CAMS-KR 문제 31
AML/CFT를 위한 새로운 기술을 구현하는 데 있어 발생하는 과제는 다음과 같습니다. (4가지 선택)
정답: A,C,D,E
Key challenges in adopting new AML/CFT technologies are:
* A: Data privacy-new tech often requires processing more personal data, raising privacy/regulatory concerns.
* C: The Travel Rule-meeting global standards for information sharing in payments is a technology challenge.
* D: Data quality-effective systems rely on accurate, comprehensive, timely data.
* E: Complexity-integrating and managing new technology can increase operational complexity.( CAMS 6th Edition, Technology in AML/CFT; FATF Guidance on Digital ID and Fintech) References:
CAMS 6th Edition, AML/CFT Technology and Implementation Challenges
FATF, "Opportunities and Challenges of New Technologies for AML/CFT" (2021)
* A: Data privacy-new tech often requires processing more personal data, raising privacy/regulatory concerns.
* C: The Travel Rule-meeting global standards for information sharing in payments is a technology challenge.
* D: Data quality-effective systems rely on accurate, comprehensive, timely data.
* E: Complexity-integrating and managing new technology can increase operational complexity.( CAMS 6th Edition, Technology in AML/CFT; FATF Guidance on Digital ID and Fintech) References:
CAMS 6th Edition, AML/CFT Technology and Implementation Challenges
FATF, "Opportunities and Challenges of New Technologies for AML/CFT" (2021)
CAMS-KR 문제 32
다음 중 투명성 저하로 인해 자금세탁 위험이 더 높은 기업 구조는 무엇입니까? (3개를 선택하세요.)
정답: A,C,E
Money launderersexploit corporate structuresthat offeranonymityandreduced transparency.
Option A (Correct):Nominee shareholders and directorscan be used tohide true beneficial ownership.
Option C (Correct):Bearer sharesallowownership to transfer anonymously, amajor AML risk.
Option E (Correct):Tax haven companieswithsecrecy lawsare frequently used formoney laundering.
Option B (Incorrect):A private companywithout activitydoes not inherently pose anAML risk.
Option D (Incorrect):LLCscan be transparentif properKYC and reporting measuresare in place.
Reference:FATF Recommendation 24 (Transparency and Beneficial Ownership), Wolfsberg Group Guidance on Legal Entities, EU AMLD Corporate Ownership Directives.
Option A (Correct):Nominee shareholders and directorscan be used tohide true beneficial ownership.
Option C (Correct):Bearer sharesallowownership to transfer anonymously, amajor AML risk.
Option E (Correct):Tax haven companieswithsecrecy lawsare frequently used formoney laundering.
Option B (Incorrect):A private companywithout activitydoes not inherently pose anAML risk.
Option D (Incorrect):LLCscan be transparentif properKYC and reporting measuresare in place.
Reference:FATF Recommendation 24 (Transparency and Beneficial Ownership), Wolfsberg Group Guidance on Legal Entities, EU AMLD Corporate Ownership Directives.
CAMS-KR 문제 33
새 계정 담당자가 최근에 직업이 학생 과외인 개인의 계정을 개설했습니다.
다음 중 자금 세탁 가능성을 나타내는 고객 행동은 무엇입니까?
다음 중 자금 세탁 가능성을 나타내는 고객 행동은 무엇입니까?
정답: C
This customer action indicates possible money laundering because it could be a sign of layering, which is the second stage of the money laundering process. Layering involves moving the illicit funds around to create distance and confusion between the source and the destination of the money. Transferring all funds to another bank on the same day of large cash deposits could be an attempt to avoid detection by the bank's transaction monitoring system or by the authorities. It could also be a way to break the audit trail and obscure the origin of the funds.
The other customer actions are not necessarily indicative of money laundering, although they could raise some red flags depending on the context and the customer profile. Continually making weekly small cash deposits could be a sign of structuring, which is a technique to avoid reporting requirements by depositing amounts below the threshold. However, this could also be a legitimate behavior for a tutor who receives cash payments from students. Periodically initiating wire transfers to another account owned by a relative could be a sign of funneling, which is a technique to move funds between accounts that are not related to the business or personal activities of the customer. However, this could also be a legitimate behavior for a tutor who supports their family members financially. Opening a savings account and making frequent transfers from the checking account could be a sign of commingling, which is a technique to mix illicit funds with legitimate funds from a legal source. However, this could also be a legitimate behavior for a tutor who wants to save money for future expenses.
