CAMS-KR 문제 176
정부 Financial Intelligence Unit은 어떤 두 가지 방법으로 공공 및 민간 부문과 상호 작용합니까?
(2개를 선택하세요.)
(2개를 선택하세요.)
정답: C,D
A government Financial Intelligence Unit (FIU) is a national body or agency that collects, analyzes, and disseminates information on suspicious or unusual financial activity related to money laundering, terrorist financing, or other financial crimes12. One of the main functions of an FIU is to receive and analyze disclosures or reports filed by financial and non-bank institutions, such as banks, casinos, money service businesses, lawyers, accountants, etc., that are obliged to report transactions or activities that may indicate money laundering or terrorist financing34. Another key function of an FIU is to disseminate the information and the results of its analysis to competent authorities, such as law enforcement, prosecutors, regulators, or other FIUs, for further investigation, prosecution, or preventive action56. These two ways of interaction enable the FIU to act as a bridge between the public and private sectors in the fight against financial crimes.
1: What are Financial Intelligence Units (FIUs)?, Dow Jones, 3; 2: Financial Intelligence Unit, Wikipedia, 2; 3: The Role of Financial Intelligence Units in Fighting Money Laundering and Terrorist Financing, IMF, 8; 4: What is an FIU?, Egmont Group of Financial Intelligence Units, [9]; 5: FIU Functions, FATF, [10]; 6: FIU.NET, Europol, [11].
Reference:http://pubdocs.worldbank.org/en/834721427730119379/AML-Module-2.pdf
1: What are Financial Intelligence Units (FIUs)?, Dow Jones, 3; 2: Financial Intelligence Unit, Wikipedia, 2; 3: The Role of Financial Intelligence Units in Fighting Money Laundering and Terrorist Financing, IMF, 8; 4: What is an FIU?, Egmont Group of Financial Intelligence Units, [9]; 5: FIU Functions, FATF, [10]; 6: FIU.NET, Europol, [11].
Reference:http://pubdocs.worldbank.org/en/834721427730119379/AML-Module-2.pdf
CAMS-KR 문제 177
테러 자금 조달 방지(CFT)
AML 교육 프로그램은 기본 개념을 넘어 다음과 같은 목표를 가진 교육을 제공해야 합니다.
AML 교육 프로그램은 기본 개념을 넘어 다음과 같은 목표를 가진 교육을 제공해야 합니다.
정답: A
A). Offering internal policies training: This is crucial. Employees need to understand the specific procedures and policies related to customer identification and verification. These internal policies ensure consistency and compliance.
B). Offering general background and history training: While historical context is valuable, it's not the primary focus. AML training should prioritize practical knowledge and current best practices.
C). Offering periodic refresher training: Absolutely! Regular refresher training keeps employees up-to-date with evolving AML regulations and reinforces their understanding.
D). Offering tailored training for specific roles: This is essential. Different roles require different expertise. For example, investigators need to recognize red flags, while report writers must understand how to create effective suspicious activity reports.
Comprehensive Detailed Explanation:
Internal Policies Training: AML training should cover internal policies thoroughly. This includes customer identification and verification procedures, as well as other relevant policies specific to the organization.
Employees need to understand how these policies translate into day-to-day practices.
General Background and History: While historical context can be interesting, it's not the primary focus of AML training. Instead, the emphasis should be on practical knowledge, current best practices, and real-world scenarios.
Periodic Refresher Training: Regular refresher training is essential. AML regulations evolve, and employees need to stay informed. Annual or periodic refreshers reinforce knowledge and ensure compliance.
Tailored Training for Specific Roles: Different roles within an organization have distinct responsibilities related to AML. Tailored training ensures that employees understand their specific duties. For example, investigators need to recognize suspicious patterns, while report writers must know how to create effective reports.
References:
Anti-Money Laundering Specialist (the 6th edition) resources.
ACAMS Certification Candidate Handbook
ACFCS AML 360 Certificate Program
B). Offering general background and history training: While historical context is valuable, it's not the primary focus. AML training should prioritize practical knowledge and current best practices.
