious transaction report with the Financial Intelligence Unit
- C. Notify the anti-money laundering specialist of his bank, but do not call the customer
- D. Close the account
Answer: C
NEW QUESTION # 259
A company service provider in Country A sets up a corporate structure for a client from Country B, which is known for corruption. The corporate structure includes a holding company in Country A with a bank account in one of the international banks located there. During on-boarding, the client's wealth was estimated at 7.52 million USD. Shortly thereafter, the client's father became president of Country B During a routine client review two years later, it was identified that the client's wealth had grown to 510 million USD. Which are two red flags that indicate money laundering or financial terrorism? (Select Two.)
- A. The holding company is in Country A with a bank account in one of the international banks.
- B. The client is from a country known for corruption.
- C. The clients account has not been reviewed for 2 years.
- D. The substantial growth in wealth during a short period of time.
- E. The client is a family member of a politically exposed person from a country known for corruption.
Answer: D,E
Explanation:
According to the Financial Action Task Force (FATF), substantial growth in wealth during a short period of time is a red flag for money laundering or terrorist financing. Additionally, when a client is a family member of a politically exposed person (PEP) from a country known for corruption, it raises concerns about the potential for corruption, bribery, or influence peddling. In this case, the client's father became the president of Country B, which makes him a PEP.
NEW QUESTION # 260
What are two requirements of United States financial institutions when conducting business with an international institution as a result of the USA PATRIOT Act? (Choose two.)
- A. Visiting the head office of the international financial institution
- B. Performing enhanced due diligence on shell banks
- C. Performing due diligence on correspondent accounts
- D. Complying with Special Measures issued under the USA PATRIOT Act
Answer: B,C
Explanation:
The USA PATRIOT Act imposes several requirements on U.S. financial institutions when dealing with foreign financial institutions, especially those that pose a high risk of money laundering or terrorist financing.
Two of these requirements are:
* Performing enhanced due diligence on shell banks: A shell bank is a bank that has no physical presence in any country and is not affiliated with a regulated financial group. The USA PATRIOT Act prohibits
U.S. financial institutions from opening or maintaining correspondent accounts for shell banks, and requires them to take reasonable steps to ensure that their correspondent accounts are not being used by shell banks indirectly12.
* Performing due diligence on correspondent accounts: A correspondent account is an account established by a financial institution to receive deposits from, make payments on behalf of, or handle other financial transactions for a foreign financial institution. The USA PATRIOT Act requires U.S. financial institutions to collect and verify certain information about the foreign financial institution, such as its ownership, licensing, and anti-money laundering policies, and to assess the risk of money laundering or terrorist financing associated with the correspondent account13.
References:
* CAMS Certification Package - 6th Edition | ACAMS, Chapter 3: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), pages 82-84
* CAMS Certifications: How to Get CAMS Certified | ACAMS, Candidate Handbook, page 14
* ACAMS CAMS Certification Video Training Course - Exam-Labs, Video 3.4: Correspondent Banking and Money Laundering Risks
NEW QUESTION # 261
Which situations would require a financial institution (FI) to update its ML/TF risk assessment? (Choose two.)
- A. When opening a sales point in a new location in the same city
- B. When new board members are elected
- C. When new products, services or customer types are introduced
- D. When the AML compliance team hires new employees
- E. When the institution faces a merger or acquisition
Answer: C,E
Explanation:
According to the ACAMS CAMS Certification Study Guide (6th edition), a financial institution (FI) should update its ML/TF risk assessment when there are changes in its business activities, customer base, or operating environment that may affect its exposure to ML/TF risks1 Some examples of such changes are:
* When new products, services or customer types are introduced: New products, services or customer types may introduce new or increased ML/TF risks that the FI may not have previously considered or addressed. For example, offering online banking, prepaid cards, or cross-border remittances may create new opportunities for money launderers or terrorist financiers to exploit the FI's systems and processes. Therefore, the FI should assess the ML/TF risks associated with the new products, services or customer types and implement appropriate controls to mitigate them12
* When the institution faces a merger or acquisition: A merger or acquisition may result in the FI inheriting the ML/TF risks of the other entity, as well as the potential liabilities and reputational damage that may arise from any ML/TF issues or violations. Therefore, the FI should conduct a due diligence on the other entity's ML/TF risk assessment, policies, procedures, and controls, and identify any gaps or weaknesses that need to be addressed. The FI should also integrate and harmonize the ML
/TF risk assessment and compliance programs of the merged or acquired entity with its own13
1: ACAMS CAMS Certification Study Guide (6th edition), page 32. 2: Money laundering/terrorism financing risk assessment | AUSTRAC4 3: MONEY LAUNDERING & TERRORIST FINANCING (ML/TF) RISK ASSESSMENT METHODOLOGY5, page 4.
