CAMS-KR 문제 171
자금 세탁 방지 전문가는 특정 지점에서 의심스러운 거래 보고서 제출이 크게 감소했다고 말합니다. 다음 조치 중 가장 적절한 것은?
정답: C
A significant reduction in suspicious transaction report (STR) filings at a particular branch could indicate that the branch is not properly identifying and reporting suspicious activities, or that the branch is experiencing a change in customer behavior or risk profile. Therefore, the most appropriate action for an anti-money laundering specialist is to review the branch exception reports, which are reports that highlight transactions or activities that deviate from the expected or normal patterns, based on the customer profiles and risk assessments. By reviewing the branch exception reports, the specialist can determine whether there are any changes in activity that warrant further investigation or reporting, or whether there are any gaps or weaknesses in the branch's compliance program or procedures.
The other options are not as appropriate as reviewing the branch exception reports, as they do not directly address the issue of suspicious activity reporting. Placing the branch on the watchlist may be a subsequent action, but it does not provide immediate insight into the reason for the reduction in STR filings. Analyzing the branch activity reports may show whether there has been a decrease in branch activity, but it does not explain why the activity has decreased, or whether the remaining activity is suspicious or not. Reviewing the staff records may reveal whether inexperienced personnel are in critical positions without appropriate training, but it does not account for other factors that may affect the branch's compliance performance, such as management oversight, internal controls, or customer risk.
ACAMS CAMS Certification Study Guide (6th edition), page 361; ACAMS CAMS Certification Video Training Course, Module 2, Lesson 12; What Is a Suspicious Activity Report (SAR)? Triggers and Filing3; Reporting suspicious transactions to FINTRAC4.
The other options are not as appropriate as reviewing the branch exception reports, as they do not directly address the issue of suspicious activity reporting. Placing the branch on the watchlist may be a subsequent action, but it does not provide immediate insight into the reason for the reduction in STR filings. Analyzing the branch activity reports may show whether there has been a decrease in branch activity, but it does not explain why the activity has decreased, or whether the remaining activity is suspicious or not. Reviewing the staff records may reveal whether inexperienced personnel are in critical positions without appropriate training, but it does not account for other factors that may affect the branch's compliance performance, such as management oversight, internal controls, or customer risk.
ACAMS CAMS Certification Study Guide (6th edition), page 361; ACAMS CAMS Certification Video Training Course, Module 2, Lesson 12; What Is a Suspicious Activity Report (SAR)? Triggers and Filing3; Reporting suspicious transactions to FINTRAC4.
CAMS-KR 문제 172
기관의 자금 세탁 방지 프로그램이 최신 상태인지 확인하려면 어떤 조치를 취해야 합니까?
정답: D
According to the Anti-Money Laundering Specialist (the 6th edition) by ACAMS, an institution's anti-money laundering program should be reassessed at least annually to ensure that it is current, effective, and compliant with the applicable laws and regulations. The reassessment should include a review of the institution's risk assessment, policies and procedures, internal controls, training, and independent testing. The reassessment should also consider any changes in the institution's products, services, customers, geographic locations, or business environment that may affect its exposure to money laundering and terrorist financing risks1.
The other options are not consistent with the best practices of maintaining an up-to-date anti-money laundering program. For example:
The program should be evaluated and updated at least every six months by the Board of Directors. While the Board of Directors has the ultimate responsibility for overseeing the institution's anti-money laundering program, it is not required to evaluate and update the program every six months. This may be too frequent and impractical, especially for large and complex institutions. The Board of Directors should, however, approve the program and any significant changes, and ensure that senior management implements and enforces the program effectively1.
The program should be reviewed by a federal law enforcement officer for gaps in controls. While federal law enforcement agencies may conduct investigations or examinations of the institution's anti-money laundering program, they are not responsible for reviewing the program for gaps in controls. This is the role of the institution's internal audit function or an external independent party, who should conduct periodic testing of the program's adequacy and effectiveness1.
