고객이 농산물 수출업을 운영하고 있습니다. 카리브해 지역 판매부터 수년에 걸쳐 꾸준한 성장을 이어왔습니다. 지난달에 이 고객의 계좌 잔액이 갑자기 증가한 것으로 나타났습니다.
자금세탁방지 전문가는 어떤 근거로 의심거래 보고서를 작성해야 합니까?
정답: D
The customer activity that should trigger a suspicious transaction report is purchasing travelers checks (cheques) for trips to a Non-Cooperative Countries and Territories (NCCTs). This could indicate an attempt to evade currency reporting requirements, avoid sanctions or embargoes, or facilitate money laundering or terrorist financing through high-risk jurisdictions12. NCCTs are countries or territories that have been identified by the Financial Action Task Force (FATF) as having serious deficiencies in their anti-money laundering and counter-terrorist financing regimes, and that pose a threat to the international financial system3.
The other options are not necessarily grounds for a suspicious transaction report, although they may require further due diligence or monitoring depending on the customer profile and the nature of the transaction. For example:
The increased activity is due to money order deposits. This could be a legitimate source of income for the customer's export business, or it could be a way of disguising the origin or destination of the funds. The anti-money laundering specialist should verify the identity and background of the customer and the issuers of the money orders, and check for any red flags or suspicious indicators4.
Wire transfers are coming from a Financial Action Task Force member country. This could be a normal business practice, or it could be a sign of involvement in trade-based money laundering or other illicit activities. The anti-money laundering specialist should assess the customer's source of funds, business rationale, and market conditions, and monitor for any changes or inconsistencies.
The client changed his address without advising the institution. This could be a simple oversight, or it could be a way of concealing the customer's true location or identity. The anti-money laundering specialist should update the customer's information, verify the new address, and check for any adverse media or sanctions.
Reference:
ACAMS CAMS Certification Video Training Course - Exam-Labs3
Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)4 ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 1, page 11: https://www.acams.org/wp-content/uploads/2019/08/ACAMS-Study-Guide-6th-Edition-Chapter-1.pdf ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 2, page 29: https://www.acams.org/wp-content/uploads/2019/08/ACAMS-Study-Guide-6th-Edition-Chapter-2.pdf ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 4, page 77: https://www.acams.org/wp-content/uploads/2019/08/ACAMS-Study-Guide-6th-Edition-Chapter-4.pdf ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 5, page 97: https://www.acams.org/wp-content/uploads/2019/08/ACAMS-Study-Guide-6th-Edition-Chapter-5.pdf
