CAMS-KR 문제 301
테러 자금 조달 방지(CFT)
두 국가 간에 체결되는 법적 문서로, 국경 간 정보 공유를 규제하는 문서로 알려져 있습니다.
두 국가 간에 체결되는 법적 문서로, 국경 간 정보 공유를 규제하는 문서로 알려져 있습니다.
정답: D
AMutual Legal Assistance Treaty (MLAT)is aformal agreement between two or more countriesthat facilitatescooperation in legal and law enforcement matters, includingAML investigations.
Option D (Correct):MLATs allow governments to share financial intelligence, request legal assistance, and conduct joint investigations.
Option A (Incorrect):A Memorandum of Agreement (MOA) is typically a non-binding contract used for general business or governmental cooperation.
Option B (Incorrect):A Declaration of Understanding is an informal agreement and does not provide a legal framework for law enforcement cooperation.
Option C (Incorrect):A Memorandum of Understanding (MOU) is often used for informal cooperation but lacks the legal enforceability of an MLAT.
Option E (Incorrect):A Request for Urgent Information is not a recognized international legal instrument.
Best Practices for Cross-Border AML Cooperation:
Use MLATs to request access to financial records in foreign jurisdictions.
Collaborate with Financial Intelligence Units (FIUs) via the Egmont Group.
Leverage FATF's International Cooperation Review Group (ICRG) for guidance.
Reference:
FATF Recommendation 37 (International Cooperation & MLATs)
U.S. Department of Justice MLAT Procedures
Egmont Group Guidelines on Cross-Border FIU Information Sharing
Option D (Correct):MLATs allow governments to share financial intelligence, request legal assistance, and conduct joint investigations.
Option A (Incorrect):A Memorandum of Agreement (MOA) is typically a non-binding contract used for general business or governmental cooperation.
Option B (Incorrect):A Declaration of Understanding is an informal agreement and does not provide a legal framework for law enforcement cooperation.
Option C (Incorrect):A Memorandum of Understanding (MOU) is often used for informal cooperation but lacks the legal enforceability of an MLAT.
Option E (Incorrect):A Request for Urgent Information is not a recognized international legal instrument.
Best Practices for Cross-Border AML Cooperation:
Use MLATs to request access to financial records in foreign jurisdictions.
Collaborate with Financial Intelligence Units (FIUs) via the Egmont Group.
Leverage FATF's International Cooperation Review Group (ICRG) for guidance.
Reference:
FATF Recommendation 37 (International Cooperation & MLATs)
U.S. Department of Justice MLAT Procedures
Egmont Group Guidelines on Cross-Border FIU Information Sharing
CAMS-KR 문제 302
Egmont에 따라 FIU(Financial Intelligence Unit)가 정보를 안전하게 공유하기 위해 어떤 보호 장치가 마련되어 있습니까?
정답: A
According to the Egmont Group of Financial Intelligence Units Principles for Information Exchange Between Financial Intelligence Units, one of the channels for the exchange of information between FIUs is the Egmont Secure Web (ESW), which is a secure and encrypted communication system that allows FIUs to share information and expertise1. The ESW is accessible to all members of the FIU who have been authorized by the FIU head or his/her delegate1. The other options are not correct because:
B). Information sharing is not always conducted according to processes contained in Memoranda of Understanding (MOUs). The Egmont Group encourages FIUs to exchange information regardless of the existence of an MOU1.
C). Intelligence is not shared via messaging applications. This would not be a secure or reliable way of exchanging sensitive information.
D). Investigators are not allowed to request information from a foreign FIU directly. Requests for information must be made through the FIU of the requesting country1.
Egmont Group of Financial Intelligence Units Principles for Information Exchange Between Financial Intelligence Units The Egmont Group of Financial Intelligence Units | FinCEN.gov The Egmont Group of The Egmont Group of Financial Intelligence Units Reference: https://www.elibrary.imf.org/view/books/069/02365-9781589063495-en/ap01.xml
B). Information sharing is not always conducted according to processes contained in Memoranda of Understanding (MOUs). The Egmont Group encourages FIUs to exchange information regardless of the existence of an MOU1.
C). Intelligence is not shared via messaging applications. This would not be a secure or reliable way of exchanging sensitive information.
D). Investigators are not allowed to request information from a foreign FIU directly. Requests for information must be made through the FIU of the requesting country1.
