
練習できるCAMS問題には認定ガイド問題と解答とトレーニングを提供しています
無料ACAMS CAMSテスト練習問題試験問題集
質問 # 510
Money laundering can cause which consequences for a financial institution? (Select Two.)
- A. Increases in correspondent banking facilities
- B. Increases in investigation costs and fines
- C. Increases in corporate taxes
- D. Reduction or loss of profitable business
- E. Reduction in number of employees
正解:B、D
解説:
Money laundering can have serious consequences for financial institutions. They may face increased investigation costs and fines from regulators and law enforcement agencies for failing to detect or prevent money laundering activities. Additionally, money laundering can result in a loss of profitable business as customers and counterparties may no longer want to do business with the institution due to its reputation for being associated with illicit activity.
Reference: Certified Anti-Money Laundering Specialist (CAMS) Study Guide, 6th Edition, page 76.
質問 # 511
A recent anti-money laundering audit revealed several regulatory reporting violations and lapses with the organization's anti-money laundering policy. As a result, the compliance officer has created a follow-up matrix to document progress in correcting the identified deficiencies.
To whom should the compliance officer provide regular updates of corrective action to help ensure the appropriate oversight?
- A. Audit management
- B. Business line managers
- C. Designated board committee
- D. Human Resources
正解:C
解説:
The compliance officer should provide regular updates of corrective action to the designated board committee, as they are ultimately responsible for the oversight of the organization's anti-money laundering program. The board committee should be informed of the audit findings, the corrective action plan, the progress and challenges, and the completion of the remediation. This will help ensure that the board committee is aware of the risks and issues, and can provide guidance and support to the compliance officer and the management.
ACAMS CAMS Certification Study Guide 6th Edition, Chapter 2, page 671
ACAMS CAMS Certification Exam Outline, Domain 2, Task 2.52
ACAMS CAMS Certification Flashcards, Question 893
質問 # 512
the Financing of Terrorism (CFT)]
What should countries do to help prevent non-profit organizations from being abused for the financing of terrorism according to the Financial Action Task Force 40 Recommendations?
- A. Ensure non-profit organizations cannot be used to conceal or obscure the diversion of funds intended for legitimate purposes to terrorists' organizations
- B. Create laws that forbid non-profit organizations from completing cross-border transactions without first running them through known terrorist data bases
- C. Require all non-profit organizations to register with the country's financial intelligence unit
- D. Allow for freezing assets of non-profit organizations
正解:A
解説:
According to the Financial Action Task Force (FATF) 40 Recommendations, countries should implement measures to prevent the abuse of non-profit organizations (NPOs) for the financing of terrorism. One of these measures is to ensure that NPOs cannot be used to conceal or obscure the diversion of funds intended for legitimate purposes to terrorists' organizations. This means that countries should have effective mechanisms to monitor and supervise NPOs, especially those that are at risk of terrorist financing abuse, and to take appropriate actions against NPOs that are involved in such activities. Countries should also ensure that NPOs maintain adequate records of their activities and transactions, and that these records are accessible to competent authorities. Furthermore, countries should promote transparency and accountability in the NPO sector, and encourage NPOs to conduct due diligence on their donors, beneficiaries, and associates.
FATF 40 Recommendations, Recommendation 8 and Interpretive Note to Recommendation 8 Best Practices on Combating the Abuse of Non-Profit Organisations, FATF, June 2015 COMBATING THE ABUSE OF NON-PROFIT ORGANISATIONS (RECOMMENDATION 8), FATF, June 2015 Reference:http://www.fatf-gafi.org/media/fatf/documents/reports/BPP-combating-abuse-non- profitorganisations.pdf(p.9)
質問 # 513
A precious metals dealer opens a new account with a bank. Which requires a referral to AML Investigations for further review?
- A. Multiple daily point of sale transactions from third parties that appear to be individuals.
- B. International incoming payments from foreign companies in which the precious metals dealer has an established relationship.
- C. International outgoing wires to diamond dealers that are part of the diamond pipeline.
- D. Payments received on the account reference unknown companies in the instructions.
正解:D
質問 # 514
What does designing a country as being of "prime money laundering concern" allow the U.S. government to do?
- A. Ensure the inclusion of that country into the office of Foreign Asset Control country sanctions programs
- B. Obtain transactional information from U.S.-owned subsidiary banks located outside the U.S.
