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質問 # 170
Which actions are involved when a prosecutor instructs a bank to freeze the assets and bank accounts held by one of its clients? (Choose three.)
- A. Inform other banks in the same geographical area to freeze the client's assets if they are a member of that bank, too.
- B. Extend the account and asset freeze to the client's family members as a precautionary measure.
- C. Ensure the client and beneficiaries are unable to access any frozen assets during the freeze order.
- D. The institution should obtain a copy of the court order to freeze the assets of the named individuals.
- E. The institution does not need to comply with the request if the client's assets make the task unusually difficult or complex to access.
- F. An affidavit must accompany the freeze order for the bank to comply with the request.
正解：C、D、F
解説：
When a prosecutor instructs a bank to freeze the assets and bank accounts held by one of its clients, the bank must take the following actions:
Ensure the client and beneficiaries are unable to access any frozen assets during the freeze order. This means the bank must prevent any withdrawals, transfers, payments, or other transactions from the frozen accounts or assets. The bank must also notify the client and beneficiaries of the freeze order and the reason for it. The bank must comply with the freeze order until it is lifted by the court or the prosecutor12.
An affidavit must accompany the freeze order for the bank to comply with the request. An affidavit is a sworn statement that provides the legal basis and evidence for the freeze order. The affidavit must specify the name of the client, the amount and location of the assets to be frozen, the nature and source of the funds, the suspected criminal activity, and the legal authority for the freeze order3 .
The institution should obtain a copy of the court order to freeze the assets of the named individuals. A court order is a legal document that authorizes the bank to freeze the assets and accounts of the client.
The court order must be signed by a judge or a magistrate and must include the same information as the affidavit. The bank should keep a copy of the court order for its records and to verify its validity .
References:
Frozen Bank Account: Here's What You Need to Know
Why Is My Bank Account Frozen? - Investopedia
What Is a Frozen Account? What Causes It and How to Unfreeze It
[Freezing Orders - Practical Law]
[Freezing Orders - The Law Society]
[Freezing Orders - LexisNexis]
質問 # 171
An AML compliance officer receives notice of government update including the names of the latest terrorists sanctioned by the United Nations Security Council. Which would be the most appropriate step to take?
- A. Inform the customers that their funds will be frozen
- B. Notify the Board of Directors
- C. Update training information to include the latest names
- D. Update the monitoring software containing sanctioned persons
正解：D
解説：
The most appropriate step for an AML compliance officer to take upon receiving notice of government update including the names of the latest terrorists sanctioned by the United Nations Security Council is to update the monitoring software containing sanctioned persons. This is because the AML compliance officer is responsible for ensuring that the financial institution does not engage in any transactions or business relationships with individuals or entities that are subject to sanctions, as this could expose the institution to legal, regulatory, and reputational risks. By updating the monitoring software, the AML compliance officer can ensure that the institution's screening and filtering systems are up to date and can flag any potential matches or hits with the sanctioned persons. This would also enable the AML compliance officer to take appropriate actions, such as blocking or freezing funds, reporting to the relevant authorities, and conducting further due diligence, if necessary.
References:
Anti-Money Laundering (AML) | FINRA.org, Overview.
AML Compliance Officer and Their Responsibilities - Tookitaki, Role and Responsibilities of an AML Compliance Officer.
What is an AML Compliance Officer? - Sanction Scanner, Communicate openly with the company's internal management team.
Guidance on Existing AML Program Rule Compliance ... - FinCEN.gov, Financial Institutions Toll-Free Hotline.
質問 # 172
A compliance officer is tasked with implementing an enterprise-wide anti-money laundering program for a bank, which operates in multiple countries. Not all the bank products and services are available in all countries.
Which three factors should be considered as part of the approach? (Choose three.)
