CAMS-KR 문제 146
에그몽 그룹의 주요 목표는 무엇입니까?
정답: B
The Egmont Group is a united body of 174 Financial Intelligence Units (FIUs) that uniquely support national and international efforts to counter terrorist financing and share financial information per global anti-money laundering and counter-financing of terrorism (AML/CFT) standards. Its primary objective is to enhance international cooperation in the investigation and prosecution of money laundering and financing of terrorism. The Egmont Group facilitates the exchange of expertise and financial intelligence among FIUs to combat money laundering, terrorist financing, and associated predicate offenses. While it does not conduct financial investigations itself, it plays a crucial role in improving stakeholders' understanding of ML/TF risks and informing policy considerations related to AML/CFT implementation and reforms12.
CAMS-KR 문제 147
어떤 사람이 기관의 자금세탁 방지 프로그램에 대한 독립적인 테스트를 수행해야 합니까?
정답: C
According to the Anti-Money Laundering Specialist (the 6th edition) by ACAMS, the independent testing of an institution's anti-money laundering program should be conducted by a person who reports directly to the Board of Directors or a Board Committee. This ensures that the person conducting the testing has the necessary authority, independence, and objectivity to evaluate the program's adequacy and effectiveness, and to report any findings or recommendations to the senior management1. The person conducting the testing should also have the appropriate knowledge, skills, and experience in the anti-money laundering field, and should be familiar with the institution's products, services, customers, and risks2.
The other options are not necessarily suitable or qualified to perform the independent testing of an institution's anti-money laundering program. For example:
A certified specialist in the anti-money laundering field may have the relevant expertise and credentials, but may not have the required independence or reporting line to conduct the testing. For instance, if the certified specialist is an employee of the institution who is involved in the implementation or operation of the anti-money laundering program, then there may be a conflict of interest or a lack of objectivity in the testing process1.
A former anti-money laundering officer from a similar institution may have the relevant experience and background, but may not have the current knowledge or familiarity with the institution's anti-money laundering program, policies, procedures, or systems. Moreover, the former anti-money laundering officer may have a personal or professional relationship with the institution or its staff, which may compromise the independence or integrity of the testing process1.
A retired government regulator or federal law enforcement officer may have the relevant authority and credibility, but may not have the specific skills or qualifications to conduct the testing. For instance, the retired regulator or law enforcement officer may not be well-versed in the latest anti-money laundering standards, regulations, or best practices, or may not be able to apply them to the institution's unique risk profile, products, services, or customers1.
Reference:
Anti-Money Laundering Specialist (the 6th edition) by ACAMS
What Is An AML Compliance Program? | ComplyAdvantage
The other options are not necessarily suitable or qualified to perform the independent testing of an institution's anti-money laundering program. For example:
A certified specialist in the anti-money laundering field may have the relevant expertise and credentials, but may not have the required independence or reporting line to conduct the testing. For instance, if the certified specialist is an employee of the institution who is involved in the implementation or operation of the anti-money laundering program, then there may be a conflict of interest or a lack of objectivity in the testing process1.
A former anti-money laundering officer from a similar institution may have the relevant experience and background, but may not have the current knowledge or familiarity with the institution's anti-money laundering program, policies, procedures, or systems. Moreover, the former anti-money laundering officer may have a personal or professional relationship with the institution or its staff, which may compromise the independence or integrity of the testing process1.
A retired government regulator or federal law enforcement officer may have the relevant authority and credibility, but may not have the specific skills or qualifications to conduct the testing. For instance, the retired regulator or law enforcement officer may not be well-versed in the latest anti-money laundering standards, regulations, or best practices, or may not be able to apply them to the institution's unique risk profile, products, services, or customers1.
Reference:
Anti-Money Laundering Specialist (the 6th edition) by ACAMS
What Is An AML Compliance Program? | ComplyAdvantage
CAMS-KR 문제 148
제재 규제 제도가 없는 국가에서는 어떻게 인식을 제고할 수 있습니까? (2가지를 선택하세요.)
정답: B,D
Many jurisdictions lack robust sanctions frameworks, requiring international cooperation and education to improve compliance.
Option B (Correct): Educational initiatives such as AML/sanctions training and workshops help raise awareness and build capacity.