Reference: https://www.fatf-gafi.org/media/fatf/content/images/National_ML_TF_Risk_Assessment.pdf
NEW QUESTION # 262
Which two factors assist a money laundering investigation that involves multiple countries? (Choose two.)
- A. Law enforcement and other authorities should not expedite information sharing between countries toensure that all information is provided at the same time to avoid premature conclusions.
- B. Law enforcement and other authorities should have access to financial information that is pertinent to theinvestigation.
- C. Every country should share all their information with foreign law enforcement and government authoritiesto facilitate rapid investigations.
- D. Law enforcement and other authorities should be allowed to establish and utilize joint investigative teamswith law enforcement in other countries.
Answer: B,D
Explanation:
A money laundering investigation that involves multiple countries can be challenging due to different legal systems, languages, cultures, and levels of cooperation. Two factors that can assist such an investigation are:
* Law enforcement and other authorities should have access to financial information that is pertinent to the investigation. This can help them trace the flow of illicit funds, identify the perpetrators and beneficiaries, and gather evidence for prosecution. Financial information can be obtained from various sources, such as financial institutions, financial intelligence units, regulators, and international organizations.
* Law enforcement and other authorities should be allowed to establish and utilize joint investigative teams with law enforcement in other countries. This can enhance coordination, communication, and information sharing among the authorities involved, and allow them to pool resources, expertise, and evidence. Joint investigative teams can also facilitate mutual legal assistance and extradition requests.
Financial Action Task Force (FATF), International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation, The FATF Recommendations, February 2012, updated June 2019, Recommendation 40, pp. 120-123 FATF, Best Practices on Establishing and Operating a Joint Investigative Team, June 2020, pp. 5-6 FATF, Money Laundering and Terrorist Financing Investigations, June 2018, pp. 11-12
NEW QUESTION # 263
Which of the following represents the first Financial Action Task Force initiative?
- A. The Special Recommendations on Terrorist Financing
- B. The Report on Money Laundering Typologies
- C. The Report on Non-Cooperative Countries and Territories
- D. The 40 Recommendations on Money Laundering
Answer: D
Explanation:
The first Financial Action Task Force (FATF) initiative was the 40 Recommendations on Money Laundering, which were issued in April 1990, less than a year after the FATF was established by the G7 summit in Paris in 1989. The 40 Recommendations aimed to provide a comprehensive plan of action to fight money laundering by setting out the principles and measures for effective legal, regulatory, and operational frameworks at the national and international levels. The 40 Recommendations have been revised and updated several times since then, most recently in 2022, to reflect the evolving trends and techniques of money laundering and to include the issues of terrorist financing and the financing of proliferation of weapons of mass destruction.
The other options are not the first FATF initiative, but they are related to the FATF's work and mandate. The Report on Non-Cooperative Countries and Territories (NCCTs) was launched in 2000 to identify and monitor the jurisdictions that did not comply with the FATF standards and posed a risk to the international financial system. The Report on Money Laundering Typologies was first published in 1996 and has been updated annually to provide an analysis of the methods, techniques, and trends of money laundering and to assist the FATF members and observers in developing effective countermeasures. The Special Recommendations on Terrorist Financing were issued in October 2001, following the September 11 attacks, to complement the 40 Recommendations and to address the specific challenges of combating the financing of terrorism and terrorist acts.
