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質問 # 32
Which might suggest misuse of crowdfunding resources by a terrorist?
- A. Multiple small deposits followed by the purchase of airplane tickets >
- B. A small charge at a gas station followed by a large charge at an electronics store
- C. A large deposit followed by multiple charges at a sporting goods store
- D. Multiple small deposits followed by a wire transfer to a large well-known international charity
正解：A
解説：
Explanation
The purchase of airplane tickets after receiving multiple small deposits from a crowdfunding platform might suggest that the funds are being used to facilitate travel for terrorist purposes. The other options are not necessarily indicative of terrorist financing, as they could be explained by legitimate reasons or other types of financial crimes.
質問 # 33
How does the Financial Action Task Force (FATF) measure the effectiveness of a country's efforts to combat money laundering and terrorist financing?
- A. FATF Evaluation Committee
- B. Mutual evaluation
- C. Basel Committee
- D. Series of internal audits followed by reporting to FATF
正解：B
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 # 34
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 perform in reference to the first client's existing accounts? (Select Three.)
- A. Review Fl approved policies regarding the existing accounts to ensure regulatory requirements were followed.
- B. Perform secondary scans of the client's other owners/authorized signers
- C. Prepare a relationship flow chart of all existing accounts to better understand the client's activities.
- D. File SARs/STRs for all accounts at the beginning of the discovery phase and amend later as necessary.
- E. Inform Fl management of all processes used to investigate the client due to LE inquiry.
- F. Review all client-signed documents relating to all accounts.
正解：B、C、F
解説：
Explanation
The investigator should review all client-signed documents relating to all accounts (A) to check for any discrepancies or red flags. The investigator should also perform secondary scans of the client's other owners/authorized signers (D) to identify any possible connections or associations with the second client or the Paradise Papers. Additionally, the investigator should prepare a relationship flow chart of all existing accounts (F) to better understand the client's activities and patterns. These steps are consistent with the ACAMS Advanced Financial Crimes Investigations Certification Study Guide1, which states that investigators should
"review all relevant documentation, including account opening documents, transaction records, and customer correspondence" (p. 23), "conduct enhanced due diligence on all parties involved in the investigation" (p. 24), and "use data visualization tools to map out complex relationships and transactions" (p. 25).
References: 1: ACAMS Advanced Financial Crimes Investigations Certification Study Guide, available at ACAMS
質問 # 35
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. Ensure that the request includes an end date.
- B. Notify LE immediately after new transactions.
- C. Stop filing SAR/STR reports on the account and/or customer.
- D. Contact the client for information relating to the account.
正解：A
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 # 36
A new customer has just been onboarded in a securities firm. After a few weeks, there are unusual trading patterns that are being flagged. Which pattern is most concerning to the compliance officer?
- A. The customer's repeated trading in securities that are low priced and low volume counters.
- B. The customer accumulates securities of a low volume counter in small increments on a weekly basis.
- C. The customer engages in large trading in securities that are liquid or highly priced from the trading account.
- D. The customer receives many incoming wire transfers from related parties to the trading account.
正解：B
解説：
Explanation
The most concerning trading pattern for a compliance officer when a new customer has been onboarded in a securities firm is the customer accumulating securities of a low volume counter in small increments on a weekly basis. This type of behavior could indicate that the customer is attempting to obscure their identity or the true purpose of their trading activity, which can be indicative of money laundering or other suspicious activity. (CAMS Manual, 6th Edition, Page 170).
質問 # 37
Which action is part of the enhanced due diligence process?
- A. Applying higher ownership percentage requirement for beneficial ownership collection
- B. Collecting beneficial ownership details regarding the client's account
- C. Using standard monitoring procedures to monitor transactions and account activity
- D. Verifying the source of wealth for entities and natural person clients
正解：B
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 # 38
In the past 6 months, a small financial institution (Fl) has received regular remittances that are increasing in value from a country with high piracy activity. The Fl's AML officer (AMLO) has also noted that piracy in this country has increased in the same time frame. Which recommendation should the AMLO make?
