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質問 # 48
Law enforcement (LE) suspects human trafficking to occur during a major sporting event. LE officers asked several financial institutions (FIs) to monitor financial transactions occurring before, during, and after the event.
An investigator identified a pattern linked to a business. The business' account received multiple even dollar deposits between midnight and 4:00 AM. They occurred each day for several days prior to the date of the sporting event. Also, large cash deposits, typically between 2,000 USD and 3,000 USD. made by a person to the business' account occurred in many branches in the days after the sports event.
There was little information about the company. The company did not have any history of employee payroll expenses or paying taxes. Expenses from the business account included air travel and hotel expenses. Searches about the person making cash deposits showed little. An online social media platform webpage with the individual's name showed ads for dates" and "companionship." The Fl receives a keep open' letter from LE for the identified account and agrees to keep the account open.
What is the Fl required to do?
- A. Notify LE immediately after new transactions.
- B. Stop filing SAR/STR reports on the account and/or customer.
- C. Ensure that the request includes an end date.
- D. Contact the client for information relating to the account.
正解：C
解説：
Explanation
The FI is required to ensure that the request includes an end date when it receives a keep open letter from LE for the identified account. This is because the FI has to balance its legal obligations to cooperate with LE and to protect its customers' privacy and rights. According to the ACAMS Advanced Financial Crimes Investigations Certification Study Guide1, "the FI should request a written confirmation from LE that includes a specific end date for the request, as well as a point of contact for any questions or concerns" (p. 35). The FI should also document the request and its compliance with it, and continue to monitor the account for any suspicious activity.
The other options are not correct. The FI should not contact the client for information relating to the account (A), as this could compromise the LE investigation or alert the client of the suspicion. The FI should not stop filing SAR/STR reports on the account and/or customer (B), as this could violate its regulatory obligations and expose it to legal risks. The FI should not notify LE immediately after new transactions (D), as this could also interfere with the LE investigation or tip off the client. The FI should follow the instructions of LE regarding when and how to share information.
質問 # 49
An analyst reviews an alert for high volume Automated Clearing House (ACH) activity in an account. The analyst's initial research finds the account is for a commercial daycare account that receives high volumes of large government-funded ACH transactions to support the programs. The account activity consists of checks (cheques) made payable to individual names in varying dollar amounts. One check indicates rent to another business.
An Internet search finds that the daycare company owner has previous government-issued violations for safety and classroom size needs, such as not having enough chairs and tables per enrollee. These violations were issued to a different daycare name.
Simultaneous to this investigation, another analyst sends an email about negative news articles referencing local child/adult daycare companies misusing governmental grants. This prompts the financial institution (Fl) to search all businesses for names containing 'daycare' or *care'. Text searches return a number of facilities as customers at the Fl and detects that three of these businesses have a similar transaction flow of high volume government ACH funding with little to no daycare expenses.
Which red flags would be an indicator that activity is connected to a corruption/bribery typology? (Select Two.)
- A. Large checks issued to various individuals with the memos noting "gift", "thank you", "favor"
- B. Negative news found on the customer related to government-issued violations for safety
- C. Checks issued to an unrelated entity referencing "rent" and "utilities" in the memos
- D. Multiple daycare locations with no active business operations or related account activity
- E. The same beneficial owner owning several daycare centers in different locations
正解：A、B
解説：
Explanation
The red flags that would be an indicator that activity is connected to a corruption/bribery typology are large checks issued to various individuals with the memos noting "gift", "thank you", "favor" (A) and negative news found on the customer related to government-issued violations for safety (B). These red flags suggest that the customer is involved in paying or receiving bribes or kickbacks to or from government officials or other parties in exchange for favorable treatment or contracts. These red flags are consistent with some of the indicators of corruption/bribery identified by ACAMS1, such as:
Payments made to or from third parties that are not directly related to the business Payments made to or from high-risk jurisdictions or sectors Payments made with vague or incomplete descriptions or justifications Negative news or reputation of the customer or its associates The other options are not as relevant or indicative of corruption/bribery as options A and B. Checks issued to an unrelated entity referencing "rent" and "utilities" in the memos could be a legitimate business expense or a sign of other types of fraud or money laundering, such as tax evasion or shell company schemes. Multiple daycare locations with no active business operations or related account activity (D) could also be a sign of other types of fraud or money laundering, such as embezzlement or front company schemes. The same beneficial owner owning several daycare centers in different locations (E) could be a normal or legitimate business practice, depending on the size, location, and profitability of the centers.
