CAMS-KR 문제 106
생명보험 사업과 관련하여, 제3유럽 지침은 회원국이 사업 관계가 확립된 후에 보험금 수혜자의 신원 확인을 허용할 수 있다고 명시하고 있지만, 어떤 사건 이전에는 그럴 수 있을까요?
the beneficiary is identified as a natural or legal person or a legal arrangement, and the verification of the identity is not possible earlier, due to the nature of the product or the transaction; there is a low risk of money laundering or terrorist financing, taking into account the type of policy, the product features, the premium amount, and the distribution channel; the Member States adopt appropriate risk-sensitive measures to prevent the misuse of the policy during the life of the relationship.
This provision is intended to accommodate the specificities of the life insurance sector, where the beneficiary may not be known at the time of the conclusion of the contract, or may change during the life of the policy.
However, the Directive also requires that the identity verification of the beneficiary is carried out as soon as possible after the establishment of the business relationship, and that the insurance undertaking applies enhanced customer due diligence measures when the beneficiary is a politically exposed person.
1: Directive 2005/60/EC of the European Parliament and of the Council of 26 October 2005 on the prevention of the use of the financial system for the purpose of money laundering and terrorist financing (OJ L 309,
25.11.2005, p. 15) 2
CAMS-KR 문제 107
Option A is not an example of structuring, but of using an alternative remittance system, which is a method of transferring money outside the formal financial sector. Hawala is a type of alternative remittance system that relies on a network of brokers who settle the transactions through trust and honor. Hawala can be used for legitimate purposes, but also poses a risk for money laundering and terrorist financing13.
Option B is not an example of structuring, but of a large cash transaction, which is a common indicator of money laundering. Large cash transactions may involve the proceeds of crime or the attempt to evade taxes or currency controls. Financial institutions are required to report large cash transactions above a certain threshold to the relevant authorities14.
Option D is not an example of structuring, but of a wire transfer, which is a method of moving funds electronically from one account to another. Wire transfers can be used for legitimate purposes, but also pose a risk for money laundering and terrorist financing, especially if they involve high-risk jurisdictions, shell companies, or complex chains of transactions1 .
References: 1: ACAMS (2020), Study Guide for the Certification Examination, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams-certification-package-6th-edition, pp. 12-14, 18-19, 22-23, 26-27. 2:
ACAMS (2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.
acams.org/en/cams-certification-package-6th-edition, Module 1, Section 1.2.2. 3: ACAMS (2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams- certification-package-6th-edition, Module 1, Section 1.2.3. 4: ACAMS (2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams-certification-package-
6th-edition, Module 1, Section 1.2.1. : ACAMS (2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams-certification-package-6th-edition, Module 1, Section
1.2.4.
CAMS-KR 문제 108
The quality of the respondent's AML and client identification controls: The correspondent should assess the adequacy and effectiveness of the respondent's AML policies, procedures, and systems, as well as its compliance with applicable AML laws and regulations. The correspondent should also verify that the respondent has implemented appropriate customer identification and verification measures, and that it maintains sufficient records of its customers and transactions.
A risk-based determination as to whether or not the respondent is a shell bank: The correspondent should ensure that the respondent is not a shell bank, which is defined as a bank that has no physical presence in any country and is not affiliated with a regulated financial group. The correspondent should also avoid establishing or maintaining relationships with banks that are known to allow their accounts to be used by shell banks.
Whether a Politically Exposed Person (PEP) has an interest or management role in the respondent: The correspondent should identify and assess the potential risks associated with any PEPs who have an ownership or management interest in the respondent, or who are customers of the respondent. The correspondent should apply enhanced scrutiny and monitoring to such relationships, and obtain senior management approval before establishing or continuing them.
Wolfsberg Correspondent Banking Principles 2022 by the Wolfsberg Group, October 2022.
Reference:http://www.fatf-gafi.org/media/fatf/documents/reports/RBA%20Guidance%20for%20Real%
20Estate%20Agents.pdf(page
20, second paragraph)
CAMS-KR 문제 109
에그몬트 그룹의 주요 목표는 무엇입니까?
"The Egmont Group is a united body of 165 Financial Intelligence Units (FIUs). The Egmont Group provides a platform for the secure exchange of expertise and financial intelligence to combat money laundering and terrorist financing (ML/TF). This is especially relevant as FIUs are uniquely positioned to cooperate and support national and international efforts to counter terrorist financing and are the trusted gateway for sharing financial information domestically and internationally in accordance with global Anti Money Laundering and Counter Financing of Terrorism (AML/CFT) standards.
CAMS-KR 문제 110
유엔 제재는 다음과 같은 경우 국제 안보 위협에 대응하기 위한 가장 효과적이고 합법적인 비폭력적 다자간 도구입니다.
Option B (Correct):For UN sanctions to be effective, they must be enforced by all member statesthroughstrong domestic legal mechanisms.
Option A (Incorrect):UN sanctions are not necessarily implemented faster than unilateral sanctions (e.g., U.S.
OFAC sanctions).
Option C (Incorrect):While UN sanctions apply internationally, enforcement depends on national governments, making implementation inconsistent.
Option D (Incorrect):Clarity of sanction measures is important, but enforcement is the primary factor determining effectiveness.
Key Features of UN Sanctions:
Mandated by the UN Security Council under Chapter VII of the UN Charter.
Binding on all 193 UN member states.
May include asset freezes, travel bans, and trade embargoes.
Best Practices for UN Sanctions Compliance:
Ensure national enforcement aligns with UN Security Council resolutions.
Monitor sanctioned individuals/entities through real-time screening tools.
Cooperate with international organizations to prevent sanctions evasion.
Reference:
FATF Recommendation 6 (Targeted Financial Sanctions)
United Nations Security Council (UNSC) Sanctions Guidelines
EU & OFAC Guidance on Sanctions Implementation
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