- A. Conduct an in-depth investigation into accumulated remittance information in the past year to find the trend of such transactions.
- B. Request the operations department to return inbound remittances when the sender of funds is from this country.
- C. File a SAR/STR to the appropriate AML authority immediately.
- D. Upgrade the transaction monitoring system of the Fl to include more fields so that more in-depth information is collected about the inward remittances.
正解：A
解説：
Explanation
Verified answer: D The recommendation that the AMLO should make is to conduct an in-depth investigation into accumulated remittance information in the past year to find the trend of such transactions. This is because the regular and increasing remittances from a country with high piracy activity may indicate a possible link to illicit funds derived from piracy or other criminal activities. According to the World Bank, remittances are often used as a channel for money laundering and terrorist financing, especially when they originate from or are destined to high-risk jurisdictions1. Therefore, the AMLO should analyze the remittance data to identify the sources, destinations, amounts, frequencies, and purposes of the transactions, and compare them with the customer profiles, expected activities, and risk ratings. The AMLO should also review any relevant information from external sources, such as media reports, sanctions lists, or law enforcement alerts, to determine if there are any red flags or indicators of suspicious activity. If the investigation reveals any evidence or suspicion of money laundering or terrorist financing, the AMLO should file a SAR/STR to the appropriate AML authority.
References:
Remittances data - Migration data portal
質問 # 39
Law enforcement (LE) suspects human trafficking to occur during a major spotting 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 alter 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." Which fact should not be included in (he SAR/STR narrative?
- A. The time of the cash deposits
- B. The air travel and hotel expenses
- C. The sporting event
- D. The request by law enforcement
正解：A
解説：
Explanation
The fact that should not be included in the SAR/STR narrative is the request by law enforcement (D). This is because the request by law enforcement is confidential and should not be disclosed to the customer or anyone else who is not authorized to know it. According to the ACAMS Advanced Financial Crimes Investigations Certification Study Guide1, "the FI should not include any reference to the LE request in the SAR/STR narrative, as this could compromise the LE investigation or alert the customer of the suspicion" (p. 35). The FI should also not inform the customer of the LE request or delay filing the SAR/STR because of it.
The other facts should be included in the SAR/STR narrative, as they are relevant and indicative of human trafficking money laundering. The air travel and hotel expenses (A) show that the customer is involved in moving people across different locations, which could be a sign of human smuggling or trafficking. The time of the cash deposits (B) shows that the customer is receiving cash payments during unusual hours, which could be a sign of illicit activities or services. The sporting event shows that the customer is exploiting a high-demand situation for their business, which could be a sign of opportunistic or organized crime.
質問 # 40
During onboarding al Private Bank A, client C indicated that the account would be initially funded with a transfer from Bank B totaling 50 million USD. On which source of funds should Bank A conduct additional scrutiny? (Select Two.)
- A. Client's verified employment income
- B. Third-party transfer
- C. Transfer from Bank B
- D. Documented sale of client properties
- E. Client's overall wealth
正解：B、C
解説：
Explanation
The sources of funds that Bank A should conduct additional scrutiny on are the third-party transfer and the transfer from Bank B. This is because these sources may pose higher risks of money laundering, terrorist financing, fraud, or other illicit activities. Some of the reasons why these sources require more scrutiny are23:
Third-party transfers may involve unknown or unrelated parties that may have ulterior motives or hidden agendas. They may also be used to obscure the origin or destination of funds, or to circumvent sanctions or other regulatory restrictions.
Transfers from Bank B may involve jurisdictions that have weak anti-money laundering and counter-terrorist financing (AML/CFT) regimes, high levels of corruption, or significant criminal activity. They may also involve banks that have poor reputation, compliance, or transparency standards.
References:
Third Party Payments - Wolfsberg Group
Guidance on Correspondent Banking Services - FATF
質問 # 41
An investigator receives an alert documenting a series of transactions. A limited liability corporation (LLC) wired 59.000,000 USD to an overseas account associated with a state-run oil company. A second account associated with the state-run oil company wired 600,000,000 USD to the LLC. The LLC then wired money to other accounts, a money brokerage firm, and real estate purchases.