C). Offering periodic refresher training: Absolutely! Regular refresher training keeps employees up-to-date with evolving AML regulations and reinforces their understanding.
D). Offering tailored training for specific roles: This is essential. Different roles require different expertise. For example, investigators need to recognize red flags, while report writers must understand how to create effective suspicious activity reports.
Comprehensive Detailed Explanation:
Internal Policies Training: AML training should cover internal policies thoroughly. This includes customer identification and verification procedures, as well as other relevant policies specific to the organization.
Employees need to understand how these policies translate into day-to-day practices.
General Background and History: While historical context can be interesting, it's not the primary focus of AML training. Instead, the emphasis should be on practical knowledge, current best practices, and real-world scenarios.
Periodic Refresher Training: Regular refresher training is essential. AML regulations evolve, and employees need to stay informed. Annual or periodic refreshers reinforce knowledge and ensure compliance.
Tailored Training for Specific Roles: Different roles within an organization have distinct responsibilities related to AML. Tailored training ensures that employees understand their specific duties. For example, investigators need to recognize suspicious patterns, while report writers must know how to create effective reports.
References:
Anti-Money Laundering Specialist (the 6th edition) resources.
ACAMS Certification Candidate Handbook
ACFCS AML 360 Certificate Program
CAMS-KR 문제 178
자금 서비스 사업(MSB)의 사업 운영을 검토할 때, 어떤 활동이 자금세탁 위험 신호로 간주될까요? (두 가지 선택)
정답: A,D
When reviewing business operations of a Money Services Business (MSB), it is critical to identify behaviors that indicate potential money laundering activity. TheCAMS Study Guide - 6th Editionoutlines severalred flagscommonly associated with MSBs.
Option Ais correct:
A customer beinghesitant to provide beneficiary information, such as the name or address, is a red flag. It may indicate attempts to hide the true purpose or recipient of the funds and could suggeststructuring or layering activity.
Option Dis correct:
A customer usingmultiple accounts under different namesto conduct transactions is a strong red flag. This could indicate efforts toobscure ownership, avoid detection, or conductsuspicious structuringbehavior to stay below reporting thresholds.
Option Bis incorrect:
While large cash deposits from cash-intensive businesses may require further review, they are not inherently suspicious unlessinconsistent with the nature of the business or transaction volume.
Option Cis incorrect:
Currency exchanges under the reporting threshold, even from high-risk jurisdictions, are not in themselves red flags unless they show a pattern ofstructuringor are part oflarger suspicious behavior.
Option Eis incorrect:
Frequent small-dollar transfers to a native country may benormal remittance behaviorand only become suspicious if tied to additional indicators such asstructuring or third-party involvement.
Reference: ACAMS CAMS Study Guide - 6th Edition, Chapter:Recognizing and Reporting Suspicious Activity- Section:Red Flags for Money Services Businesses
Option Ais correct:
A customer beinghesitant to provide beneficiary information, such as the name or address, is a red flag. It may indicate attempts to hide the true purpose or recipient of the funds and could suggeststructuring or layering activity.
Option Dis correct:
A customer usingmultiple accounts under different namesto conduct transactions is a strong red flag. This could indicate efforts toobscure ownership, avoid detection, or conductsuspicious structuringbehavior to stay below reporting thresholds.
Option Bis incorrect:
While large cash deposits from cash-intensive businesses may require further review, they are not inherently suspicious unlessinconsistent with the nature of the business or transaction volume.
Option Cis incorrect:
Currency exchanges under the reporting threshold, even from high-risk jurisdictions, are not in themselves red flags unless they show a pattern ofstructuringor are part oflarger suspicious behavior.
Option Eis incorrect:
Frequent small-dollar transfers to a native country may benormal remittance behaviorand only become suspicious if tied to additional indicators such asstructuring or third-party involvement.
Reference: ACAMS CAMS Study Guide - 6th Edition, Chapter:Recognizing and Reporting Suspicious Activity- Section:Red Flags for Money Services Businesses
CAMS-KR 문제 179
테러 자금 조달 방지(CFT)
은행 내 AML 규정 준수에 대한 의지를 입증하기 위해 이사회는 다음을 수행해야 합니다.