- A. The amount of resources needed to implement the anti-money laundering program in the countries
- B. The customer onboarding platform that will be used
- C. The extent of anti-money laundering regulations in the various countries
- D. The types of customers serviced by the bank
- E. The anti-money laundering risk posed by the products and services offered by the bank
正解：C、D、E
解説：
A compliance officer should consider the following three factors as part of the approach to implement an enterprise-wide anti-money laundering program for a bank that operates in multiple countries:
The types of customers serviced by the bank: Different types of customers may pose different levels of money laundering risk, depending on their nature, source of funds, geographic location, transaction patterns, and other factors. A compliance officer should identify and assess the money laundering risk associated with each customer type and segment, and apply appropriate due diligence measures, monitoring systems, and risk mitigation strategies accordingly12.
The extent of anti-money laundering regulations in the various countries: A compliance officer should be aware of the legal and regulatory requirements and expectations for anti-money laundering compliance in each country where the bank operates, and ensure that the bank's policies and procedures are consistent with them. A compliance officer should also monitor any changes or updates in the anti-money laundering laws and regulations in the various countries, and adjust the bank's program accordingly34.
The anti-money laundering risk posed by the products and services offered by the bank: Different products and services may have different features and functionalities that could be exploited by money launderers, such as anonymity, cross-border transfers, cash transactions, complex structures, or new technologies. A compliance officer should evaluate the money laundering risk associated with each product and service offered by the bank, and implement appropriate controls, safeguards, and oversight mechanisms to prevent and detect money laundering activities5 .
References:
1: ACAMS, CAMS Study Guide, 6th Edition, Chapter 2: Risk Assessments
2: FATF, Guidance for a Risk-Based Approach: The Banking Sector
3: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT)
4: Deloitte, AML Program Effectiveness Reform
5: ACAMS, CAMS Study Guide, 6th Edition, Chapter 4: AML Program Design
[6]: OCC, Money Laundering: A Banker's Guide to Avoiding Problems
質問 # 173
A bank's transaction surveillance system triggers an alert for a deposit of 250.000 USO into a client's account.
According to the bank's KYC information, the client works for a financial advisory firm, and earns approximately 100,000 USD per year. Which actions should be taken? (Select Three.) File the suspicious transaction immediately to the financial intelligence unit.
- A. Review the alert if the deposit is made in cash.
- B. Request information and documentation from the client on the background of the transaction.
- C. Review the transaction background in the bank's transaction platform.
- D. Discard the alert as a false positive hit
- E. Contact the client advisor to learn if he has any insight on the transaction background.
正解：B、C、E
解説：
Explanation
According to the Certified Anti-Money Laundering Specialist (CAMS) Manual , 6th edition, if a bank's transaction surveillance system triggers an alert for a deposit of 250.000 USD into a client's account, the bank should take the following actions:
* Request information and documentation from the client on the background of the transaction (CAMS Manual, 6th edition, page 46).
* Contact the client advisor to learn if he has any insight on the transaction background (CAMS Manual,
6th edition, page 47).
* Review the transaction background in the bank's transaction platform (CAMS Manual, 6th edition, page
47).
Discarding the alert as a false positive hit and reviewing the alert if the deposit is made in cash should not be done.
The bank should request additional information and documentation from the client to better understand the nature of the transaction. Additionally, the bank should reach out to the client advisor to learn if they have any insight on the transaction background. Finally, the bank should review the transaction background in the bank's transaction platform to determine if any additional alerts or anomalies are present. (CAMS Manual, 6th Edition, Pages 117-118)
質問 # 174
A financial institution is reorganizing and the anti-money laundering officer is now required to report to the Sales Director. Which of the following statements about this situation is most correct?
- A. The anti-money laundering officer should be independent of business functions.
- B. The reorganization will ensure communication of anti-money laundering issues to the board.
- C. The anti-money laundering officer should be elevated to a position on the Board.
- D. The reorganization will enhance the compliance framework.
正解：A
解説：
The anti-money laundering officer (AML officer) is responsible for overseeing the implementation and effectiveness of the anti-money laundering (AML) program of a financial institution. The AML officer should have sufficient authority, independence, and access to resources to perform this role. Reporting to the Sales Director may compromise the independence and objectivity of the AML officer, as the Sales Director may have conflicting interests or incentives that could influence the AML officer's decisions or actions. The AML officer should report to a senior management level that is independent of business functions and has direct access to the board of directors or a relevant committee. This would ensure that the AML officer can communicate any AML issues or concerns to the board without any interference or undue influence from the business functions.
