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A remittance company received a money order from a senior political figure m the Philippines to transfer a large sum of money to a charity group in the Philippines. A review of the charity group revealed a director having dose ties with a known terrorist group primarily financed through kidnapping and extortion.
What is a key risk indicator associated with terrorism financing?
A. There is a link between the charity group and a known terrorist group
B. A large sum sent by money order to a charity
C. There is no risk relating of terrorism financing when the charity group is operating legitimately in that country
D. The sender is a Political Exposed Person (PEP) and should be subject to enhanced due diligence
答案:A
解題說明:
A key risk indicator associated with terrorism financing is the link between the charity group and a known terrorist group. This indicates that the funds transferred to the charity group may be used to support the terrorist group's activities, such as recruitment, training, propaganda, or attacks. Charities are often vulnerable to abuse by terrorist financiers, as they may operate in high-risk areas, have access to large amounts of cash, and enjoy public trust and legitimacy. Therefore, financial institutions (FIs) should conduct due diligence on the charity group, its directors, its beneficiaries, and its sources and uses of funds, and monitor the transactions for any red flags, such as unusual patterns, amounts, or destinations. FIs should also comply with the relevant sanctions and regulatory requirements, and report any suspicious or unusual activity to the authorities.
1: FATF Guidance on Private Sector Information Sharing1
2: Mitigating the risks of terrorist financing | Crowe LLP3
3: ACAMS Study Guide for the CAMS Certification Examination3
問題 #45
the Financing of Terrorism (CFT)]
A senior government official is trying to open an account in a financial institution (FI) that operates in a different country from where the official is domiciled. The official is using an asset manager intermediary to represent them. According to the Wolfsberg Group, which next steps should the FI take regarding the opening of the account? (Select Three.)
A. Ensure the official's client file is updated so that the information is maintained in a consistent and complete manner.
B. Screen for applicable sanctions only for the official in the name of the person for whom the account will be opened.
C. Report to authorities that a possible suspicious activity is being undertaken by a politically exposed person.
D. Perform due diligence procedures on the managing intermediary.
E. Determine whether the intermediary representative is acting on the officer's behalf.
F. Reasonably establish if the source of wealth and funds of the official is legitimate.
答案:D,E,F
解題說明:
According to the Wolfsberg Group, the FI should take the following steps regarding the opening of the account for the senior government official:
Reasonably establish if the source of wealth and funds of the official is legitimate. This is to ensure that the FI is not facilitating the laundering of proceeds of corruption, bribery, or other illicit activities by the official, who is considered a politically exposed person (PEP) and poses a higherrisk of financial crime. The FI should obtain information and documentation on the origin and ownership of the funds, the official's income and assets, and the purpose and expected activity of the account12.
Perform due diligence procedures on the managing intermediary. This is to verify the identity, reputation, and regulatory status of the intermediary, who acts as a third party on behalf of the official. The FI should also assess the intermediary's own AML/CFT policies and controls, and the nature and extent of the relationship between the intermediary and the official13.
Determine whether the intermediary representative is acting on the officer's behalf. This is to establish the beneficial ownership and control of the account, and to avoid any potential conflicts of interest or undue influence by the intermediary. The FI should obtain a written confirmation from the intermediary that they are authorized to act on behalf of the official, and that they will disclose any changes in the beneficial ownership or control of the account13.
References:
1, Wolfsberg Group, Guidance on Politically Exposed Persons (PEPs), 2023
2, Wolfsberg Group, FAQs on Source of Wealth (SoW) & Source of Funds (SoF), 2023
3, Wolfsberg Group, FAQs on Intermediaries, 2023
問題 #46
Combating the Financing of Terrorism (CFT)]
Typical events to identify and investigate potential AML activities include: (Select Three.)
A. internal tips from employees of the bank about potential suspicious activity.
B. requests from law enforcement agencies.
C. alerts triggered by the automated AML monitoring system.
D. subpoenas requesting information for civil cases.
E. blocked transactions involving individuals included in the Office of Foreign Assets Control Specially Designated Nationals and Blocked Persons List.
