CAMS-KR 문제 256
유엔 안전보장이사회가 제재를 부과하는 데 있어서 하는 주된 역할은 다음과 같은 권한을 갖는다는 것입니다.
정답: A
The United Nations Security Council (UNSC) is the only body with the legal authority under international law to impose binding sanctions on countries, entities, or individuals.
"The Security Council's primary function in imposing sanctions is to maintain or restore international peace and security. These sanctions are legally binding on all UN member states." (CAMS 6th Edition, Chapter: International Sanctions and Proliferation Financing; United Nations Charter, Article 41) Incorrect Options:
* B: Sanctions may address AML/CFT failings, but the core mandate is international peace/security.
* C: The UNSC does not primarily conduct research or impact analysis.
* D: The purpose is international peace/security, not only domestic financial stability.
References:
CAMS 6th Edition, International Sanctions
United Nations Charter, Article 41
"The Security Council's primary function in imposing sanctions is to maintain or restore international peace and security. These sanctions are legally binding on all UN member states." (CAMS 6th Edition, Chapter: International Sanctions and Proliferation Financing; United Nations Charter, Article 41) Incorrect Options:
* B: Sanctions may address AML/CFT failings, but the core mandate is international peace/security.
* C: The UNSC does not primarily conduct research or impact analysis.
* D: The purpose is international peace/security, not only domestic financial stability.
References:
CAMS 6th Edition, International Sanctions
United Nations Charter, Article 41
CAMS-KR 문제 257
고위험 관할 구역의 귀금속 및 석재 대량 판매상에게 $200,000 상당의 금 판매에 관심이 있는 신규 고객이 찾아왔습니다. 고객은 딜러의 오랜 가족 친구가 추천했으며 판매에 대한 배경이나 비즈니스 목적에 대한 정보를 제공하지 않습니다. 딜러는 참조만을 기반으로 구매하는 데 동의합니다.
돈세탁 적신호란?
돈세탁 적신호란?
정답: D
This is when a customer or a transaction does not provide sufficient or credible information about their identity, source of funds, business activity, or purpose of the transaction. Lack of transparency can indicate that the customer or the transaction is trying to conceal the origin, ownership, or destination of illicit funds, or to evade regulatory scrutiny or reporting obligations. Lack of transparency is a common risk factor for money laundering and terrorist financing, especially in high-risk jurisdictions or sectors.
The other options are not necessarily red flags, although they may increase the risk or require further due diligence depending on the circumstances and the risk profile of the customers and countries involved. Option A describes a referral by a longtime friend of the dealer, which may be a legitimate source of trust or business relationship, but it does not substitute the need for proper customer identification and verification. Option B describes the location of the precious metals dealer, which may be a high-risk jurisdiction due to factors such as weak governance, corruption, crime, or sanctions, but it does not imply that the dealer or the customer is involved in money laundering. Option C describes the amount and nature of the transaction, which may be unusual or large, but it does not necessarily indicate money laundering, as long as the customer can provide a reasonable explanation and evidence for the source and use of funds.
ACAMS CAMS Certification Video Training Course - 6th Edition1
Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)2 ACAMS CAMS Study Guide - 6th Edition, Chapter 3, pages 64-65
https://www.acams.org/wp-content/uploads/2019/09/ACAMS-CAMS-Study-Guide-6th-Edition-Chapter-3.pdf
The other options are not necessarily red flags, although they may increase the risk or require further due diligence depending on the circumstances and the risk profile of the customers and countries involved. Option A describes a referral by a longtime friend of the dealer, which may be a legitimate source of trust or business relationship, but it does not substitute the need for proper customer identification and verification. Option B describes the location of the precious metals dealer, which may be a high-risk jurisdiction due to factors such as weak governance, corruption, crime, or sanctions, but it does not imply that the dealer or the customer is involved in money laundering. Option C describes the amount and nature of the transaction, which may be unusual or large, but it does not necessarily indicate money laundering, as long as the customer can provide a reasonable explanation and evidence for the source and use of funds.