CAMS Certification Package - 6th Edition | ACAMS, Chapter 2: Money Laundering Risks and Methods, pp.
35-40
CAMS Certifications: How to Get CAMS Certified | ACAMS, CAMS Study Guide, pp. 28-32 ACAMS CAMS Certification Video Training Course - Exam-Labs, Module 2: Money Laundering Risks and Methods, Video 2.2: The Three Stages of Money Laundering Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition), Question 311, Answer C
The other customer actions are not necessarily indicative of money laundering, although they could raise some red flags depending on the context and the customer profile. Continually making weekly small cash deposits could be a sign of structuring, which is a technique to avoid reporting requirements by depositing amounts below the threshold. However, this could also be a legitimate behavior for a tutor who receives cash payments from students. Periodically initiating wire transfers to another account owned by a relative could be a sign of funneling, which is a technique to move funds between accounts that are not related to the business or personal activities of the customer. However, this could also be a legitimate behavior for a tutor who supports their family members financially. Opening a savings account and making frequent transfers from the checking account could be a sign of commingling, which is a technique to mix illicit funds with legitimate funds from a legal source. However, this could also be a legitimate behavior for a tutor who wants to save money for future expenses.
CAMS Certification Package - 6th Edition | ACAMS, Chapter 2: Money Laundering Risks and Methods, pp.
35-40
CAMS Certifications: How to Get CAMS Certified | ACAMS, CAMS Study Guide, pp. 28-32 ACAMS CAMS Certification Video Training Course - Exam-Labs, Module 2: Money Laundering Risks and Methods, Video 2.2: The Three Stages of Money Laundering Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition), Question 311, Answer C
CAMS-KR 문제 34
테러 자금 조달(CFT)
다음 중 금융활동기구(FATF)의 첫 번째 이니셔티브를 나타내는 것은 무엇입니까?
다음 중 금융활동기구(FATF)의 첫 번째 이니셔티브를 나타내는 것은 무엇입니까?
정답: A
The first Financial Action Task Force (FATF) initiative was the 40 Recommendations on Money Laundering, which were issued in April 1990, less than a year after the FATF was established by the G7 summit in Paris in
1989. The 40 Recommendations aimed to provide a comprehensive plan of action to fight money laundering by setting out the principles and measures for effective legal, regulatory, and operational frameworks at the national and international levels. The 40 Recommendations have been revised and updated several times since then, most recently in 2022, to reflect the evolving trends and techniques of money laundering and to include the issues of terrorist financing and the financing of proliferation of weapons of mass destruction.
The other options are not the first FATF initiative, but they are related to the FATF's work and mandate. The Report on Non-Cooperative Countries and Territories (NCCTs) was launched in 2000 to identify and monitor the jurisdictions that did not comply with the FATF standards and posed a risk to the international financial system. The Report on Money Laundering Typologies was first published in 1996 and has been updated annually to provide an analysis of the methods, techniques, and trends of money launderingand to assist the FATF members and observers in developing effective countermeasures. The Special Recommendations on Terrorist Financing were issued in October 2001, following the September 11 attacks, to complement the 40 Recommendations and to address the specific challenges of combating the financing of terrorism and terrorist acts.
History of the FATF, 1
Financial Action Task Force - Wikipedia, 2
Financial Action Task Force (FATF): What it is, How it Works - Investopedia, 3 The FINANCIAL ACTION TASK FORCE (FATF) - INSIGHTSIAS, 4
1989. The 40 Recommendations aimed to provide a comprehensive plan of action to fight money laundering by setting out the principles and measures for effective legal, regulatory, and operational frameworks at the national and international levels. The 40 Recommendations have been revised and updated several times since then, most recently in 2022, to reflect the evolving trends and techniques of money laundering and to include the issues of terrorist financing and the financing of proliferation of weapons of mass destruction.