質問 # 50
Why is a more robust supervisory approach needed by regulators when overseeing small- and medium-sized money service businesses (MSBs) compared to larger MSBs for combatting terrorist financing (TF)?
- A. Small- and medium-sized MSBs need to be robustly supervised so the regulator can maintain visibility in combatting TF.
- B. Small- and medium-sized MSBs are more likely to falsify records to appear less risky in order to keep the banking relationship.
- C. Small- and medium-sized MSBs need to be targeted to ensure that competition in the industry remains constant and uniform.
- D. Small- and medium-sized MSBs are more at risk of allowing transactions linked to TF due to the lack of skilled compliance resources.
正解：D
解説：
Explanation
A more robust supervisory approach is needed by regulators when overseeing small- and medium-sized MSBs compared to larger MSBs for combatting TF because small- and medium-sized MSBs are more at risk of allowing transactions linked to TF due to the lack of skilled compliance resources. Small- and medium-sized MSBs may face challenges in implementing effective AML/CFT controls, such as conducting risk assessments, applying customer due diligence measures, monitoring transactions, detecting suspicious activities, and reporting to the authorities. They may also have limited access to training, guidance, and tools to enhance their compliance capabilities. Therefore, regulators need to provide more supervision and support to small- and medium-sized MSBs to ensure that they comply with the AML/CFT requirements and mitigate the TF risks.
References:
Sustainable Growth for Small and Medium-Sized Enterprises ... - MDPI
Lessons on Resilience for Small and Midsize Businesses - HBR
質問 # 51
A SAR/STR regarding money-mule activity prompts law enforcement action. Under U.S. law, the alleged money mules can be prosecuted:
- A. only if they were aware of their role and actively participated.
- B. even if they were unaware that money was transferred.
- C. in a country only if funds were transferred between accounts maintained in the same country.
- D. unless they can prove they were not aware of the origin of the funds.
正解：B
解説：
Explanation
According to U.S. law, money mules can be prosecuted even if they were unaware that money was transferred, as long as they acted with reckless disregard of the source of the funds or the purpose of the transaction1.
This is because money mules are considered to be aiding and abetting money laundering, which does not require proof of specific intent2.
References: 1: Money Mule Awareness Booklet, page 8 2: Money Laundering: An Overview of 18 U.S.C. § 1956 and Related Federal Criminal Law, page 7
質問 # 52
How does the Financial Action Task Force (FATF) measure the effectiveness of a country's efforts to combat money laundering and terrorist financing?
- A. Mutual evaluation
- B. Basel Committee
- C. Series of internal audits followed by reporting to FATF
- D. FATF Evaluation Committee
正解：A
解説：
Explanation
"The FATF measures the effectiveness of a country's efforts to combat money laundering and terrorist financing through a mutual evaluation process. During a mutual evaluation, the FATF assesses a country's legal and institutional framework, its implementation of measures to combat money laundering and terrorist financing, and the effectiveness of its efforts. The FATF then issues a report with recommendations for improvement" [CAMS Study Guide 6th edition, page 15-16].
質問 # 53
A compliance analyst is reviewing the account activity of a customer that they suspect may be indicative of money laundering activity. Which is difficult to determine solely from the customer's account activity and KYC file?
- A. If the activity is materially different from related businesses
- B. If the account has multiple transfers to the same, related businesses
- C. If the account is mostly dormant or has little activity
- D. If there is negative media associated with counterparties
正解：D
解説：
Explanation
According to the Certified Anti-Money Laundering Specialist (CAMS) study guide, 6th edition, page 105, the correct answer is C. It can be difficult to determine if there is negative media associated with counterparties solely from the customer's account activity and KYC file.
The study guide explains that negative media can include news articles, government sanctions lists, and other sources of public information that may indicate that a counterparty is involved in illicit activities. However, this information may not be readily available in a customer's account activity or KYC file, and may require additional research or investigation.
質問 # 54
During transaction monitoring. Bank A learns that one of their customers. Med Supplies 123, is attempting to make a payment via wire totaling 382,500 USD to PPE Business LLC located in Mexico to purchase a large order of personal protective equipment. specifically surgical masks and face shields. Upon further verification.
Bank A decides to escalate and refers the case to investigators.
Bank A notes that, days prior to the above transaction, the same customer went to a Bank A location to wire
1,215,280 USD to Breath Well LTD located in Singapore. Breath Well was acting as an intermediary to purchase both 3-ply surgical masks and face shields from China. Bank A decided not to complete the transaction due to concerns with the involved supplier in China. Moreover, the customer is attempting to send a third wire in the amount of 350,000 USD for the purchase of these items, this time using a different vendor in China. The investigator must determine next steps in the investigation and what actions, if any. should be taken against relevant parties.