The investigator initiated an enhanced KYC investigation on the LLC. The financial institution opened the LLC account a couple of weeks prior to the series of transactions. The names associated with the LLC had changed multiple times since the account opened. A search of those names revealed relations with multiple LLCs. Public records about the LLCs did not show any identifiable business activities.
Open-source research identified mixed reports about the brokerage firm. The firm indicated it purchased mutual funds for its clients and dispensed returns to clients.
Media reports claimed the firm laundered money by holding for a fee before returning it to investors.
The investigator discovers that the bank has no records pertaining to ownership of the LLC. What would this mean for the bank and/or investigator?
- A. The bank is out of compliance with CIP regulations.
- B. The bank may not be able to file a SAR/STR without the ownership data.
- C. The bank is out of compliance with beneficial ownership regulations.
- D. The bank cannot respond to law enforcement requests without the ownership data.
正解：A
解説：
Explanation
The bank is out of compliance with CIP regulations because it did not obtain the minimum identifying information from the customer prior to opening the account, as required by 31 CFR § 1020.220(a)(2)(i)(A).
The bank should have obtained the name, date of birth, address, and identification number of the customer, as well as verified the identity of the customer to the extent reasonable and practicable. The lack of ownership data may also indicate a violation of beneficial ownership regulations, but that is not the primary issue in this case.
質問 # 42
According to the Financial Action Task Force, as part of their risk assessment, which are important data and information that a Trust and Company Service Provider must understand when establishing and administering a trust? (Select Two.)
- A. The general nature of business of the trust
- B. The source of funds in the structure
- C. The general purpose behind the structure
- D. The management structure of the trust
- E. The responsibility and authority in the structure
正解：C、E
解説：
Explanation
Here is the exact information from the Financial Action Task Force (FATF) Guidance for a Risk-Based Approach for Trust and Company Service Providers:
"Understanding the management and ownership structure of a trust is crucial in assessing the ML/TF risk it poses. This includes the identity of all settlors, trustees and beneficiaries, and their respective roles and responsibilities, as well as the nature and purpose of the trust."
"TCSPs should obtain and maintain up-to-date information on the purpose and intended nature of the business relationship, the source of funds and wealth, and where relevant, the source of funds or wealth of the settlor and beneficiaries." Based on this information, the correct answers are A and D. Trust and Company Service Providers must understand the responsibility and authority in the structure, as well as the general purpose behind the structure in order to assess the overall risk of the trust and ensure that any transactions with the trust are legitimate.
質問 # 43
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 'care1. 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.
During the investigation, it was determined that some of the checks were issued to a mother-in-law of a PEP and deposited into her account with the Fl. This customer was not found on the Fl's PEP list How should the investigator proceed in this situation"? (Select Two.)
- A. File a SAR/STR due to the potential involvement of a PEP.
- B. Conduct the investigation as usual, since the activity in question is not directly connected to the PEP.
- C. Reter the newly identified customers account for closure due to the high risk associated with the potential PEP.
- D. Use this case as an example to train employees to recognize potential PEPs during their investigation process.
- E. Send a referral to Sanctions/List Screening, or similar department/responsible individual, to ensure that the customer due diligence information is up to date.
正解：B、E
解説：
Explanation
The investigator should proceed in this situation by conducting the investigation as usual, since the activity in question is not directly connected to the PEP (A) and sending a referral to Sanctions/List Screening, or similar department/responsible individual, to ensure that the customer due diligence information is up to date (D).
These actions are appropriate and prudent, as they allow the investigator to continue their analysis of the suspicious activity without being biased by the potential PEP status of the customer's relative, and they ensure that the FI has accurate and current information about its customers and their associates. According to the ACAMS Advanced Financial Crimes Investigations Certification Study Guide1, "the FI should conduct enhanced due diligence on all parties involved in the investigation, including checking various sources of information, such as watch lists, sanctions lists, negative news, and official registries" (p. 24). The FI should also "update the customer profile with any new information obtained during the investigation" (p. 25).