The program should be sent to the institution's government regulator on a periodic basis. While the institution' s government regulator may request or review the institution's anti-money laundering program as part of its supervisory or enforcement activities, the institution is not obligated to send the program to the regulator on a periodic basis. The institution should, however, report any suspicious or unusual transactions or activities to the relevant authorities, such as the Financial Crimes Enforcement Network (FinCEN) or the Office of Foreign Assets Control (OFAC)1.
Anti-Money Laundering Specialist (the 6th edition) by ACAMS
The other options are not consistent with the best practices of maintaining an up-to-date anti-money laundering program. For example:
The program should be evaluated and updated at least every six months by the Board of Directors. While the Board of Directors has the ultimate responsibility for overseeing the institution's anti-money laundering program, it is not required to evaluate and update the program every six months. This may be too frequent and impractical, especially for large and complex institutions. The Board of Directors should, however, approve the program and any significant changes, and ensure that senior management implements and enforces the program effectively1.
The program should be reviewed by a federal law enforcement officer for gaps in controls. While federal law enforcement agencies may conduct investigations or examinations of the institution's anti-money laundering program, they are not responsible for reviewing the program for gaps in controls. This is the role of the institution's internal audit function or an external independent party, who should conduct periodic testing of the program's adequacy and effectiveness1.
The program should be sent to the institution's government regulator on a periodic basis. While the institution' s government regulator may request or review the institution's anti-money laundering program as part of its supervisory or enforcement activities, the institution is not obligated to send the program to the regulator on a periodic basis. The institution should, however, report any suspicious or unusual transactions or activities to the relevant authorities, such as the Financial Crimes Enforcement Network (FinCEN) or the Office of Foreign Assets Control (OFAC)1.
Anti-Money Laundering Specialist (the 6th edition) by ACAMS
CAMS-KR 문제 173
은행 직원이 돈세탁에 관여할 가능성이 있음을 나타내는 위험 신호는 무엇입니까? (2개를 선택합니다.)
정답: A,E
The two red flags indicating potential engagement of a bank employee in money laundering are A. Lavish lifestyle that cannot be supported by an employee's salary, and E. Maintaining friendships with customers and going to restaurants, games, and other events. A bank employee who has a lifestyle that cannot be supported by their salary could be receiving money from illicit activities. Similarly, if the employee is maintaining friendships and going to social events with customers, they could be receiving money in exchange for providing special services. These behaviors should be monitored closely to ensure that the employee is not engaging in activities that could be linked to money laundering.
CAMS-KR 문제 174
자금 세탁 방지 전문가는 자금 세탁 및 테러 자금 조달을 감지하고 방지하기 위한 규정 준수 프로그램을 수립하도록 요청받았습니다. 다음 중 자금세탁 방지 전문가가 프로그램을 개발할 때 고려해야 할 사항은 무엇입니까?
1. 자금 세탁 및 테러 자금 조달을 위한 자금은 불법 출처에서 파생됩니다.
2. 자금의 성격을 은폐하기 위해 관련 관행을 사용합니다.
3. 자금의 출처와 처분이 유사하다.
4. 유사한 기술이 자금을 이동하는 데 사용됩니다.
1. 자금 세탁 및 테러 자금 조달을 위한 자금은 불법 출처에서 파생됩니다.
2. 자금의 성격을 은폐하기 위해 관련 관행을 사용합니다.
3. 자금의 출처와 처분이 유사하다.
4. 유사한 기술이 자금을 이동하는 데 사용됩니다.
정답: C
Money laundering and terrorist financing are both forms of financial crime that involve the movement of illicit funds. However, they differ in the source and purpose of the funds. Money laundering is the process of disguising the origin, ownership, or destination of funds that are derived from illegal activities, such as drug trafficking, fraud, or tax evasion. Terrorist financing is the provision or collection of funds, by legitimate or illegitimate means, for the purpose of carrying out terrorist acts. Therefore, the anti-money laundering specialist should consider the following factors in developing a compliance program:
Related practices are used to conceal the nature of the funds. Both money launderers and terrorist financiers use similar methods to hide the true identity, source, or destination of the funds, such as using shell companies, front organizations, complex transactions, cash couriers, or cryptoassets. A compliance program should include measures to identify and verify the customers, beneficial owners, and counterparties involved in the transactions, as well as to monitor and report any suspicious or unusual activities.
