CAMS-KR 문제 91
온라인 도박을 통한 자금 세탁 가능성의 위험 신호는 무엇입니까? (2개를 선택하세요.)
정답: B,E
According to the research report by the Council of Europe1, one of the typologies of money laundering through online gambling is the use of multiple accounts and identities to conceal the source and destination of funds. This can be done by opening several accounts under the same name using different IP addresses, or by using false or stolen identification documents to create multiple accounts. Another typology is the use of online gambling platforms that are not regulated or authorized by the jurisdiction where the customer is located, or that do not require know-your-client information from users. This can allow money launderers to access the online gambling services from multiple countries, without being subject to any verification or monitoring by the authorities.
References:
1: Research report - The use of online gambling for money laundering and the financing of terrorism purposes, Council of Europe, April 2013.
References:
1: Research report - The use of online gambling for money laundering and the financing of terrorism purposes, Council of Europe, April 2013.
CAMS-KR 문제 92
다음 중 자금세탁의 재정적 단계는?
정답: D
According to the CAMS study guide, chapter 1, page 91, placement is the first stage of money laundering, where the illicit funds are introduced into the financial system. This stage involves the highest risk of detection, as the money launderers may use various methods to avoid suspicion, such as structuring, commingling, or using cash-intensive businesses. Placement is followed by layering and integration, which are the second and third stages of money laundering, where the illicit funds are moved and disguised through multiple transactions and entities, and then integrated into the legitimate economy as seemingly legal assets.
The other options are not the financial stages of money laundering, although they may be related to some aspects or techniques of money laundering. Option A, integration, is the final stage of money laundering, not the first. Option B, structuring, is a method of placement, not a stage of money laundering. Structuring, also known as smurfing, is the practice of breaking down large amounts of cash into smaller deposits or transactions to avoid reporting thresholds or scrutiny. Option C, off shoring, is a term that refers to the relocation of assets or activities to another jurisdiction, usually for tax or regulatory advantages. Off shoring may be used by money launderers to exploit the differences or loopholes between jurisdictions, but it is not a stage of money laundering.
References:
1: ACAMS CAMS Study Guide - 6th Edition, Chapter 1, page 9:
https://www.acams.org/wp-content/uploads/2019/09/ACAMS-CAMS-Study-Guide-6th-Edition-Chapter-1.pdf
The other options are not the financial stages of money laundering, although they may be related to some aspects or techniques of money laundering. Option A, integration, is the final stage of money laundering, not the first. Option B, structuring, is a method of placement, not a stage of money laundering. Structuring, also known as smurfing, is the practice of breaking down large amounts of cash into smaller deposits or transactions to avoid reporting thresholds or scrutiny. Option C, off shoring, is a term that refers to the relocation of assets or activities to another jurisdiction, usually for tax or regulatory advantages. Off shoring may be used by money launderers to exploit the differences or loopholes between jurisdictions, but it is not a stage of money laundering.
References:
1: ACAMS CAMS Study Guide - 6th Edition, Chapter 1, page 9:
https://www.acams.org/wp-content/uploads/2019/09/ACAMS-CAMS-Study-Guide-6th-Edition-Chapter-1.pdf
CAMS-KR 문제 93
법 집행 기관은 은행에 고객 중 한 명에 관한 정보 요청을 제출했습니다.
금융 조치 태스크포스 지침에 따라 은행은 어떻게 대응해야 합니까?
금융 조치 태스크포스 지침에 따라 은행은 어떻게 대응해야 합니까?
정답: B
According to the ACAMS Study Guide 6th Edition, Chapter 2, page 37, one of the red flags of money laundering or terrorist financing is the use of nominees, trusts, or third parties to hide the identity, ownership, or control of the funds or assets involved in the transaction. Nominees are individuals or entities that act on behalf of the actual or beneficial owners of a company, trust, or account, and may be used to conceal the source, destination, or purpose of the funds or assets. Nominees may also be used to evade taxes, sanctions, or regulatory requirements.
In this case, the compliance officer is unable to verify the identity of the beneficial owners of the company, and only information on the nominee owners was provided. This raises the suspicion that the company may be involved in money laundering or terrorist financing activities, and that the nominee owners may be acting as fronts or intermediaries for the actual or beneficial owners. The compliance officer should conduct further due diligence on the company, the nominee owners, and the beneficial owners, and report any suspicious or unusual activity to the relevant authorities.
References:
ACAMS Study Guide 6th Edition, Chapter 2, page 37
Beneficial Ownership Meaning and Regulation - Investopedia
What is a nominee shareholder? | LawBite
In this case, the compliance officer is unable to verify the identity of the beneficial owners of the company, and only information on the nominee owners was provided. This raises the suspicion that the company may be involved in money laundering or terrorist financing activities, and that the nominee owners may be acting as fronts or intermediaries for the actual or beneficial owners. The compliance officer should conduct further due diligence on the company, the nominee owners, and the beneficial owners, and report any suspicious or unusual activity to the relevant authorities.
References:
ACAMS Study Guide 6th Edition, Chapter 2, page 37
Beneficial Ownership Meaning and Regulation - Investopedia
What is a nominee shareholder? | LawBite
CAMS-KR 문제 94
금융기관이 개편되어 이제 자금세탁방지담당관이 영업이사에게 보고해야 합니다. 이 상황에 대한 다음 설명 중 가장 옳은 것은 무엇입니까?
정답: D
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."
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."
CAMS-KR 문제 95
규정 준수 담당자는 IT(정보 기술) 소스에서 신제품 승인 위원회에서 논의 중인 잠재적인 새로운 금융 서비스에 대해 알아봅니다.
올바른 다음 조치는 무엇입니까?
올바른 다음 조치는 무엇입니까?
정답: A
The correct next course of action is to request that the new product approval committee include the compliance officer. This is because the compliance officer has the responsibility to ensure that the new financial service complies with the applicable laws, regulations, and standards, and does not pose any undue risks to the institution or its customers. The compliance officer should be involved in the new product development process from the beginning, and provide guidance and feedback on the potential compliance implications and requirements of the new service12.
References:
1: CAMS Certification Package - 6th Edition | ACAMS, Chapter 6: Developing an Effective Anti-Money Laundering Program, p. 121-122 2:
FATF Guidance: The Role of Hawala and Other Similar Service Providers in Money Laundering and Terrorist Financing, October 2013, p. 28,
http://www.fatf-gafi.org/media/fatf/documents/reports/Role-of-hawala-and-similar-in-ml-tf.pdf
References:
1: CAMS Certification Package - 6th Edition | ACAMS, Chapter 6: Developing an Effective Anti-Money Laundering Program, p. 121-122 2:
FATF Guidance: The Role of Hawala and Other Similar Service Providers in Money Laundering and Terrorist Financing, October 2013, p. 28,
http://www.fatf-gafi.org/media/fatf/documents/reports/Role-of-hawala-and-similar-in-ml-tf.pdf
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