ACAMS CAMS Certification Video Training Course - 6th Edition1
Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)2 ACAMS CAMS Study Guide - 6th Edition, Chapter 3, pages 64-65
https://www.acams.org/wp-content/uploads/2019/09/ACAMS-CAMS-Study-Guide-6th-Edition-Chapter-3.pdf
CAMS-KR 문제 258
테러 자금 조달 방지(CFT)
AML 조사 맥락에서 데이터 개인정보 보호에 관한 어떤 진술이 가장 정확합니까?
AML 조사 맥락에서 데이터 개인정보 보호에 관한 어떤 진술이 가장 정확합니까?
정답: A
AML compliancemust balancedata privacy lawswithfinancial crime prevention.
Option A (Correct):FIUsmust document the purpose of SAR-related data sharingunderFATF Recommendation 29andGDPR compliance standards.
Option B (Incorrect):Customers do not have the rightto request redaction of personal data in SARs, as this wouldcompromise AML enforcement.
Option C (Incorrect):Many jurisdictions permit information sharingfor AML purposes underformal agreements (e.g., 314(b) USA PATRIOT Act, GDPR exemptions).
Option D (Incorrect):AML reporting requirementsoverride opt-in privacy preferencesdue to thelegal obligation to report suspicious activity.
Reference:FATF Recommendation 29 (FIUs), GDPR Article 6(1)(e) (AML Data Processing), USA PATRIOT Act Section 314(b).
Option A (Correct):FIUsmust document the purpose of SAR-related data sharingunderFATF Recommendation 29andGDPR compliance standards.
Option B (Incorrect):Customers do not have the rightto request redaction of personal data in SARs, as this wouldcompromise AML enforcement.
Option C (Incorrect):Many jurisdictions permit information sharingfor AML purposes underformal agreements (e.g., 314(b) USA PATRIOT Act, GDPR exemptions).
Option D (Incorrect):AML reporting requirementsoverride opt-in privacy preferencesdue to thelegal obligation to report suspicious activity.
Reference:FATF Recommendation 29 (FIUs), GDPR Article 6(1)(e) (AML Data Processing), USA PATRIOT Act Section 314(b).
CAMS-KR 문제 259
테러 자금 조달(CFT)
왜 상호사법공조조약(MLAT)은 국제 협력의 관문인가?
왜 상호사법공조조약(MLAT)은 국제 협력의 관문인가?
정답: A
A Mutual Legal Assistance Treaty (MLAT) is an agreement between two or more countries for the purpose of gathering andexchanging information in an effort to enforce public or criminal laws1. MLATs provide a legal basis for transmitting evidence that can be used for prosecution and judicial proceedings, such as witness statements, bank records, search and seizure orders, and asset forfeiture2. MLATs also facilitate the cooperation and coordination between law enforcement authorities of different jurisdictions in investigating and prosecuting transnational crimes, such as money laundering, terrorist financing, corruption, and cybercrime3. The other options are incorrect because:
B). MLATs do not receive reports of suspicious transactions from financial institutions, but rather request specific information or evidence from foreign authorities. Financial institutions report suspicious transactions to their domestic Financial Intelligence Units (FIUs), which may then share the information with foreign FIUs through other mechanisms, such as the Egmont Group or bilateral agreements4.
C). MLATs do not obtain intelligence that might lead to evidence, but rather request evidence that is already available or can be obtained by foreign authorities. Intelligence is a broader term that refers to any information that is relevant to the security or interests of a country, and may not be admissible as evidence in a court of law5. Intelligence may be obtained through other means, such as covert operations, surveillance, or informants6.
D). MLATs do not issue the Principles of Information Exchange Between Financial Intelligence Units (FIUs), but rather follow them. The Principles of Information Exchange are a set of guidelines that were adopted by the Egmont Group of FIUs in 2001, and aim to enhance the cooperation and communication among FIUs in exchanging financial information and intelligence7. The Principles of Information Exchange are not legally binding, but rather reflect the best practices and standards of the FIU community.
1: Mutual legal assistance treaty - Wikipedia
2: FREQUENTLY ASKED QUESTIONS REGARDING LEGAL ASSISTANCE IN CRIMINAL
MATTERS, page 1
3: The Mutual Legal Assistance Problem explained | wilmap
4: ACAMS, CAMS Certification Package - 6th Edition, Chapter 4, page 125
5: Intelligence - Wikipedia
6: Intelligence cycle - Wikipedia
7: Egmont Group of Financial Intelligence Units - Wikipedia
Principles for Information Exchange Between Financial Intelligence Units for Money Laundering and Terrorism Financing Cases
B). MLATs do not receive reports of suspicious transactions from financial institutions, but rather request specific information or evidence from foreign authorities. Financial institutions report suspicious transactions to their domestic Financial Intelligence Units (FIUs), which may then share the information with foreign FIUs through other mechanisms, such as the Egmont Group or bilateral agreements4.