References: = Some of the references that support this answer are:
ACAMS Study Guide for the CAMS Certification Examination, Chapter 2, Section 2.2.1, page 41: "The AML officer should report to a senior management level that is independent of the business line and has direct access to the board of directors or a relevant committee." Money Laundering Reporting Officer: The Role Of MLRO, Section "Role Of Money Laundering Reporting Officer": "The MLRO should have independent monitoring and should be able to connect directly with people who make business decisions, such as senior management or the board of directors." Money Laundering Reporting Officer (MLRO)? | Dow Jones, Section "What is a Money Laundering Reporting Officer (MLRO)?": "A Money Laundering Reporting Officer (MLRO) is tasked with overseeing a firm's compliance with the Financial Conduct Authority's (FCA) rules on money laundering. ... The MLRO should have sufficient authority and independence within the firm to carry out their responsibilities effectively."
質問 # 175
In 2004, Consolidated KYC Risk Management was issued by the Basel Committee on Banking Supervision (BCBS). What is a key message in this document?
- A. Consolidated KYC risk management for a group is critical and trumps jurisdictional rules hat limitinformation sharing
- B. Policies and procedures should be designed not merely to comply strictly with all relevant lawsand regulations
- C. KYC Risk Management required a yearly consolidation effort
- D. KYC Risk Management means as established decentralized process for promulgating policies andprocedures
正解：A
質問 # 176
What is the most effective criterion for determining the beneficial ownership of funds?
- A. Being a person who is the trusted party in a correspondent banking relationship
- B. Having signature authority over the account
- C. Being the person in whose name an account is opened with a financial institution
- D. Having control over such funds or entitlement to such funds
正解：D
解説：
According to the FATF Recommendations, the international standard for anti-money laundering and counter-terrorist financing, beneficial owners are the natural persons who ultimately own or control a customer or the natural persons on whose behalf a transaction is being conducted1 The beneficial ownership criterion is not based on the legal title or the nominal ownership of the funds, but on the effective control or the ultimate entitlement to the funds. Therefore, having signature authority over the account, being the person in whose name an account is opened, or being a trusted party in a correspondent banking relationship are not sufficient to determine the beneficial ownership of funds. These may be indicators of legal ownership or nominee arrangements, but they do not necessarily reflect the true ownership or control of the funds. The most effective criterion for determining the beneficial ownership of funds is having control over such funds or entitlement to such funds, either directly or indirectly, through ownership, voting rights, contractual agreements, trusts, or other means2345 References:
1: FATF Recommendations, 2012, Recommendation 10 and Interpretive Note
2: Beneficial Ownership Meaning and Regulation, Investopedia, 2022
3: Ultimate Beneficial Ownership: Understanding Where The Money Comes From, ComplyAdvantage,
2022
4: Beneficial ownership and Irish investment funds, A&L Goodbody, 2021
5: Asset Management and Investment Funds Legal and Regulatory Update, Arthur Cox, 2020
質問 # 177
According to the Financial Action Task Force Special Recommendations on Terrorist Financing, which of the following should an anti-money laundering specialist do if the specialist has reasonable grounds to suspect funds are linked or related to terrorist acts?
- A. Conduct a full due diligence review of the client.
- B. Inform the institution's managing Board.
- C. Contact the institution's legal advisor.
- D. Promptly report to the competent authority.
正解：D
質問 # 178
You have a solution that runs on a five-node Azure Kubernetes Service (AKS) cluster. The cluster uses an N- series virtual machine.
An Azure Batch AI process runs once a day and rarely on demand.
You need to recommend a solution to maintain the cluster configuration when the cluster is not in use. The solution must not incur any compute costs.
What should you include in the recommendation?
- A. Delete the cluster
- B. Downscale the cluster to zero nodes
- C. Downscale the cluster to one node
正解：C
解説：
An AKS cluster has one or more nodes.