Reference:
History of the FATF, 1
Financial Action Task Force - Wikipedia, 2
Financial Action Task Force (FATF): What it is, How it Works - Investopedia, 3 The FINANCIAL ACTION TASK FORCE (FATF) - INSIGHTSIAS, 4
NEW QUESTION # 264
A compliance officer provides an overview of the bank's anti-money laundering program to a group of new tellers during employee orientation.
Which training element should be delivered to this audience?
- A. Past check fraud losses incurred by the financial institution
- B. Results of recent risk assessments
- C. The financial institution's surprise cash audit policy
- D. Large cash transaction reporting procedures
Answer: D
Explanation:
According to the ACAMS study guide, one of the training elements that should be delivered to new tellers during employee orientation is "large cash transaction reporting procedures" (p. 224). This is because tellers are often the first line of defense against money laundering and have the responsibility to identify and report any transactions that exceed the threshold of $10,000 or are otherwise suspicious. The other options are not relevant for tellers, as they are more suitable for higher-level or specialized staff.
References:
ACAMS. (2020). Study Guide for the Certification Examination for Anti-Money Laundering Specialists (6th ed.). Miami, FL: ACAMS.
AML Requirements for Tellers 1
Deposit Compliance Training Courses 2
As the compliance officer is providing overview of the "bank's anti-money laundering program to a group of new tellers during employee orientation"
NEW QUESTION # 265
Which activity is most likely to facilitate money laundering through on-line systems with inadequate controls?
- A. Conducting anonymous transactions
- B. Providing continuous worldwide access
- C. Conducting large value transactions
- D. Conducting a large volume of transactions
Answer: B
NEW QUESTION # 266
A bank located in New York has identified suspicious transactions at a correspondent bank in China. For one of the international customers, the correspondent bank is not following agreed upon protocols.
Which factor indicates that the bank should terminate the relationship?
- A. The correspondent bank has recently exceeded acceptable limits in the primary banks' recently developed risk model.
- B. The compliance officer at the correspondent bank is currently being investigated due to bribery allegations.
- C. The primary institution has requested transactional details from the correspondent bank to aide in their investigation.
- D. The correspondent bank has opened branches in a country on the Office of Foreign Assets Control list.
Answer: A
Explanation:
Explanation
NEW QUESTION # 267
Combating the Financing of Terrorism (CFT)]
Which of the following activities conducted at a financial institution is the strongest example of avoiding reporting thresholds?
- A. Conducting small cash transactions at multiple locations during the same day.
- B. Performing transactions by check (cheque) or other payment instrument.
- C. Making small cash deposits over the course of a week.
- D. Establishing both a personal and business account and depositing cash in both.
Answer: A
Explanation:
Conducting small cash transactions at multiple locations during the same day is the strongest example of avoiding reporting thresholds. This is a common technique used by money launderers to evade the attention of financial institutions and regulators, who are required to report cash transactions above a certain amount (usually $10,000) to the authorities. By splitting the large sum of money into smaller amounts and depositing them at different branches or ATMs, the money launderer can avoid triggering the reporting requirement and conceal the source and destination of the funds. This practice is also known as smurfing or structuring12.
:
ACAMS CAMS Certification Study Guide, 6th Edition, Chapter 2, page 36
ACAMS CAMS Certification Video Training Course, Module 2, Lesson 2.2, Structuring and Smurfing
1, Smurfing Money Laundering: Mechanics, Detection, and Prevention
2, AML & eWallets - The Risks & How To Comply | ComplyAdvantage
NEW QUESTION # 268
......
The CAMS certification exam covers a wide range of topics related to AML, including money laundering techniques, AML regulations, risk management, and compliance. CAMS exam is designed to test both theoretical knowledge and practical skills, and it requires candidates to demonstrate their ability to apply AML concepts to real-world scenarios. CAMS exam consists of 120 multiple-choice questions, and candidates have four hours to complete it. To be eligible to take the CAMS certification exam, candidates must have at least 40 hours of AML training or equivalent experience, and they must also pass a background check. Obtaining the CAMS certification can help professionals advance their careers in the AML field and demonstrate their commitment to the highest standards of AML compliance.
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