The other options are not correct. The investigator should not refer the newly identified customer's account for closure due to the high risk associated with the potential PEP (B), as this could be premature or disproportionate, as well as potentially discriminatory or illegal. The investigator should not file a SAR/STR due to the potential involvement of a PEP (E), as this could also be premature or unnecessary, as well as potentially misleading or inaccurate. The investigator should not use this case as an example to train employees to recognize potential PEPs during their investigation process , as this could violate confidentiality or data protection laws, as well as compromise the investigation or alert the customer or their relative of the suspicion.
References: 1: ACAMS Advanced Financial Crimes Investigations Certification Study Guide, available at ACAMS
質問 # 44
A retail bank prepares a yearly AML risk assessment. Which inherent risk factor is likely the most relevant?
- A. The provision of brokerage services
- B. The provision of remote check deposit services
- C. The provision of payable through accounts
- 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 # 45
Which statement most accurately characterizes the methods used by transnational criminal organizations?
- A. They routinely engage in many different types of criminal activities as long as they think it will benefit them.
- B. They see each other as competitors and rarely cooperate.
- C. They are likely to specialize in one particular method and continue to refine that method to escape detection.
- D. They are unlikely to associate with known terrorist organizations due to the reputational risks.
正解：A
解説：
Explanation
The statement that most accurately characterizes the methods used by transnational criminal organizations is that they routinely engage in many different types of criminal activities as long as they think it will benefit them . This is because transnational criminal organizations are flexible and adaptable, and they exploit opportunities and vulnerabilities in different markets and jurisdictions. According to ACAMS2, "Transnational criminal organizations are involved in a wide range of illicit activities, such as drug trafficking, human trafficking, arms trafficking, money laundering, cybercrime, environmental crime, fraud, corruption, and terrorism" (p. 3). They also "operate across borders and regions, using complex networks and structures to evade detection and prosecution" (p. 3).
The other statements are not as accurate or comprehensive as option C. Transnational criminal organizations are unlikely to associate with known terrorist organizations due to the reputational risks (A) is false, as transnational criminal organizations may collaborate or cooperate with terrorist organizations for mutual benefit or convenience, such as sharing resources, routes, or contacts. Transnational criminal organizations are likely to specialize in one particular method and continue to refine that method to escape detection (B) is false, as transnational criminal organizations may diversify or change their methods depending on the circumstances or opportunities, such as shifting products, markets, or modus operandi. Transnational criminal organizations see each other as competitors and rarely cooperate (D) is false, as transnational criminal organizations may form alliances or partnerships with other criminal groups for strategic or tactical reasons, such as sharing information, expertise, or influence.
質問 # 46
A SAR/STR on cash activity is filed for a company registered in the Marshall Islands operating a Mediterranean beach bar and hotel. The company has three nominee directors, one nominee shareholder, and another individual declared as both the beneficial owner and authorized signatory. Which information is key for law enforcement's physical surveillance of cash activity? (Select Two.)
- A. The company's operating address
- B. The identification details the nominee directors
- C. The identification details of the beneficial owner and authorized signatory
- D. The identification details o' the nominee shareholder
- E. The company's registered address
正解：A、C
解説：
Explanation
The identification details of the beneficial owner and authorized signatory are key for law enforcement's physical surveillance of cash activity, as they would help identify the person who controls and operates the company and who is responsible for its financial transactions. The company's operating address is also key, as it would help locate the premises where the cash activity takes place and observe any suspicious movements or behaviors. The identification details of the nominee shareholder and directors are not relevant, as they are not involved in the management or operation of the company. The company's registered address is also not relevant, as it is likely to be a shell or mailbox address that does not reflect the actual location of the business.
References: Advanced CAMS-FCI Study Guide, page 44-45; [FATF Guidance on Transparency and Beneficial Ownership], page 12-13.
質問 # 47
Which reputations risk consequence could a financial entity face for violating AML laws?
- A. Increased audit costs to monitor behavior
- B. Monetary penalties
- C. Loss of high-profile customers
- D. Seizure of assets
正解：B
質問 # 48
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