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位於紐約的一家銀行在中國的一家代理銀行發現了可疑交易。對於其中一位國際客戶，代理行沒有遵守商定的協議。
哪些因素顯示銀行應該終止關係？
A. 代理銀行已在外國資產管制辦公室名單上的國家開設分行。
B. 代理銀行最近超出了主要銀行最近開發的風險模型中可接受的限制。
C. 代理銀行的合規官目前因賄賂指控正在接受調查。
D. 主要機構已要求代理銀行提供交易詳細資料以協助調查。
Answer: A
Explanation:
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 trade sanctions 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.
References:
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
5: https://home.treasury.gov/policy ... grams-and-informati
6: https://www.acams.org/en/cams-certification-package-6th-edition
7: https://www.exam-labs.com/video-training/acams-cams
8: https://vceplus.io/exam-cams/
NEW QUESTION # 432
FATF 建議在客戶盡職調查 (CDD) 計劃中納入一些措施，包括：
A. 辨識產品和服務及其對顧客的適合性。
B. 對業務關係進行持續的盡職調查並監控交易。
C. 辨識受益所有人的數量，無需驗證其真實身分。
D. 對產品和服務進行風險評估。
Answer: B
Explanation:
According to the FATF Recommendation 10, financial institutions should conduct ongoing due diligence on the business relationship and scrutiny of transactions undertaken throughout the course of that relationship to ensure that the transactions being conducted are consistent with the institution's knowledge of the customer, their business and risk profile, including, where necessary, the source of funds. This is one of the core measures of customer due diligence (CDD) that aim to prevent and detect money laundering and terrorist financing risks.
NEW QUESTION # 433
夏季，一家機構發現了有關客戶帳戶活動的反洗錢問題。這位冰淇淋客戶在國外銀行存入了大量支票，向不同國家發送大量高額國際電匯，每隔幾天存入數百美元現金，並為數人開出多張支票。每兩周向同一批收款人支付一百美元。
哪兩種交易類型值得調查？（選兩個。）
A. 對同一收款人重複支票
B. 定期現金存款
C. 從外國銀行開立的支票
D. 到國外的電匯
Answer: C,D
Explanation:
According to the ACAMS Study Guide 6th Edition, Chapter 2, page 36, one of the methods that financial institutions can use to identify suspicious or unusual activity is to monitor transactions for red flags or indicators of money laundering or terrorist financing. Some of the common red flags are:
Transactions that are inconsistent with the customer's profile, business, or source of funds Transactions that involve high-risk countries or jurisdictions, especially those with weak or inadequate anti-money laundering regulations, or those known to be sources or destinations of illicit funds Transactions that involve the use of complex or unusual financial instruments or structures, such as multiple accounts, intermediaries, or offshore entities, that have no apparent economic or lawful purpose Transactions that involve the use of large amounts of cash, checks, or monetary instruments, especially if they are structured or aggregated to avoid reporting or recordkeeping requirements Transactions that involve the use of third parties or nominees, such as relatives, associates, or shell companies, to conceal the identity, ownership, or control of the funds or assets Option B is a transaction type that warrants investigation, as it involves sending large number of high dollar international wires to different countries, which could indicate that the customer is involved in layering or integration stages of money laundering, where the illicit funds are moved across borders and disguised as legitimate transfers. This transaction type also raises the risk of exposure to sanctions, terrorist financing, or other illicit activities, depending on the destination and purpose of the wires.
Option D is also a transaction type that warrants investigation, as it involves depositing a lot of checks drawn on banks in foreign countries, which could indicate that the customer is involved in placement or layering stages of money laundering, where the illicit funds are introduced into the financial system or converted into other forms of value. This transaction type also raises the risk of exposure to fraud, counterfeit, or forgery, depending on the origin and authenticity of the checks.
Option A is not a transaction type that warrants investigation, as it involves making regular cash deposits of a few hundred dollars every few days, which could be consistent with the customer's profile, business, or source of funds, especially if the customer is an ice cream vendor who operates in cash. This transaction type does not raise any red flags of money laundering or terrorist financing, unless there is evidence that the cash deposits are structured or aggregated to avoid reporting or recordkeeping requirements.
Option C is also not a transaction type that warrants investigation, as it involves writing multiple checks for a few hundred dollars to the same dozen payees every two weeks, which could be consistent with the customer's profile, business, or source of funds, especially if the payees are suppliers, employees, or contractors of the customer. This transaction type does not raise any red flags of money laundering or terrorist financing, unless there is evidence that the checks are used to facilitate illicit activities, such as bribery, kickbacks, or tax evasion.
Reference:
ACAMS Study Guide 6th Edition, Chapter 2, page 36
Red Flags And Atypical Customer Behavior: Anti-Money Laundering Awareness
4 Red Flags of Money Laundering or Terrorist Financing
NEW QUESTION # 434
一家銀行正在為一家位於紐約市的小型數位行銷公司完成定期的 KYC 資料審查。
下列哪一項是危險訊號？
A. 帳戶活動包括儲蓄帳戶和支票帳戶的存款活動。
B. 此帳戶活動包括頻繁購買產業會議和其他活動的門票。
C. 此帳戶活動包括在紐約市週邊的多個分行向同一帳戶進行的存款。
D. 此帳戶活動包括來自紐約小型企業不定期的資金轉移。
Answer: C
Explanation:
Money laundering risks arise when transaction patterns are inconsistent with a business's expected activity.
Option D (Correct): Multiple cash deposits in different branches is a known structuring (smurfing) technique, used to evade cash transaction reporting thresholds.
Option A (Incorrect): Depositing into both checking and savings accounts is normal behavior.
Option B (Incorrect): Irregular incoming payments may require further review but are not inherently suspicious.
Option C (Incorrect): Industry-related expenses (e.g., conference tickets) are normal business activity.
NEW QUESTION # 435
歐盟的「骯髒反洗錢」指令有哪些要求？{選兩項。)
A. 擴大高風險第三國的評估標準
B. 制定應對有組織犯罪和恐怖主義威脅的策略的不同方法
C. 將 AML 規則擴展到提供虛擬貨幣服務的實體
D. 根據金融情報機構功能、權限和權力性質的差異向其提供資訊存取權限
E. 將銀行的記錄保存義務提升至反洗錢調查所需的最大資料量
Answer: C,E
Explanation:
A: Promoting the record-keeping obligations of banks to the maximum amount of data necessary for the purposes of AML investigations: "The Fifth AML Directive emphasizes that record-keeping obligations of banks must extend to the maximum amount of data necessary for the purposes of anti-money laundering investigations" (CAMS Manual, 6th Edition, page 79).
C: Extending AML rules to entities that provide virtual currency services: "The 5AMLD expands the scope of the EU's anti-money laundering rules to include virtual currency exchange platforms and custodian wallet providers" (CAMS Manual, 6th Edition, page 80).
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NEW QUESTION # 436
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