Upon further investigation. Bank As investigator learns that both the Mexico- and Singapore-based companies are linked to the alleged suppliers in China. Which additional indicators would the investigator need to identify to determine if this fits a fentanyl (drug) trafficking typology? (Select Two.)
- A. Review of the Food and Drug Administration (FDA) product certifications provided by the customer reveals that documents were falsified.
- B. Review of the account activity reveals that wires were mainly funded by multiple cash deposits, conducted in amounts of 10.000 USD or below.
- C. Review of the account activity reveals that account is inconsistent with the expected business activity as it shows multiple charges at various hotels, transportation tickets for unrelated 3rd parties, etc.
- D. Review of the invoices and transportation documents, provided by the customer, reveal significant discrepancies between the description of goods.
Internet research reveals that suppliers are newly established companies with no history of sales of medical equipment.
正解：A、D
質問 # 55
A retail bank prepares a yearly AML risk assessment. Which inherent risk factor is likely the most relevant?
- A. The provision of remote check deposit services
- B. The provision of payable through accounts
- C. The provision of brokerage services
- D. The provision of cash services
正解：D
解説：
Explanation
Retail banks typically have a high inherent risk of money laundering due to their provision of cash services.
This is because cash is a preferred medium of exchange for criminals and terrorists, and retail banks provide a convenient way for them to move large sums of money without detection. Retail banks are also vulnerable to money laundering through the use of false identities and other deceptive practices. (CAMS Manual, 6th Edition, Page 8).
質問 # 56
An unusual spike in activity has occurred for a customer who is a supplier of aviation parts to a military force.
The customer's current line of business is consistent with the banks records, and no adverse media hits have occurred. Which is the best reason for an investigator to continue an investigation?
- A. The current line of business is consistent with the bank's records.
- B. The end-user is a military force.
- C. There are no adverse media hits.
- D. The customer is a supplier of aviation parts.
正解：B
解説：
Explanation
The best reason for an investigator to continue an investigation is that the end-user is a military force. This is because supplying aviation parts to a military force may involve sanctions risk, export control risk, or human rights risk, depending on the nature and destination of the military force. The investigator should conduct further due diligence to determine if the customer is complying with the relevant laws and regulations, and if the bank is exposed to any reputational or legal risk by providing services to the customer.
References:
Former Airline Employee and Aircraft Part Sellers Charged in Kickback ...
Former Airline Employee and Aircraft Part Sellers Charged in Kickback ...
Former airline employee and aircraft part sellers charged in kickback ...
質問 # 57
The law enforcement agency (LEA) of a foreign jurisdiction contacts a financial institution (Fl) regarding one of the Fl's clients. The LEA advises that the client is currently wanted for prosecution as a result of a series of human trafficking charges. What should the Fl do? (Select Two.)
- A. Advise the LEA that the government needs to be contacted for extradition.
- B. Close the clients accounts immediately to avoid any undue risk.
- C. Inform local LEA and regulator of the request for awareness.
- D. Comply immediately with the foreign jurisdiction and turn over all client information.
- E. Review the client's activity, determine if suspicious activity exists, and report accordingly.
正解：C、E
解説：
Explanation
According to the Certified Anti-Money Laundering Specialist (the 6th edition), the financial institution (Fl) should take the following actions:
A: Review the client's activity, determine if suspicious activity exists, and report accordingly. The Fl should assess the risk of the situation and determine if there is any suspicious activity that needs to be reported to the appropriate authorities. This would involve conducting a review of the client's account activity and transactions to determine if there are any indicators of money laundering or terrorist financing.
D: Inform local LEA and regulator of the request for awareness. The Fl should inform the local law enforcement agency and regulator of the request from the foreign jurisdiction to raise awareness of the situation and determine if any further actions need to be taken.
質問 # 58
A client with many personal and business deposits with the financial institution (Fl) seeks a business loan. The client wants to guarantee the loan with a trust for which they are the beneficiary.
An investigator examines the trust. The trust has many layers, including shell companies in known tax havens.
The client's ultimate beneficial ownership claim cannot be validated, and the loan is denied.
Two months later, the Fl receives a law enforcement (LE) request on one of the client's business accounts.
While reviewing the business account, the Fl receives another LE request on the same account from another agency. The requested information is shared.