C). MLATs do not obtain intelligence that might lead to evidence, but rather request evidence that is already available or can be obtained by foreign authorities. Intelligence is a broader term that refers to any information that is relevant to the security or interests of a country, and may not be admissible as evidence in a court of law5. Intelligence may be obtained through other means, such as covert operations, surveillance, or informants6.
D). MLATs do not issue the Principles of Information Exchange Between Financial Intelligence Units (FIUs), but rather follow them. The Principles of Information Exchange are a set of guidelines that were adopted by the Egmont Group of FIUs in 2001, and aim to enhance the cooperation and communication among FIUs in exchanging financial information and intelligence7. The Principles of Information Exchange are not legally binding, but rather reflect the best practices and standards of the FIU community.
1: Mutual legal assistance treaty - Wikipedia
2: FREQUENTLY ASKED QUESTIONS REGARDING LEGAL ASSISTANCE IN CRIMINAL
MATTERS, page 1
3: The Mutual Legal Assistance Problem explained | wilmap
4: ACAMS, CAMS Certification Package - 6th Edition, Chapter 4, page 125
5: Intelligence - Wikipedia
6: Intelligence cycle - Wikipedia
7: Egmont Group of Financial Intelligence Units - Wikipedia
Principles for Information Exchange Between Financial Intelligence Units for Money Laundering and Terrorism Financing Cases
CAMS-KR 문제 260
암시장 페소 거래소 자금 세탁 방법에 대한 설명은 무엇입니까?
정답: C
The Black Market Peso Exchange (BMPE) is a trade-based money laundering technique commonly used by narcotics traffickers based in Colombia and Mexico. The central feature is the use of a money trader to ensure that the revenue from drug sales in the U.S.doesn't actually cross any borders. Instead, those dollars are used to purchase any number of legitimate commodities from unsuspecting businesses on behalf of legitimate South American businesspersons, whose legitimate imports are used to obtain pesos for the drug cartels12.
The BMPE involves six distinct steps:
Obtaining criminal proceeds: The drug cartels sell drugs for dollars in the U.S.
Involvement of intermediary services: The drug cartels sell the dollars to black market peso exchangers in Colombia at a discounted rate.
Identification of complicit companies: The black market peso exchangers identify exporting companies in the U).S. and importing companies in South America that are willing to participate in the scheme.
Placement of funds: The black market peso exchangers deposit the dollars into U.S. bank accounts or use money service businesses or other methods to transfer the funds.
Layering of funds: The black market peso exchangers use the funds to purchase monetary instruments such as checks, money orders, or wire transfers, or to pay for the goods ordered by the South American importers.
Integration of funds: The South American importers receive the goods or the monetary instruments and use them to pay for their imports or to sell them for pesos in the local market.
1: Black Market Peso Exchange in Money Laundering - Financial Crime Academy
2: Overview - FinCEN.gov
The BMPE involves six distinct steps:
Obtaining criminal proceeds: The drug cartels sell drugs for dollars in the U.S.
Involvement of intermediary services: The drug cartels sell the dollars to black market peso exchangers in Colombia at a discounted rate.
Identification of complicit companies: The black market peso exchangers identify exporting companies in the U).S. and importing companies in South America that are willing to participate in the scheme.
Placement of funds: The black market peso exchangers deposit the dollars into U.S. bank accounts or use money service businesses or other methods to transfer the funds.
Layering of funds: The black market peso exchangers use the funds to purchase monetary instruments such as checks, money orders, or wire transfers, or to pay for the goods ordered by the South American importers.
Integration of funds: The South American importers receive the goods or the monetary instruments and use them to pay for their imports or to sell them for pesos in the local market.
1: Black Market Peso Exchange in Money Laundering - Financial Crime Academy
2: Overview - FinCEN.gov
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