- C. Close some or all correspondent or payable-through accounts
- D. Ensure the inclusion of that country onto FATF's Non-Cooperative Country and Territory list
正解:C
解説:
Designating a country as being of "prime money laundering concern" allows the U.S. government to impose one or more of five special measures under Section 311 of the USA PATRIOT Act12. These special measures are intended to protect the U.S. financial system from the risks posed by the designated country, such as money laundering, terrorist financing, or other illicit activities. The fifth special measure, which is the most severe, authorizes the Treasury Department to prohibit U.S. financial institutions from opening or maintaining correspondent or payable-through accounts for foreign financial institutions that involve the designated country12. Correspondent accounts are accounts that enable foreign banks to access the U.S. financial system and provide services to their customers, while payable-through accounts are accounts that allow foreign banks to offer their customers direct access to the U.S. financial system3. Closing these accounts effectively cuts off the designated country from the U.S. financial system and imposes significant costs and burdens on its financial sector.
:
1: 311 Actions | U.S. Department of the Treasury
2: Press Releases - U.S. Department of the Treasury
3: Anti-Money Laundering Laws and Regulations USA 2023-2024
質問 # 515
A precious metals dealer opens a new account with a bank. Which requires a referral to AML investigations for further review?
- A. International incoming payments from foreign companies in which the precious metals dealer has an established relationship
- B. Multiple daily point of sale transactions from third parties that appear to be individuals
- C. Payments on the account reference unknown companies from high-risk jurisdictions
- D. International outgoing wires to diamond dealers that are part of the diamond pipeline
正解:C
解説:
According to the ACAMS Study Guide for the CAMS Certification Exam (6th edition), page 211, dealers in precious metals and stones (DPMS) are vulnerable to money laundering and terrorist financing risks due to the high value, portability, and fungibility of their products. Therefore, DPMS should apply a risk-based approach to their AML/CFT compliance program and monitor their customers and transactions for any red flags or suspicious activities. One of the red flags for DPMS is receiving payments from or sending payments to unknown or unverified third parties, especially if they are located in high-risk jurisdictions that have weak AML/CFT controls, are subject to sanctions, or are known to be sources or destinations of illicit funds. Such payments may indicate that the DPMS is being used as a conduit or a front for money laundering, terrorist financing, tax evasion, or other criminal activities. Therefore, if a precious metals dealer opens a new account with a bank and receives or makes payments that reference unknown companies from high-risk jurisdictions, the bank should refer the account to AML investigations for further review and verification of the source and purpose of the funds, the identity and legitimacy of the third parties, and the nature and rationale of the business relationship.
Reference:
ACAMS Study Guide for the CAMS Certification Exam (6th edition), page 2111 FATF Guidance on the Risk-Based Approach for Dealers in Precious Metals and Stones2 Risk-Based Approach for Dealers in Precious Metals and Stones (DPMS)3
質問 # 516
The chief compliance officer (CCO) at a bank approved offering trade finance services to a company which is established within a country with a weak democratic system routinely reviews news on upcoming targeted economic sanction regulations in the EU, a major import partner for the country's production of crude oil.
Which of the following pieces of news would be of greatest concern?
- A. The Council of the European Union adopts a new import restriction regime for goods coming from countries that do not respect human rights
- B. The Council of the European Union adopts a new export control regime for electronic equipment
- C. The European Commission and the High Representative issue a joint proposal for an import ban on oil extraction equipment
- D. The European Commission and the High Representative issue a joint proposal for an import ban on refined oil products.
正解:D
解説:
A proposed EU import ban on refined oil products would be of greatest concern to the bank's trade finance services, as it directly targets a core revenue-generating sector (oil production) of the company's country. This could lead to significant disruptions in trade flows, regulatory risk exposure, and potential sanctions violations.
質問 # 517
The compliance officer for a bank is reviewing on-boarding documents for a new business account for a domestic corporation. The officer is unable to verify the identity of the beneficial owners of the company.
Only
information on the nominee owners was provided, and none of the listed addresses are local. The purpose of the business and future expected activity were disclosed to include cash letters, money orders and international remittance transfers.
Which red flag identifies a heightened money laundering risk?