Option D (Correct): Bilateral cooperation allows knowledge-sharing and technical assistance between regulatory authorities.
Why Other Options Are Incorrect:
Option A (Incorrect): Trade restrictions may pressure non-compliant nations, but they do not directly improve sanctions awareness.
Option C (Incorrect): Enforcing fines without prior education or assistance is ineffective and may create diplomatic tensions.
Best Practices for Sanctions Awareness & Compliance:
Develop international AML/sanctions training programs for emerging markets.
Encourage diplomatic engagement to strengthen legal frameworks.
Leverage FATF's Mutual Evaluation process to assess progress.
Reference:
FATF Recommendation 6 (Sanctions & International Cooperation)
OFAC Guidance on Sanctions Compliance for Emerging Jurisdictions
Egmont Group Guidelines on Information Sharing & Capacity Building
Option B (Correct): Educational initiatives such as AML/sanctions training and workshops help raise awareness and build capacity.
Option D (Correct): Bilateral cooperation allows knowledge-sharing and technical assistance between regulatory authorities.
Why Other Options Are Incorrect:
Option A (Incorrect): Trade restrictions may pressure non-compliant nations, but they do not directly improve sanctions awareness.
Option C (Incorrect): Enforcing fines without prior education or assistance is ineffective and may create diplomatic tensions.
Best Practices for Sanctions Awareness & Compliance:
Develop international AML/sanctions training programs for emerging markets.
Encourage diplomatic engagement to strengthen legal frameworks.
Leverage FATF's Mutual Evaluation process to assess progress.
Reference:
FATF Recommendation 6 (Sanctions & International Cooperation)
OFAC Guidance on Sanctions Compliance for Emerging Jurisdictions
Egmont Group Guidelines on Information Sharing & Capacity Building
CAMS-KR 문제 149
다음 중 금융 기관에서 수행되는 활동 중 보고 기준점을 회피하는 가장 강력한 예는 무엇입니까?
정답: C
Conducting small cash transactions at multiple locations during the same day is the strongest example of avoiding reporting thresholds. This is a common technique used by money launderers to evade the attention of financial institutions and regulators, who are required to report cash transactions above a certain amount (usually $10,000) to the authorities. By splitting the large sum of money into smaller amounts and depositing them at different branches or ATMs, the money launderer can avoid triggering the reporting requirement and conceal the source and destination of the funds. This practice is also known as smurfing or structuring12.
Reference:
ACAMS CAMS Certification Study Guide, 6th Edition, Chapter 2, page 36
ACAMS CAMS Certification Video Training Course, Module 2, Lesson 2.2, Structuring and Smurfing
1, Smurfing Money Laundering: Mechanics, Detection, and Prevention
2, AML & eWallets - The Risks & How To Comply | ComplyAdvantage
Reference:
ACAMS CAMS Certification Study Guide, 6th Edition, Chapter 2, page 36
ACAMS CAMS Certification Video Training Course, Module 2, Lesson 2.2, Structuring and Smurfing
1, Smurfing Money Laundering: Mechanics, Detection, and Prevention
2, AML & eWallets - The Risks & How To Comply | ComplyAdvantage
CAMS-KR 문제 150
미국의 특정 불법 행위(SUA)에 대한 설명으로 옳지 않은 것은?
정답: A
According to 18 U.S.C. § 1956, the money laundering statute, the property involved in a financial transaction must represent the proceeds of some form of unlawful activity, which is defined as a specified unlawful activity (SUA). SUAs include over 250 crimes in six categories, such as RICO predicate offenses, certain offenses against foreign nations, acts constituting a criminal enterprise under the Controlled Substances Act, and federal health care offenses. Therefore, in order to pursue a money laundering conviction, the government must prove that at least one SUA was committed and that the property involved in the transaction was derived from that SUA.
Reference:
18 U.S. Code § 1956 - Laundering of monetary instruments, (a)(1) and ©(7).
957. Money Laundering-18 U.S.C. §§ 1956 & 1957, first paragraph.
Specified Unlawful Activities (SUA), first paragraph.
Reference:
18 U.S. Code § 1956 - Laundering of monetary instruments, (a)(1) and ©(7).
957. Money Laundering-18 U.S.C. §§ 1956 & 1957, first paragraph.
Specified Unlawful Activities (SUA), first paragraph.
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