Similar techniques are used to move funds. Both money launderers and terrorist financiers use the same stages of placement, layering, and integration to move funds through the financial system. Placement is the introduction of illicit funds into the legitimate financial system, such as by depositing cash, purchasing assets, or transferring funds electronically. Layering is the separation of the funds from their source, such as by using multiple accounts, jurisdictions, or intermediaries. Integration is the re-entry of the funds into the legitimate economy, such as by investing in businesses, real estate, or securities. A compliance program should include measures to detect and prevent the movement of illicit funds through the financial system, such as by applying risk-based due diligence, record-keeping, and transaction limits.
CAMS Certification Package - 6th Edition | ACAMS
CAMS Certifications: How to Get CAMS Certified | ACAMS
ACAMS CAMS Certification Video Training Course - Exam-Labs
Exam CAMS: Certified Anti-Money Laundering Specialist (the6th edition)
Related practices are used to conceal the nature of the funds. Both money launderers and terrorist financiers use similar methods to hide the true identity, source, or destination of the funds, such as using shell companies, front organizations, complex transactions, cash couriers, or cryptoassets. A compliance program should include measures to identify and verify the customers, beneficial owners, and counterparties involved in the transactions, as well as to monitor and report any suspicious or unusual activities.
Similar techniques are used to move funds. Both money launderers and terrorist financiers use the same stages of placement, layering, and integration to move funds through the financial system. Placement is the introduction of illicit funds into the legitimate financial system, such as by depositing cash, purchasing assets, or transferring funds electronically. Layering is the separation of the funds from their source, such as by using multiple accounts, jurisdictions, or intermediaries. Integration is the re-entry of the funds into the legitimate economy, such as by investing in businesses, real estate, or securities. A compliance program should include measures to detect and prevent the movement of illicit funds through the financial system, such as by applying risk-based due diligence, record-keeping, and transaction limits.
CAMS Certification Package - 6th Edition | ACAMS
CAMS Certifications: How to Get CAMS Certified | ACAMS
ACAMS CAMS Certification Video Training Course - Exam-Labs
Exam CAMS: Certified Anti-Money Laundering Specialist (the6th edition)
CAMS-KR 문제 175
테러 자금 조달 방지(CFT)
구조화된 거래를 감지하는 데 사용되는 가장 효과적인 도구는 다음과 같습니다.
구조화된 거래를 감지하는 데 사용되는 가장 효과적인 도구는 다음과 같습니다.
정답: D
Structured transactions are a common method of money laundering, where large amounts of cash are broken down into smaller deposits or withdrawals to avoid reporting thresholds or detection. The most effective tool to detect such transactions is a software program that can link apparently unrelated transactions by using various criteria, such as customer name, address, account number, identification number, transaction amount, date, time, location, etc. Such a program can help identify patterns, trends, and anomalies that may indicate money laundering activity.
ACAMS CAMS Certification Study Guide1, Chapter 2: Money Laundering Risks and Methods, Section 2.2:
Common Money Laundering Methods, pp. 51-52
ACAMS CAMS Certification Video Training Course2, Module 2: Money Laundering Risks and Methods, Lesson 2.2: Common Money Laundering Methods ACAMS CAMS Certification Exam Outline3, Domain 2: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), Task 2.2: Implement risk-based CDD, EDD and ongoing due diligence policies, procedures and processes, p. 13
ACAMS CAMS Certification Study Guide1, Chapter 2: Money Laundering Risks and Methods, Section 2.2:
Common Money Laundering Methods, pp. 51-52
ACAMS CAMS Certification Video Training Course2, Module 2: Money Laundering Risks and Methods, Lesson 2.2: Common Money Laundering Methods ACAMS CAMS Certification Exam Outline3, Domain 2: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), Task 2.2: Implement risk-based CDD, EDD and ongoing due diligence policies, procedures and processes, p. 13
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