- A. Account signer's government issued identification lists addresses outside of where the branch account was opened
- B. Expected activity was advised to include cash letter and money orders
- C. The names provided at account opening are identified as the corporation's representative nominees
- D. The nature and purpose of the business include international remittance transfers
正解:D
質問 # 518
Which of the following is the most likely reason for the Financial Action Task Force to remove a jurisdiction from the Non-Cooperative Countries and Territories list?
- A. Receiving a favorable mutual evaluation.
- B. Entering into a mutual legal assistance treaty.
- C. Joining the Wolfsberg Group.
- D. Conducting successful annual self-assessments.
正解:A
解説:
The Financial Action Task Force (FATF) is an inter-governmental body that sets standards and monitors compliance with anti-money laundering and counter-terrorist financing (AML/CFT) measures. The FATF conducts periodic mutual evaluations of its members and other jurisdictions to assess their level of implementation of the FATF Recommendations, which are the international AML/CFT standards. The FATF also identifies jurisdictions with strategic deficiencies in their AML/CFT regimes that pose a risk to the international financial system, and places them on two public lists: the High-Risk Jurisdictions subject to a Call for Action (also known as the black list) and the Jurisdictions under Increased Monitoring (also known as the grey list). The FATF works with these jurisdictions to address their deficiencies and monitors their progress through regular follow-up reports and on-site visits. The FATF may remove a jurisdiction from the list if it has made sufficient and sustainable progress in implementing the required reforms and has effectively addressed the identified strategic deficiencies. Therefore, receiving a favorable mutual evaluation is the most likely reason for the FATF to remove a jurisdictionfrom the list, as it indicates that the jurisdiction has met the FATF standards and has a robust AML/CFT system in place.
Conducting successful annual self-assessments, entering into a mutual legal assistance treaty, or joining the Wolfsberg Group are not sufficient reasons for the FATF to remove a jurisdiction from the list, as they do not necessarily reflect the overall compliance with the FATF Recommendations or the resolution of the strategic deficiencies. Moreover, the Wolfsberg Group is a private association of global banks that develops guidance and best practices for the financial sector on AML/CFT issues, and is not affiliated with the FATF.
ACAMS Study Guide for the CAMS Certification Examination - 6th Edition, Chapter 1: Risks and Methods of Money Laundering and Terrorism Financing, page 11.
ACAMS CAMS Certification Video Training Course, Module 1: Risks and Methods of Money Laundering and Terrorism Financing, Lesson 1.4: FATF and the 40 Recommendations.
About the Non-Cooperative Countries and Territories NCCT Initiative, FATF website.
質問 # 519
Which statement is true about when an institute becomes aware that a particular employee is under investigation by law enforcement as a result of a subpoena or warrant?
- A. If an independent investigation provides grounds to interview the employee, they can be interviewed and, if necessary, terminated buy not advised that they are under investigation
- B. The employee can and should be interviewed, as well as notified of the investigation to demonstrate the seriousness of the offence and to get the employee's full attention and cooperation
- C. The institute has a duty as an employer to inform the employee he or she is under investigation by law enforcement, buy must not inform them that a warrant or subpoena has been received
- D. Under no circumstances can the employee be interviewed by the institution without the consent of law enforcement for fear of tipping the employee off
正解:B
質問 # 520
What is the intentional evasion of a reporting or recordkeeping requirement?
- A. Structuring
- B. Layering
- C. Money laundering
- D. Placement
正解:A
解説:
Structuring is the intentional evasion of a reporting or recordkeeping requirement by breaking down a large transaction into smaller ones, or by using multiple accounts, institutions, or persons to avoid triggering the threshold for reporting or recordkeeping. Structuring is also known as smurfing, and it is a common technique used by money launderers to conceal the source, ownership, or control of illicit funds.
References: =
ACAMS Study Guide for the CAMS Certification Examination, 6th Edition, Chapter 2, Section 2.1.1, page 511 ACAMS CAMS Certification Video Training Course, Module 2, Lesson 2.1, video time 7:00-8:002 ACAMS CAMS Certification Practice Exam, Question 134, page 2853
質問 # 521
A high-volume dealer of precious metals and stones in a high-risk jurisdiction is approached by a new customer interested in selling gold worth $200,000. The customer was referred by a longtime family friend of the dealer and provides no indication ofbackground or business purpose for the sale. The dealer agrees to make the purchase based solely on the reference.