References:
https://docs.microsoft.com/en-us/azure/aks/concepts-clusters-workloads
質問 # 179
Which of the following is the best action to take regarding a particular account once suspicious activity is reported by the institution?
- A. Secure all supporting documentation.
- B. Notify the client that the transaction has been reported.
- C. Freeze the funds pending notification from the competent authority.
- D. Immediately close the account.
正解：A
解説：
According to the BSA/AML Manual1, once a financial institution files a SAR, it should maintain a copy of the SAR and the original or business record equivalent of any supporting documentation for a period of five years from the date of filing the SAR. The supporting documentation should be identified and maintained by the financial institution as such, and be deemed to have been filed with the SAR. The financial institution should make all supporting documentation available to FinCEN or any federal, state, or local law enforcement agency, or any federal regulatory authority that examines the financial institution for compliance with the BSA, upon request. Therefore, the best action to take regarding a particular account once suspicious activity is reported by the institution is to secure all supporting documentation, as it may be needed for further investigation or examination.
References:
BSA/AML Manual1
Suspicious Activity Reporting - Overview2
Suspicious Activity Report (SAR) Basics3
質問 # 180
How should a compliance officer respond to law enforcement agencies' request for information on a customer undergoing an investigation?
- A. Freeze account assets and advise the customer that assets will not be released until the investigation has been completed
- B. Gather all requested documentation and send via secure email to the requesting authority.
- C. Share details of the investigation with respective colleagues who deal with this customer type on a daily basis.
- D. Collaborate with the financial institution's (FI's) designated department to determine the appropriate course of action to comply with the request.
正解：D
解説：
A compliance officer should cooperate with the law enforcement inquiry as much as possible, but also ensure that the request is valid, lawful, and does not violate any confidentiality or privacy obligations. Therefore, the compliance officer should collaborate with the FI's designated department, such as the legal counsel, the senior management, or the board of directors, to determine the appropriate course of action to comply with the request12. The compliance officer should also ensure that all communication, written and oral, is funneled through a centralized place, and that the FI maintains a record of the request and the response12.
References:
1: Requests by Law Enforcement for Financial Institutions to Maintain Accounts, FinCEN, 2014
2: Best Practices for Compliance and Enforcement-Related Information Requests, EPA, 2018 Reference: https://www.acams.org/en/resources/aml-glossary-of-terms
質問 # 181
In the summer, an institution identifies anti-money laundering concerns regarding a customer's account activity.
The customer, an ice cream, has deposited a lot of checks drawn on banks in foreign countries, sent large number of high dollar international wires to different countries, made cash deposits of a few hundred dollars every few days and written multiple checks for a few hundred dollars to the same dozen payees every two weeks.
Which two transaction types warrant investigation? (Choose two.)
- A. Repeated checks to the same payees
- B. Checks drawn on banks in foreign countries
- C. Regular cash deposits
- D. The wires to foreign countries
正解：B、D
質問 # 182
OFAC-issued regulations apply to which entities? (Choose two.)
- A. Foreign banks with US customers
- B. Foreign import-export companies
- C. US branches of a foreign bank
- D. Intermediaries transacting with US banks
- E. Foreign subsidiaries of US banks
正解：D、E
質問 # 183
FATF recommends the incorporation of some measures in customer due diligence (CDD) programs including:
- A. identifying the number of beneficial owners without the verification of their true identity.
- B. conducting ongoing due diligence on the business relationship and monitoring of transactions.
- C. conducting the risk assessment of products and services.
- D. identifying the products and services and their suitability to customers.
正解：B
質問 # 184
Your company recently deployed several hardware devices that contain sensors.
The sensors generate new data on an hourly basis. The data generated is stored on-premises and retained for several years.
During the past two months, the sensors generated 300 GB of data.
You plan to move the data to Azure and then perform advanced analytics on the data.
You need to recommend an Azure storage solution for the data.
Which storage solution should you recommend?