Egmont Group of Financial Intelligence Units Principles for Information Exchange Between Financial Intelligence Units The Egmont Group of Financial Intelligence Units | FinCEN.gov The Egmont Group of The Egmont Group of Financial Intelligence Units Reference: https://www.elibrary.imf.org/view/books/069/02365-9781589063495-en/ap01.xml
CAMS-KR 문제 303
금융활동기구(FATF)가 다양한 관할권의 AML 통제 품질을 평가하기 위해 사용하는 상호 평가 및 후속 조치 과정에서 FATF는 다음을 수행합니다.
정답: D
The FATF conducts mutual evaluations-a peer review process-whereby member countries assess each other's AML/CFT systems. This includes on-site visits and reviews by international experts, with public reports containing recommendations for improvement. The process is not punitive and does not impose sanctions.
"FATF mutual evaluations are peer reviews in which experts from member countries assess another member's AML/CFT system and provide recommendations." (CAMS 6th Edition, International AML/CFT Standards; FATF Methodology, Recommendation 40) References:
CAMS 6th Edition, FATF Mutual Evaluations
FATF Methodology for Assessing Technical Compliance and Effectiveness
"FATF mutual evaluations are peer reviews in which experts from member countries assess another member's AML/CFT system and provide recommendations." (CAMS 6th Edition, International AML/CFT Standards; FATF Methodology, Recommendation 40) References:
CAMS 6th Edition, FATF Mutual Evaluations
FATF Methodology for Assessing Technical Compliance and Effectiveness
CAMS-KR 문제 304
테러 자금 조달(CFT)
고위 경영진과 이사회는 STR 제출에 어느 정도까지 관여해야 합니까?
고위 경영진과 이사회는 STR 제출에 어느 정도까지 관여해야 합니까?
정답: A
According to the ACAMS CAMS Certification Study Guide (6th edition), senior management and the Board of Directors have the ultimate responsibility for the effectiveness of the AML program and the compliance with the relevant laws and regulations. Therefore, they should be informed of all significant STRs and the numbers and trends of the filings, as this would help them to assess the level of risk exposure and the adequacy of the controls and resources. The other options are either too restrictive or too burdensome for senior management and the Board of Directors, and may interfere with the timely and confidential filing of STRs.
ACAMS CAMS Certification Study Guide (6th edition), page 361; ACAMS CAMS Certification Video Training Course, Module 2, Lesson 12
ACAMS CAMS Certification Study Guide (6th edition), page 361; ACAMS CAMS Certification Video Training Course, Module 2, Lesson 12
CAMS-KR 문제 305
테러 자금 조달(CFT)
FATF 스타일 지역 기구(FSRB) 업데이트에는 어떤 원칙이 포함되어야 합니까? (두 가지를 선택하세요.)
FATF 스타일 지역 기구(FSRB) 업데이트에는 어떤 원칙이 포함되어야 합니까? (두 가지를 선택하세요.)
정답: A,C
According to the Anti-Money Laundering Specialist (the 6th edition) resources, FSRBs are regional organizations that help the FATF implement its global AML/CFT policy and standards in over 200 affiliated countries1. FSRBs have their own high-level principles and objectives that govern their relationship with the FATF and their members2. Among these principles and objectives, two that should be included in a FSRB update are:
Issue country-specific Mutual Evaluation reports. This is the process by which FSRBs assess the compliance and effectiveness of their members' AML/CFT systems, based on the FATF standards and methodology3. Mutual Evaluation reports provide an in-depth analysis of the strengths and weaknesses of each jurisdiction, as well as recommendations for improvement4.
Identify jurisdictions with weak AML/CFT regimes. This is the process by which FSRBs, in coordination with the FATF, monitor and publicly list the countries that pose a risk to the international financial system due to their strategic deficiencies in AML/CFT. This process aims to encourage and assist these jurisdictions to address their gaps and enhance their cooperation with the global network.
The other three options are incorrect because:
Address AML/CFT technical assistance of individual members is not a principle that should be included in a FSRB update, as it is not a core function of FSRBs. FSRBs may facilitate or coordinate technical assistance, but they are not the primary providers or funders of such assistance.
Establish AML/CFT standards and typologies is not a principle that should be included in a FSRB update, as it is not a role of FSRBs. FSRBs are expected to adopt and implement the FATF standards, not to create their own. Typologies are the methods and trends of money laundering and terrorist financing, which are identified and analyzed by the FATF and FSRBs through research and workshops.