Three months later, a branch manager receives a request to open a business deposit account related to a complex trust. The manager forwarded the request because of the complexity. The trust was the same as the previously examined trust, but the request came from a different client. The second client also has many accounts with the Fl. Further inspection finds links between the second client and the Paradise Papers. The Papers state the client led illegal activities and committed tax evasion.
What steps should the investigator take to review the accounts held by the second client who is listed in the Paradise Papers? (Select Two.)
- A. Inform Fl management of the start of a serious risk-based investigation that could result in losses and reputation risk.
- B. Inform Fl management of deficiencies in their AML program because the second client's activities were not detected.
- C. Review all accounts being reviewed by AML investigators over the past year that have opened trust accounts.
- D. Recommend a SAR/STR be filed regarding the second client's use of a questionable trust to open an account.
- E. Monitor all accounts and entities related to the second client
正解：D、E
解説：
Explanation
The investigator should recommend a SAR/STR be filed regarding the second client's use of a questionable trust to open an account, as this could indicate an attempt to conceal the source and ownership of funds, and to evade taxes and sanctions. The investigator should also monitor all accounts and entities related to the second client, as they may be involved in illegal activities or pose a high risk to the FI. The investigator should not review all accounts that have opened trust accounts, as this would be too broad and inefficient. The investigator should not inform FI management of deficiencies in their AML program, as this is not their role or responsibility. The investigator should not inform FI management of the start of a serious risk-based investigation, as this may compromise the confidentiality and integrity of the investigation.
質問 # 59
The training department is conducting awareness training for unusual customer identification scenarios. Which two indicators should be included? (Select Two.)
- A. The customer requests payment of proceeds to an unrelated third party.
- B. The customer's name and home address cannot be verified
- C. The customer opens the account in the name of a family member who begins making large deposits.
- D. The customer's internet protocol address does not match the identifying information provided during online registration.
- E. The customer frequently exchanges small bills for large bills.
正解：B、C
解説：
Explanation
This information can be found in the Certified Anti-Money Laundering Specialist (CAMS) study guide, 6th edition, under the section on Unusual Customer Identification Scenarios. The guide explains that two indicators that should be included in awareness training for unusual customer identification scenarios are:
A: The customer opens the account in the name of a family member who begins making large deposits.
This is an indicator of potential structuring, where a customer may be attempting to avoid triggering reporting thresholds by depositing funds in smaller amounts over time. It is important for staff to be aware of this scenario and to monitor accounts for potential suspicious activity.
B: The customer's name and home address cannot be verified.
This is an indicator of potential identity theft or other fraudulent activity. If a customer's identifying information cannot be verified, it is important for staff to conduct additional due diligence to ensure that the customer is legitimate and that the account is not being used for illicit purposes.
質問 # 60
While each is potentially important, which allows an investigations analyst to better write a SAR/STR narrative that is useful to law enforcement? (Select Two.)
- A. Including a detailed description of the known or suspected criminal violation or suspicious activity
- B. Including an explanation of the internal process that brought the transaction to the attention of the analyst
- C. Including contact information for individuals at other institutions with whom correspondence has occurred
- D. Ensuring all information in the SAR/STR is complete and accurate based on what the institution knows
- E. Including information about the general activity trends in the area where the suspicious transactions were conducted
正解：A、D
解説：
Explanation
A SAR/STR narrative that is useful to law enforcement should include a detailed description of the known or suspected criminal violation or suspicious activity, as well as ensure that all information in the SAR/STR is complete and accurate based on what the institution knows. These elements help law enforcement to understand the nature and scope of the suspicious activity, and to follow up with further investigation if needed. The other options are not essential for a useful SAR/STR narrative, as they either provide irrelevant or redundant information, or could compromise the confidentiality of the report.
質問 # 61
Which action is part of the enhanced due diligence process?
- A. Using standard monitoring procedures to monitor transactions and account activity
- B. Verifying the source of wealth for entities and natural person clients
- C. Applying higher ownership percentage requirement for beneficial ownership collection
- D. Collecting beneficial ownership details regarding the client's account
正解：D
解説：
Explanation
One of the actions that is part of the enhanced due diligence process is collecting beneficial ownership details regarding the client's account. This is important to identify the natural persons who ultimately own or control the client, and to assess the potential risks associated with them. According to the Financial Action Task Force (FATF), beneficial ownership information should include1:
The name, nationality, and country of residence of each beneficial owner.
The date of birth or incorporation of each beneficial owner.
The nature and extent of the beneficial interest held by each beneficial owner.