은행 내 AML 규정 준수에 대한 의지를 입증하기 위해 이사회는 다음을 수행해야 합니다.
정답: D
According to the Anti-Money Laundering Specialist (the 6th edition) resources, one of the essential elements of an effective AML program is the establishment of a written AML policy that sets out the bank's commitment to comply with the applicable AML laws and regulations, as well asthe roles and responsibilities of the board of directors, senior management, and staff in implementing the AML program. The AML policy should also include the bank's risk assessment, customer due diligence, transaction monitoring, record keeping, reporting, training, and audit procedures. The AML policy should be approved by the board of directors and communicated to all staff from the top down. The other options are not incorrect, but they are not the primary responsibility of the board of directors in demonstrating commitment to AML compliance.
References:
1: ACAMS Study Guide for the Certified Anti-Money Laundering Specialist (the 6th edition), Chapter 8: Anti- Money Laundering Programs, page 221.
2: ACAMS Study Guide for the Certified Anti-Money Laundering Specialist (the 6th edition), Chapter 8: Anti- Money Laundering Programs, page 224.
References:
1: ACAMS Study Guide for the Certified Anti-Money Laundering Specialist (the 6th edition), Chapter 8: Anti- Money Laundering Programs, page 221.
2: ACAMS Study Guide for the Certified Anti-Money Laundering Specialist (the 6th edition), Chapter 8: Anti- Money Laundering Programs, page 224.
CAMS-KR 문제 180
테러 자금 조달(CFT)
AML 준수 책임자는 여러 가지 조사 결과가 담긴 독립적인 감사 보고서를 받습니다.
보고서에 대한 적절한 대응은 다음과 같습니다.
AML 준수 책임자는 여러 가지 조사 결과가 담긴 독립적인 감사 보고서를 받습니다.
보고서에 대한 적절한 대응은 다음과 같습니다.
정답: D
AML audit findings must beanalyzed and addressed through remedial actions based on root cause analysis.
Option D (Correct):Root cause analysis helps develop effective corrective measures to prevent recurring AML deficiencies.
Option A (Incorrect):Retesting controls may be useful, but addressing deficiencies is more critical.
Option B (Incorrect):While the board oversees compliance, the responsibility for implementing fixes lies with AML teams.
Option C (Incorrect):Audit teams provide findings but do not execute corrective actions.
Best Practices for Addressing AML Audit Findings:
Identify the root cause of AML control failures.
Develop risk-based remediation plans.
Implement and monitor corrective actions.
Reference:
FATF Recommendation 18 (AML Internal Controls & Audit)
Basel Committee's Guidelines on AML Audits
Wolfsberg Group Principles for AML Risk Management
Final Thoughts:
Suspicious stock price movements can indicate market manipulation linked to money laundering.
EU AML and GDPR regulations enforce strict data minimization and AI compliance requirements.
Bearer shares, nominee directors, and tax-haven corporations increase money laundering risks.
AML audit findings should be addressed through root cause analysis and corrective actions.
Option D (Correct):Root cause analysis helps develop effective corrective measures to prevent recurring AML deficiencies.
Option A (Incorrect):Retesting controls may be useful, but addressing deficiencies is more critical.
Option B (Incorrect):While the board oversees compliance, the responsibility for implementing fixes lies with AML teams.
Option C (Incorrect):Audit teams provide findings but do not execute corrective actions.
Best Practices for Addressing AML Audit Findings:
Identify the root cause of AML control failures.
Develop risk-based remediation plans.
Implement and monitor corrective actions.
Reference:
FATF Recommendation 18 (AML Internal Controls & Audit)
Basel Committee's Guidelines on AML Audits
Wolfsberg Group Principles for AML Risk Management
Final Thoughts:
Suspicious stock price movements can indicate market manipulation linked to money laundering.
EU AML and GDPR regulations enforce strict data minimization and AI compliance requirements.
Bearer shares, nominee directors, and tax-haven corporations increase money laundering risks.
AML audit findings should be addressed through root cause analysis and corrective actions.
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