- A. Azure Blob storage
- B. Azure SQL Database
- C. Azure Queue storage
- D. Azure Cosmos DB
正解：A
解説：
Explanation/Reference:
References:
https://docs.microsoft.com/en-us/azure/architecture/data-guide/technology-choices/data-storage
質問 # 185
Separating illicit proceeds from their source by a series of complex financial Transactions designed to disguise the audit trail and provide anonymity is an example of what?
- A. integration
- B. structuring
- C. layering
- D. placement
正解：C
質問 # 186
A financial institution (FI) has decided to revamp its compliance program to be more risk-based. Which option should the FI use as part of the new risk-based compliance program?
- A. Predictive-based
- B. Transaction-based
- C. Data-based
- D. Leadership-based
正解：B
解説：
Reference:
https://www.ifc.org/wps/wcm/connect/e7e10e94-3cd8-4f4c-b6f8-1e14ea9eff80/45464_IFC_AML_Report.pdf?M
質問 # 187
Which two aspects of the security broker dealer industry increase its exposure to money laundering? Choose 2 answers
- A. The routine use of wire transfers from, to or through multiple jurisdictions
- B. Fast paced transactions conducted electronically
- C. Disposing of cash through securities purchases
- D. They easy conversion of holdings to cash with significant loss of principal
正解：B、C
質問 # 188
Historically, which vehicle is most often used to hide beneficial ownership?
- A. Professional association
- B. A limited liability partnership
- C. An offshore company
- D. A charitable organization
正解：C
解説：
a vehicle that is historically most often used to hide beneficial ownership, which is an offshore company. An offshore company is a legal entity that is incorporated or registered in a foreign jurisdiction, usually with low or no taxes, high confidentiality, and lax regulation. Offshore companies can be used by money launderers and other criminals to conceal the true identity and ownership of the funds or assets that they control, and to evade taxes, reporting, or legal obligations in their home jurisdictions. Offshore companies can also be layered with other vehicles, such as trusts, foundations, or nominees, to create complex and opaque structures that make it difficult for authorities to trace the source and destination of illicit funds.
The other options are not necessarily vehicles that are most often used to hide beneficial ownership, although they may pose some risks or challenges depending on the circumstances and the risk profile of the customers and countries involved. Option A describes a professional association, which is a group of individuals or entities that share a common profession or interest, such as lawyers, accountants, or doctors. Professional associations may be involved in money laundering or terrorist financing as facilitators, intermediaries, or advisors, but they are not typically used to hide beneficial ownership. Option C describes a limited liability partnership, which is a legal entity that combines the features of a partnership and a corporation, and limits the liability of its partners. Limited liability partnerships may be used by money launderers or terrorist financiers to obscure the ownership or control of funds or assets, but they are not as common or as secretive as offshore companies. Option D describes a charitable organization, which is a non-profit entity that is established for a charitable, religious, educational, or other public benefit purpose. Charitable organizations may be abused by money launderers or terrorist financiers to divert funds or assets for illicit purposes, but they are not usually used to hide beneficial ownership.
References:
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 4, pages 86-87
https://www.acams.org/wp-content/uploads/2019/09/ACAMS-CAMS-Study-Guide-6th-Edition-Chapter-4.pdf
質問 # 189
According to the Financial Action Task Force 40 Recommendations, Designated Non-Financial Businesses and Professionals include which entities?
- A. Money services businesses
- B. Commodities traders
- C. Real estate agents
- D. Hawala operators
正解：C
質問 # 190
A financial institution (FI) is being investigated for possible money laundering. When cooperating with law enforcement agencies, which additional steps should the FI ensure are taken? (Choose two.)
- A. Subpoenas and other information requests should be reviewed by senior management and an investigations group or counsel.
- B. Address the document destruction policy to ensure the relevant documents are destroyed.
- C. Make employees, including corporate officers, unavailable for interviews and refuse documents upon receipt of a subpoena.
- D. Centralized control is maintained over all requests and responses to ensure completeness and timely responses.
- E. Inquiries from the media are not answered directly, but rather are addressed by replying, "No comment."