The means by which the beneficial ownership or control is exercised.
References:
FATF Guidance on Transparency and Beneficial Ownership
質問 # 62
When writing or reviewing a SAR/STR, it is important to:
- A. ensure the narrative is kept to the point; easy to read; and addresses the who, what, when, where, why, and how.
- B. ensure that the narrative is detailed with all available information so that law enforcement can decide what is relevant.
- C. avoid mentioning suspect names in case it is seen by someone involved in criminal activity, effectively tipping them off.
- D. keep the introduction brief but ensure all relevant transactions, account numbers, and suspect names are listed in the conclusion summary.
正解：A
解説：
Explanation
The correct answer is A because a SAR/STR narrative should be concise, clear, and complete, addressing the who, what, when, where, why, and how of the suspicious activity. Option B is incorrect because providing too much information can make the narrative confusing and irrelevant. Option C is incorrect because the introduction should provide a summary of the suspicious activity, not the conclusion. Option D is incorrect because suspect names should be mentioned in the narrative to identify the parties involved in the suspicious activity.
References: Advanced CAMS-FCI Certification Handbook, page 17; Leading Complex Investigations Certificate, Module 3.
質問 # 63
Which test should be included in a bank's Office of Foreign Assets Control sanctions screening audit program?
- A. Examining Human Resources processes for conducting criminal background checks on executives
- B. Ensuring that all clients with foreign identification are subject to enhanced due diligence
- C. Looking at copies of suspicious activity reports filed with regulators to ensure completeness
- D. Reviewing wire transfer screening processes to ensure that potential name hits are investigated promptly
正解：B
解説：
Explanation
The OFAC sanctions screening audit program should include the requirement that all clients with foreign identification are subject to enhanced due diligence, as this provides an extra layer of protection against potential violations of OFAC sanctions.
質問 # 64
An investigator at a corporate bank is conducting transaction monitoring alerts clearance.
KYC profile background: An entity customer, doing business offshore in Hong Kong, established a banking business relationship with the bank since 2017 for deposit and loan purposes. It acts as an offshore investment holding company. The customer declared that the ongoing source of funds to this account comes from group-related companies.
* X is the UBO. and owns 97% shares of this entity customer;
* Y is is the authorized signatory of this entity customer. This entity customer was previously the subject of a SAR/STR.
KYC PROFILE
Customer Name: AAA International Company. Ltd
Customer ID: 123456
Account Opened: June 2017
Last KYC review date: 15 Nov 2020
Country and Year of Incorporation: The British Virgin Islands, May 2017 AML risk level: High Account opening and purpose: Deposits, Loans, and Trade Finance Anticipated account activities: 1 to 5 transactions per year and around 1 million per transaction amount During the investigation, the investigator reviewed remittance transactions activities for the period from Jul
2019 to Sep 2021 and noted the following transactions pattern:
TRANSACTION JOURNAL
Review dates: from July 2019 to Sept 2021
For Hong Kong Dollars (HKD) currency:
Incoming transactions: 2 inward remittances of around 1.88 million HKD in total from different third parties Outgoing transactions: 24 outward remittances of around 9 4 million HKD in total to different third parties For United States Dollars (USD) currency:
Incoming transactions: 13 inward remittances of around 3.3 million USD in total from different third parties Outgoing transactions: 10 outward remittances of around 9.4 million USD in total to different third parties.
RFI Information and Supporting documents:
According to the RFI reply received on 26 May 2021, the customer provided the bank with the information below:
1J All incoming funds received in HKD & USD currencies were monies lent from non-customers of the bank.
Copies of loan agreements had been provided as supporting documents. All of the loan agreements were in the same format and all the lenders are engaged in trading business.
2) Some loan agreements were signed among four parties, including among lenders. borrower (the bank's customer), guarantor, and guardian with supplemental agreements, which stated that the customer, as a borrower, who failed to repay a loan Which suspicious activity should the investigator identify during the review of the loan agreements?
- A. AAA International Company Ltd.'s account has transactions in HKD and USD.
- B. Y is the authorized signatory on the beneficial ownership form.
- C. Online information found that X is the chairman of a business group of companies.
- D. Y signed on behalf of the lenders.
正解：D
解説：
Explanation
The correct answer is D because it is a suspicious activity that Y, who is the authorized signatory of the customer, also signed on behalf of the lenders. This indicates a possible conflict of interest, collusion, or fraud.
The other options are not suspicious activities based on the information given.
References: [Advanced CAMS-FCI Study Guide], page 17-18
質問 # 65
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