CAMS-KR 문제 251
References:
1: Enterprise Compliance Risk Management Services | Deloitte US
2: Enterprise Risk Management and Risk Culture - McKinsey & Company
3: FRB: Speech, Bies-Enterprise-wide Compliance Programs-February 4, 2004 Reference:
https://www.ifc.org/wps/wcm/connect/e7e10e94-3cd8-4f4c-b6f8-1e14ea9eff80/45464_IFC_AML_Report.pdf?M (51)
CAMS-KR 문제 252
1: ACAMS Study Guide for the CAMS Certification Examination, 6th Edition, Chapter 4, page 137
2: USA PATRIOT Act, Title III, Section 319(b)
CAMS-KR 문제 253
Limited types of institutions and persons covered by money laundering laws and regulations. This means that only a narrow range of financial activities or entities are subject to anti-money laundering (AML) and combatting the financing of terrorism (CFT) obligations, such as customer due diligence, record-keeping, reporting, and supervision. For example, some havens may exclude lawyers, accountants, trust and company service providers, or non-bank financial institutions from AML/CFT requirements.
Little enforcement of the laws, weak penalties or provisions that make it difficult to confiscate or freeze assets related to money laundering. This means that the authorities in these havens lack the political will, resources, or capacity to effectively implement and enforce the AML/CFT laws and regulations. They may also impose low sanctions or fines for non-compliance, or create legal barriers or obstacles for the confiscation or freezing of assets that are the proceeds of, or used in, or intended or allocated for use in, money laundering, terrorist financing, or other crimes.
Absence of an effective FIU. This means that these havens do not have a central agency that is responsible for receiving, analyzing, and disseminating financial intelligence related to money laundering, terrorist financing, and other crimes. An effective FIU is essential for facilitating domestic and international cooperation and information exchange, as well as for supporting investigations and prosecutions of money laundering and terrorist financing cases.
References:
1: The IMF and the Fight Against Money Laundering and Terrorism Financing, 1 2: IX Special Recommendations, 2
CAMS-KR 문제 254
References:
ACAMS Study Guide, 6th Edition, page 191
Which statement about a multinational institution's ability to fully investigate unusual activity in all its foreign operations is correct? - Exam4Training Learn more
1blob:https://www.bing.com/12e36647-a7b4-48a5-9dff-13e7aab69e80
quizlet.com2blob:https://www.bing.com/2c9f865a-c41c-4acb-9e08-acb661cdbbe3 exam4training.com3blob:https://www.bing.com/2c9f865a-c41c-4acb-9e08-acb661cdbbe3 exam4training.com4blob:https://www.bing.com/12e36647-a7b4-48a5-9dff-13e7aab69e80 quizlet.com A multinational institution may face challenges in conducting a full investigation of unusual activity across its foreign operations, due to the different legal and regulatory frameworks that apply in each jurisdiction. One of the main obstacles is the local privacy and data protection laws that may restrict the access, transfer, or disclosure of customer information, especially personal or sensitive data, to other entities within the same group or to external parties, such as law enforcement or regulators. Therefore, the institution should be aware of the local laws and regulations that govern the collection, processing, and sharing of customer data, and ensure compliance with them12.
References:
ACAMS Study Guide, 6th Edition, page 191
Which statement about a multinational institution's ability to fully investigate unusual activity in all its foreign operations is correct? - Exam4Training
CAMS-KR 문제 255
사설 은행에 대한 Wolfsberg 자금 세탁 방지 원칙과 일치시키기 위해 중개자에 대한 정책에 어떤 두 가지 측면이 포함되어야 합니까? (2개를 선택하세요.)
The bank should perform due diligence on the intermediary itself, including its ownership, reputation, regulatory status, and AML policies and procedures.
The bank should obtain the identity and beneficial ownership information of the clients introduced or managed by the intermediary, and verify them using reliable and independent sources, unless there are legal or regulatory impediments to do so.
The bank should assess the level of due diligence performed by the intermediary on its clients, and determine whether it is equivalent or comparable to the bank's own standards. If not, the bank should perform additional due diligence on the intermediary's clients, or decline to accept them.
The bank should monitor the transactions and activities of the clients introduced or managed by the intermediary, and report any suspicious or unusual activity to the relevant authorities.
Option B is consistent with these aspects, as it states that the bank must obtain the same type of information with respect to an introduced client that would otherwise be obtained by the bank, absent the involvement of the intermediary. This ensures that the bank has a sufficient understanding of the client's identity, source of wealth, and risk profile, and can apply appropriate AML measures.
Option C is also consistent with these aspects, as it states that where an intermediary manages assets on behalf of a number of clients and is the account holder with the bank, but that intermediary does not conduct the same level of due diligence as the bank, it is necessary for the bank to undertake due diligence on the intermediary's clients. This ensures that the bank does not rely solely on the intermediary's due diligence, and can identify and mitigate any potential money laundering risks associated with the clients.
Option A is not consistent with these aspects, as it states that when an intermediary introduces clients to the bank, it is not necessary for the bank to perform due diligence on the intermediary's clients. This contradicts the principle that the bank should obtain and verify the identity and beneficial ownership information of the clients introduced by the intermediary, unless there are legal or regulatory impediments to do so.
Option D is also not consistent with these aspects, as it states that where an intermediary manages assets on behalf of a number of clients and arranges for the opening of accounts for its clients with the bank, and that intermediary is a financial institution subject to similar regulations, it is necessary for the bank to perform due diligence on the intermediary's clients. This contradicts the principle that the bank may rely on the due diligence performed by the intermediary on its clients, if the intermediary is a regulated financial institution that applies equivalent or comparable AML standards to the bank, and if the bank has access to the relevant information and documentation.
References:
1: Wolfsberg Anti-Money Laundering Principles for Private Banking (2012), Section 3: Intermediaries
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