The other options are not the first FATF initiative, but they are related to the FATF's work and mandate. The Report on Non-Cooperative Countries and Territories (NCCTs) was launched in 2000 to identify and monitor the jurisdictions that did not comply with the FATF standards and posed a risk to the international financial system. The Report on Money Laundering Typologies was first published in 1996 and has been updated annually to provide an analysis of the methods, techniques, and trends of money launderingand to assist the FATF members and observers in developing effective countermeasures. The Special Recommendations on Terrorist Financing were issued in October 2001, following the September 11 attacks, to complement the 40 Recommendations and to address the specific challenges of combating the financing of terrorism and terrorist acts.
History of the FATF, 1
Financial Action Task Force - Wikipedia, 2
Financial Action Task Force (FATF): What it is, How it Works - Investopedia, 3 The FINANCIAL ACTION TASK FORCE (FATF) - INSIGHTSIAS, 4
CAMS-KR 문제 35
뉴욕에 위치한 한 은행은 중국의 환거래 은행에서 의심스러운 거래를 식별했습니다. 국제 고객 중 하나의 경우, 거래 은행은 합의된 프로토콜을 따르지 않습니다.
은행이 관계를 종료해야 함을 나타내는 요인은 무엇입니까?
은행이 관계를 종료해야 함을 나타내는 요인은 무엇입니까?
정답: A
the correspondent bank has engaged in a high-risk activity that could expose the primary bank to sanctions violations, reputational damage, and regulatory scrutiny. The Office of Foreign Assets Control (OFAC) administers and enforces economic and tradesanctions against targeted foreign countries, regimes, terrorists, and other threats to the national security, foreign policy, or economy of the United States1. Opening branches in a country on the OFAC list indicates that the correspondent bank is not complying with the sanctions requirements, and could be facilitating transactions for sanctioned entities or individuals. This would pose a serious risk for the primary bank, which is responsible for conducting due diligence and monitoring of its correspondent banking relationships2. Therefore, the primary bank should terminate the relationship with the correspondent bank to avoid any potential liability or penalties.
The other options are not as compelling as A, because they do not necessarily indicate that the correspondent bank is violating any laws or regulations, or that the primary bank is exposed to significant risks. Option B could be a cause for concern, but it does not imply that the correspondent bank is involved in any wrongdoing, or that the compliance officer has any influence over the correspondent banking activities.
Option C could suggest that the correspondent bank is engaging in unusual or suspicious transactions, but it does not mean that the primary bank should terminate the relationship immediately, as it could also be a result of changes in the correspondent bank's business profile, customer base, or market conditions. Option D is a normal and expected part of the correspondent banking relationship, as the primary bank has the right and obligation to request transactional details from the correspondent bank to verify the legitimacy and source of funds, and to identify any red flags or anomalies3.
1: OFAC website
2: ACAMS Study Guide for the CAMS Certification Examination, 6th Edition, Chapter 5, page 178
3: ACAMS CAMS Certification Video Training Course, Module 5, Lesson 4
4: ACAMS CAMS Certification Practice Exam, Question 93
https://home.treasury.gov/policy-issues/office-of-foreign-assets-control-sanctions-programs-and-information
https://www.acams.org/en/cams-certification-package-6th-edition
https://www.exam-labs.com/video-training/acams-cams
https://vceplus.io/exam-cams/
The other options are not as compelling as A, because they do not necessarily indicate that the correspondent bank is violating any laws or regulations, or that the primary bank is exposed to significant risks. Option B could be a cause for concern, but it does not imply that the correspondent bank is involved in any wrongdoing, or that the compliance officer has any influence over the correspondent banking activities.
Option C could suggest that the correspondent bank is engaging in unusual or suspicious transactions, but it does not mean that the primary bank should terminate the relationship immediately, as it could also be a result of changes in the correspondent bank's business profile, customer base, or market conditions. Option D is a normal and expected part of the correspondent banking relationship, as the primary bank has the right and obligation to request transactional details from the correspondent bank to verify the legitimacy and source of funds, and to identify any red flags or anomalies3.
1: OFAC website
2: ACAMS Study Guide for the CAMS Certification Examination, 6th Edition, Chapter 5, page 178
3: ACAMS CAMS Certification Video Training Course, Module 5, Lesson 4
4: ACAMS CAMS Certification Practice Exam, Question 93
https://home.treasury.gov/policy-issues/office-of-foreign-assets-control-sanctions-programs-and-information
https://www.acams.org/en/cams-certification-package-6th-edition
https://www.exam-labs.com/video-training/acams-cams
https://vceplus.io/exam-cams/
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