正解：A、D
解説：
When an FI is being investigated for possible money laundering, it is important that it cooperates with the law enforcement agencies (LEAs) in a professional and transparent manner. This means that the FI should take the following steps:
Maintain centralized control over all requests and responses to ensure completeness and timely responses. This will help the FI to avoid duplication, inconsistency, or omission of information, as well as to track the status and progress of the requests and responses. It will also facilitate the communication and coordination between the FI and the LEAs, and demonstrate the FI's willingness to cooperate12.
Review subpoenas and other information requests by senior management and an investigations group or counsel. This will help the FI to assess the scope, relevance, and legality of the requests, as well as to identify any potential risks, conflicts, or sensitivities. It will also enable the FI to prepare and provide the requested information in an accurate and timely manner, and to seek clarification or negotiation if necessary13.
The other options are not advisable, as they may indicate a lack of cooperation, obstruct the investigation, or damage the FI's reputation. For example:
Making employees, including corporate officers, unavailable for interviews and refusing documents upon receipt of a subpoena may be considered as non-compliance, evasion, or contempt of court, and may result in legal sanctions or penalties4.
Addressing the document destruction policy to ensure the relevant documents are destroyed may be seen as tampering with evidence, destroying records, or concealing information, and may constitute a criminal offence or a breach of regulatory obligations5.
Not answering inquiries from the media directly, but rather replying, "No comment" may create a negative impression, fuel speculation, or invite criticism, and may harm the FI's image, credibility, or trustworthiness.
References:
Cooperation between FIUs, Law Enforcement Authorities, and Prosecutors
AML and Financial crimes investigation
Mechanisms for interaction of law enforcement agencies in the field of counteracting and combating money laundering Recommendation 30: Responsibilities of law enforcement and investigative authorities Money laundering and illicit finance
質問 # 191
Which statements regarding the USA PATRIOT ACT best describe key aspects that have extraterritorial reach? (Choose three.)
- A. It obliges the government to trace the origin of the funds when a seizure of assets occurs in a correspondent account that has been opened and maintained for a foreign bank in the US.
- B. It allows foreign banks to voluntarily designate a registered agent in the US to accept service of subpoenas.
- C. It allows the Secretary of the Treasury to order a US financial institution (FI) to close a correspondent account when a subpoena has not been responded by a foreign bank in a timely manner.
- D. It excludes as foreign FIs businesses that would be considered broker-dealers, money transmitters, and currency exchangers.
- E. It allows for the US Attorney General to subpoena records from a foreign bank with US correspondent accounts, including those that are located outside the US.
- F. It allows federal banking supervisors to require records of the identity of the owners of a foreign bank from a Fl operating in the US.
正解：C、D、E
解説：
Reference:
https://www.jonesday.com/-/media/files/publications/2007/10/extraterritorial-application-of-the-usa-patriot-ac/fi
https://www.lawfareblog.com/long-arm-us-law-patriot-act-anti-money-laundering-act-2020-and-foreign-banks
質問 # 192
In performing a risk analysis, which factor(s) should a financial institution review?
- A. Its customer base, location, products and services
- B. Recent regulatory actions against financial institutions of comparable size
- C. The adequacy and completeness of its STR filings
- D. The level of its gross revenue
正解：A
質問 # 193
What are three elements of a sound Customer Due Diligence Program?
- A. Determination of what type of customer the financial institution will accept
- B. Training as to how and to what extent to identify prospective customers
- C. Obtaining date of birth and address of a prospective customer
- D. Determination of who in the institution should be assigned to the prospective customer as a liaison
正解：A、B、C
質問 # 194
After several months of research, the Director of Marketing and the Managing Director of Business Development received approval to launch a branded, stored-value card that will be marketed to the diverse, primarily non-resident population that comprises the bank's current customer demographics. The Chief Credit Officer and the Risk Officer have also been involved in the efforts to develop the card. After the card is launched, the anti-money laundering officer is consulted. The anti-money laundering officer should advise the bank that compliance should have been involved
- A. During product development to perform a risk assessment of the product.
- B. After product development to confer with the legal department.
- C. During product development to develop reports for the Board.
- D. After product development to perform an assessment of the product.
正解：A
質問 # 195
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