What is the money laundering red flag?
- A. The customer provides no background information or business purpose for the transaction
- B. The customer was referred by a longtime friend of the dealer
- C. The precious metals dealer is operating in a high-risk jurisdiction
- D. A new customer is selling gold worth $200,000 to a high volume dealer
正解:A
解説:
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
質問 # 522
The most important anti-money laundering issue associated with on-line banking is accurately
- A. Generating reports
- B. Identifying clients
- C. Analyzing data
- D. Capturing data
正解:B
解説:
One of the main challenges of online banking is verifying the identity of customers who open accounts or conduct transactions remotely, without face-to-face interaction. This poses a higher risk of money laundering, as criminals may use false or stolen identities, or hide behind shell companies or nominees, to move illicit funds through online platforms. Therefore, online banking providers must implement robust and risk-based customer due diligence (CDD) measures, such as verifying identity documents, using biometric or digital verification methods, screening customers against sanctions and watchlists, and monitoring customer behavior and transactions for any red flags or anomalies.
Reference:
ACAMS Study Guide for the CAMS Certification Examination, 6th Edition, Chapter 2: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), Section 2.2: Customer Due Diligence (CDD) and Know Your Customer (KYC), p. 32-35.
eWallets: AML Risks & How to Comply1
質問 # 523
A private banker of a major international bank is onboarding a new private investment company. The banker has verified the identity of the two directors, a husband and wife, who are equal shareholders. The funds in the account will be provided solely by the wife.
The banker was later informed by the company that an additional director and shareholder will be added to the company although the new shareholder will not provide funds.
What is the next step for due diligence in respect to the additional director and shareholder according to the Wolfsberg Anti-Money Laundering Principles for Private Banking?
- A. Verify the identity of this individual, including due diligence in respect of background and reputation, and undertake due diligence on her source of funds and wealth
- B. Seek to further understand the relationship between the shareholders and verify the identity of the individual which may include due diligence in respect to her background and reputation
- C. Refuse to open the account as it is not usual for an individual to be a director and shareholder of a private investment company without providing funds.
- D. Seek to further understand the relationship between the shareholders and undertake due diligence on the source of funds and wealth for each of the shareholders
正解:D
質問 # 524
Which three are the most commonly used risk criteria?
- A. Product and Service Risk
- B. Customer Risk
- C. Reputation Risk
- D. Country Risk
正解:A、B、D
解説:
According to the CAMS Study Guide, the most commonly used risk criteria for assessing the money laundering and terrorist financing risks are country risk, customer risk, and product and service risk. These criteria are based on the FATF Recommendations and the Basel Committee's guidance on sound management of risks related to money laundering and financing of terrorism.
Country risk refers to the level of exposure to potential money laundering and terrorist financing activities in a specific jurisdiction, based on factors such as the quality of its AML/CFT regime, its level of corruption, its political and economic stability, its involvement in illicit activities, and its cooperation with international bodies.
Customer risk refers to the level of exposure to potential money laundering and terrorist financing activities associated with a specific customer or customer segment, based on factors such as the nature and purpose of the business relationship, the source and destination of funds, the type and volume of transactions, the customer's profile and behavior, and the customer's geographic location.
Product and service risk refers to the level of exposure to potential money laundering and terrorist financing activities associated with a specific product or service offered by a financial institution, based on factors such as the complexity, transparency, anonymity, and accessibility of the product or service, the delivery channels and payment methods used, and the degree of oversight and monitoring applied.
Reputation risk is not a risk criterion for assessing the money laundering and terrorist financing risks, but rather a potential consequence of failing to manage those risks effectively. Reputation risk refers to the potential damage to the public trust and confidence in a financial institution due to its involvement or association with money laundering and terrorist financing activities, whether directly or indirectly.
CAMS Study Guide, 6th Edition, Chapter 2: Risk Assessments, pp. 41-461
FATF Recommendations, Recommendation 1: Assessing Risks and Applying a Risk-Based Approach2 Basel Committee on Banking Supervision, Sound management of risks related to money laundering and financing of terrorism, June 2017, pp. 9-143
質問 # 525
One key aspect of promoting an enterprise-wide compliance culture within a financial institution (FI) is that the:
- A. relevant information should be shared throughout the organization.