Protect the reputation and standing of FATF is not a principle that should be included in a FSRB update, as it is not a responsibility of FSRBs. FSRBs are autonomous and independent organizations that have their own governance and accountability mechanisms. FSRBs are expected to cooperate and coordinate with the FATF, but not to act as its agents or representatives.
1: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 64 2: FATF, High-Level Principles for the Relationship between the FATF and the FATF-Style Regional Bodies, February 2019, 3 3: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 65 4: FATF, FATF Methodology for Assessing Technical Compliance with the FATF Recommendations and the Effectiveness of AML/CFT Systems, February 2013 (updated October 2019), [12] : ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 66 : FATF, High-Risk and Other Monitored Jurisdictions, 4 : FATF, High-Level Principles for the Relationship between the FATF and the FATF-Style Regional Bodies, February 2019, 3, p. 4 : FATF, High-Level Principles for the Relationship between the FATF and the FATF-Style Regional Bodies, February 2019, 3, p. 2 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 67 : FATF, High-Level Principles for the Relationship between the FATF and the FATF-Style Regional Bodies, February 2019, 3, p. 3 : FATF, High-Level Principles for the Relationship between the FATF and the FATF-Style Regional Bodies, February 2019, 3, p. 5 : FATF, FATF Methodology for Assessing Technical Compliance with the FATF Recommendations and the Effectiveness of AML/CFT Systems, February 2013 (updated October 2019), [12], p. 9 : FATF, High-Risk and Other Monitored Jurisdictions, 4, p. 1 Reference: https://www.fatf-gafi.org/media/fatf/documents/High-Level%20Principles%20and%
20Objectives%20for%20FATF%20and%20FSRBs.pdf
Issue country-specific Mutual Evaluation reports. This is the process by which FSRBs assess the compliance and effectiveness of their members' AML/CFT systems, based on the FATF standards and methodology3. Mutual Evaluation reports provide an in-depth analysis of the strengths and weaknesses of each jurisdiction, as well as recommendations for improvement4.
Identify jurisdictions with weak AML/CFT regimes. This is the process by which FSRBs, in coordination with the FATF, monitor and publicly list the countries that pose a risk to the international financial system due to their strategic deficiencies in AML/CFT. This process aims to encourage and assist these jurisdictions to address their gaps and enhance their cooperation with the global network.
The other three options are incorrect because:
Address AML/CFT technical assistance of individual members is not a principle that should be included in a FSRB update, as it is not a core function of FSRBs. FSRBs may facilitate or coordinate technical assistance, but they are not the primary providers or funders of such assistance.
Establish AML/CFT standards and typologies is not a principle that should be included in a FSRB update, as it is not a role of FSRBs. FSRBs are expected to adopt and implement the FATF standards, not to create their own. Typologies are the methods and trends of money laundering and terrorist financing, which are identified and analyzed by the FATF and FSRBs through research and workshops.
Protect the reputation and standing of FATF is not a principle that should be included in a FSRB update, as it is not a responsibility of FSRBs. FSRBs are autonomous and independent organizations that have their own governance and accountability mechanisms. FSRBs are expected to cooperate and coordinate with the FATF, but not to act as its agents or representatives.
1: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 64 2: FATF, High-Level Principles for the Relationship between the FATF and the FATF-Style Regional Bodies, February 2019, 3 3: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 65 4: FATF, FATF Methodology for Assessing Technical Compliance with the FATF Recommendations and the Effectiveness of AML/CFT Systems, February 2013 (updated October 2019), [12] : ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 66 : FATF, High-Risk and Other Monitored Jurisdictions, 4 : FATF, High-Level Principles for the Relationship between the FATF and the FATF-Style Regional Bodies, February 2019, 3, p. 4 : FATF, High-Level Principles for the Relationship between the FATF and the FATF-Style Regional Bodies, February 2019, 3, p. 2 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 67 : FATF, High-Level Principles for the Relationship between the FATF and the FATF-Style Regional Bodies, February 2019, 3, p. 3 : FATF, High-Level Principles for the Relationship between the FATF and the FATF-Style Regional Bodies, February 2019, 3, p. 5 : FATF, FATF Methodology for Assessing Technical Compliance with the FATF Recommendations and the Effectiveness of AML/CFT Systems, February 2013 (updated October 2019), [12], p. 9 : FATF, High-Risk and Other Monitored Jurisdictions, 4, p. 1 Reference: https://www.fatf-gafi.org/media/fatf/documents/High-Level%20Principles%20and%
20Objectives%20for%20FATF%20and%20FSRBs.pdf
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