F. accounts going to dormant status.
答案:A,C,E
解題說明:
Typical events to identify and investigate potential AML activities include: A) blocked transactions involving individuals included in the Office of Foreign Assets Control Specially Designated Nationals and Blocked Persons List; B) internal tips from employees of the bank about potential suspicious activity; and C) alerts triggered by the automated AML monitoring system [1]. Blocked transactions are those which involve individuals included on the Specially Designated Nationals and Blocked Persons List - this is a list maintained by the Office of Foreign Assets Control of individuals who are subject to economic or trade sanctions [1], or who may be involved in money laundering or terrorist activities [2]. Internal tips are those which are provided by employees of the bank who may have observed suspicious activity, or have reason to believe that certain transactions or activities may be related to potential money laundering. Alerts triggered by the automated AML monitoring system are those which are generated by the banks systems and processes which are designed to detect potential money laundering.
問題 #47
An institution has made the decision to exit a client relationship due to anti-money laundering concerns. Prior to starting the close out process, the institution receives a written request from a law enforcement agency to keep the account open. The client is the subject of an ongoing investigation and law enforcement wants the institution to continue to monitor the account and report any suspicious activity.
What is primary consideration the institution should keep in mind when deciding whether to agree to this request?
A. Whether the institution can continue to meet its regulatory obligations with the accounts open
B. The fact that the institution has a solid record in complying with law enforcement requests
C. The number of suspicious transaction reports previously filed on the client
D. The anticipated cost of complying with the law enforcement request
答案:A
解題說明:
The primary consideration the institution should keep in mind when deciding whether to agree to the law enforcement request is whether the institution can continue to meet its regulatory obligations with the accounts open. This is because the institution has a duty to comply with the applicable laws and regulations, and to protect its reputation and integrity from being associated with money laundering or terrorist financing.
The institution should assess the risks and benefits of keeping the account open, and consult with its legal counsel and senior management before making a decision. The institution should also document its decision and the rationale behind it, and communicate it to the law enforcement agency12.
References:
1: CAMS Certification Package - 6th Edition | ACAMS, Chapter 7: Conducting or Supporting the Investigation Process, p. 143-144 2:
FATF Guidance: Anti-Money Laundering and Terrorist Financing Measures and Financial Inclusion, February 2013, p. 50-51, http://www.fatf-gafi.org/media/fatf/documents/reports
/AML_CFT_Measures_and_Financial_Inclusion_2013.pdf
問題 #48
Which information should be provided to the Board of Directors or a designated specialized committee when preparing a Suspicious Activity Report (SAR) report summary?
A. Copies of all SARs filed during the reported period.
B. Statistical data regarding SARs filed during the reported period.
C. All possible details of SARs filed during the reporting period.
D. Names of all customers subject to SARs filed during the reported period.
答案:B
解題說明:
SAR information is highly sensitive, and institutions must follow strict confidentiality rules to protect investigations and avoid "tipping off" customers.
Option D (Correct): Statistical summaries (e.g., the number of SARs filed, trends, typologies) help the Board monitor AML risks without disclosing confidential details.
Option A (Incorrect): Providing all possible details may violate SAR confidentiality laws.
Option B (Incorrect): Sharing full SAR copies with non-compliance staff is not permitted under AML regulations.
Option C (Incorrect): Naming specific customers under SAR review risks "tipping off" or leaking confidential information.
Best Practices for SAR Reporting to the Board:
Provide anonymized statistics on SAR trends.
Highlight emerging AML risks and compliance effectiveness.
Avoid disclosing specific cases or customer names.
Reference:
FinCEN SAR Confidentiality Rules (U.S.)
6th EU Anti-Money Laundering Directive (6AMLD)
FATF Recommendation 20 (Reporting Suspicious Transactions)