- B. cost of compliance should increase proportionately to revenues.
- C. revenue generating business sectors should have precedence over compliance.
- D. first line of defense should establish its own policies independently.
正解:A
解説:
Reference:
https://www.ifc.org/wps/wcm/connect/e7e10e94-3cd8-4f4c-b6f8-1e14ea9eff80/45464_IFC_AML_Report.pdf?M (51)
質問 # 526
A client opens a bank account for a multi-level marketing company. The debits and credits of the account are numerous and very involved. Further, there are a lot of international transactions. Also, funds are being tunneled from the company to the client's personal account in another jurisdiction.
Which two steps should law enforcement take in investigating this matter? (Choose two.)
- A. Ask the bank for the history of this multi-level marketing company
- B. Examine the flow of money from the company to the individual in an effort to determine if it is legitimate
- C. Examine possible Suspicious Activity Report information received from the local Financial Intelligence Units
- D. Determine who are the signatories on the account
正解:B、D
解説:
The correct answer is A and C. Law enforcement should determine who are the signatories on the account and examine the flow of money from the company to the individual in an effort to determine if it is legitimate.
These steps would help to identify the source and destination of the funds, the purpose and nature of the transactions, and the possible involvement of money laundering or other financial crimes. Asking the bank for the history of the multi-level marketing company (B) may not be relevant or useful, as the company may have a legitimate business model or a false front. Examining possible Suspicious Activity Report information received from the local Financial IntelligenceUnits (D) may be helpful, but it is not a necessary step, as the bank may not have filed any reports or the reports may not contain sufficient information.
:
ACAMS CAMS Certification Video Training Course1, Module 4: Conducting or Supporting the Investigation Process, Lesson 1: Investigating Techniques for Law Enforcement ACAMS CAMS Certification Study Guide2, Chapter 4: Conducting or Supporting the Investigation Process, Section 4.1: Investigating Techniques for Law Enforcement, pp. 125-126
質問 # 527
After a FATF mutual evaluation process, which are resulting actions for jurisdictions that are determined to have strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing? (Choose two.)
- A. Appeal to FATF for a technical compliance re-rating based on the jurisdiction's own experts criteria.
- B. Request FATF for an extension of deadlines in order to provide local awareness on the improvements that are necessary to solve the deficiencies.
- C. Report to FATF on the implementation of their progress under the enhanced follow-up mechanism.
- D. Expect private statements from FATF regarding the level of compliance of the jurisdiction, when insufficient progress is made.
- E. Demonstrate a high-level commitment to swiftly resolve the identified deficiencies in the FATF mutual evaluation report.
正解:C、E
解説:
According to the FATF Procedures for the Fourth Round of AML/CFT Mutual Evaluations1, jurisdictions that are determined to have strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing are subject to the FATF's International Cooperation Review Group (ICRG) process. The ICRG process involves the following actions for such jurisdictions:
* Demonstrate a high-level commitment to swiftly resolve the identified deficiencies in the FATF mutual evaluation report. This commitment should be made in writing to the FATF President and should include an action plan with specific deadlines and milestones to address the deficiencies.
* Report to FATF on the implementation of their progress under the enhanced follow-up mechanism. The FATF will monitor the progress of the jurisdiction through regular reports and on-site visits, and will decide whether the jurisdiction has made sufficient progress to exit the ICRG process or whether further actions are required, such as public statements, counter-measures, or suspension of membership.
The other options are not resulting actions for jurisdictions with strategic deficiencies, as they are either not part of the FATF procedures or not consistent with the FATF's objectives and principles. For example, the FATF does not issue private statements regarding the level of compliance of a jurisdiction, nor does it allow a jurisdiction to appeal for a technical compliance re-rating based on its own criteria. The FATF also does not grant extensions of deadlines for jurisdictions to improve their regimes, as this would undermine the credibility and effectiveness of the mutual evaluation process.
References:
* 1: Mutual Evaluations - Financial Action Task Force
* 2: Procedures for the FATF Fourth Round of AML/CFT Mutual Evaluations Reference: https://www.fatf-gafi.org/publications/high-risk-and-other-monitored-jurisdictions/documents
/increased-monitoring-june-2021.html
質問 # 528
Which three actions should employees be instructed to do during an internal investigation?
- A. Inform counsel of all request for documentation
- B. Keep a log of the documents requested
- C. Make copies of all documents provided to law enforcement
- D. Provide corporate documents directly to law enforcement
正解:A、B、C
解説:
During an internal investigation, employees should be instructed to do the following actions:
Inform counsel of all request for documentation: This is to ensure that the legal rights and obligations of the organization and the employees are protected and respected. Counsel can also advise on the scope, relevance, and confidentiality of the requested documents1.
Make copies of all documents provided to law enforcement: This is to maintain a record of the information that has been disclosed and to prevent any loss or alteration of the original documents. Copies should be made before the documents are handed over to law enforcement2.
Keep a log of the documents requested: This is to track the progress and status of the investigation and to avoid any duplication or omission of the requested documents. The log should include the date, time, description, and location of the documents, as well as the name and contact details of the person who requested and received them3.
Providing corporate documents directly to law enforcement, on the other hand, is not an action that employees should be instructed to do during an internal investigation. This is because law enforcement may not have the legal authority or the proper warrant to access the documents, and doing so may violate the privacy or confidentiality of the organization or the employees. Employees should consult with counsel before providing any documents to law enforcement4.
References:
1: Internal money laundering reporting | The Law Society5 2: How to Conduct Effective AML Investigations - Blog | Unit212 3: What Is The Importance Of An Internal Investigation?4 4: Anti-Money Laundering: 5 Steps to Conduct an Audit3
質問 # 529
One area of responsibility for the Board of Directors when implementing a successful AML program is to:
- A. create a culture of compliance based on the profit expectation.
- B. hire a third-party firm to be responsible for the AML compliance.
- C. manage the day-to-day processes of the compliance program.
- D. ensure the appointment of a qualified chief AML officer.
正解:D
解説:
Reference: https://www.fmu.gov.pk/docs/AML_CFT_Guide_for_Accountants.pdf (30)
質問 # 530
What do the Financial Action Task Force (FATF) mutual evaluations of each member assess?
- A. If the member has made any suggestions for updates to the FATF Recommendations
- B. If the member has a large enough economy to maintain its membership
- C. The member's ability to send a representative to the plenary sessions
- D. The levels of implementation of the FATF Recommendations
正解:D
解説:
A compliance officer should consider the following three factors as part of the approach to implement an enterprise-wide anti-money laundering program for a bank that operates in multiple countries:
The types of customers serviced by the bank: Different types of customers may pose different levels of money laundering risk, depending on their nature, source of funds, geographic location, transaction patterns, and other factors. A compliance officer should identify and assess the money laundering risk associated with each customer type and segment, and apply appropriate due diligence measures, monitoring systems, and risk mitigation strategies accordingly12.
The extent of anti-money laundering regulations in the various countries: A compliance officer should be aware of the legal and regulatory requirements and expectations for anti-money laundering compliance in each country where the bank operates, and ensure that the bank's policies and procedures are consistent with them. A compliance officer should also monitor any changes or updates in the anti-money laundering laws and regulations in the various countries, and adjust the bank's program accordingly34.
The anti-money laundering risk posed by the products and services offered by the bank: Different products and services may have different features and functionalities that could be exploited by money launderers, such as anonymity, cross-border transfers, cash transactions, complex structures, or new technologies. A compliance officer should evaluate the money laundering risk associated with each product and service offered by the bank, and implement appropriate controls, safeguards, and oversight mechanisms to prevent and detect money laundering activities5 .
Reference:
1: ACAMS, CAMS Study Guide, 6th Edition, Chapter 2: Risk Assessments
2: FATF, Guidance for a Risk-Based Approach: The Banking Sector
3: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT)
4: Deloitte, AML Program Effectiveness Reform
5: ACAMS, CAMS Study Guide, 6th Edition, Chapter 4: AML Program Design
[6]: OCC, Money Laundering: A Banker's Guide to Avoiding Problems
質問 # 531
......
CAMS試験に合格すると、専門家の卓越性に対する個人のコミットメントと、最新のAMLの傾向と規制に最新の状態を維持することへの献身が示されています。また、AMLの専門家としての信頼性と市場性を高め、キャリアの進歩と収益の可能性の増加の機会を開きます。
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