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ACAMS Certified Anti-Money Laundering Specialists (CAMS中文版) Sample Questions (Q155-Q160):NEW QUESTION # 155
對於向客戶提供線上服務的金融機構來說,最大的洗錢風險是什麼?
- A. 提供線上服務的機構無法正確驗證其客戶的身份
- B. 將客戶與所提供的身份證明文件進行配對存在較大困難
- C. 客戶可以直接存取其帳戶而不被發現
- D. 缺乏對客戶交易的人工審核
Answer: B
Explanation:
One of the key components of an effective anti-money laundering (AML) program is customer due diligence (CDD), which involves verifying the identity of the customer, understanding the nature and purpose of the customer's relationship with the financial institution (FI), and assessing the risk of money laundering or terrorist financing that the customer poses. CDD is essential for preventing and detecting the misuse of the FI's services by criminals, and for complying with the relevant laws and regulations.
However, CDD can be challenging for FIs that offer online services to customers, as there is a greater difficulty in matching the customer with the provided identification documentation. Unlike face-to-face interactions, online services rely on electronic or remote methods of identification and verification, such as scanned copies of documents, biometric data, digital signatures, or third-party verification services. These methods may not be as reliable or secure as physical verification, and may expose the FI to the risk of identity fraud, document forgery, or impersonation. Moreover, online services may attract customers from different jurisdictions, which may have different standards and requirements for identification and verification, and may pose different levels of risk.
Therefore, FIs that offer online services to customers should implement enhanced due diligence (EDD) measures to mitigate the risk of money laundering, such as obtaining additional information or documentation from the customer, applying more stringent verification procedures, conducting more frequent and intensive monitoring of the customer's transactions and behavior, and restricting or limiting the types or amounts of transactions that the customer can perform online.
Reference:
CAMS Study Guide - 6th Edition, Chapter 3, Section 3.4, page 82
Anti-Money Laundering in a Nutshell, Chapter 4, Section 4.2, page 63
Guidance on Digital Identity, Section 2, page 8
Anti-Money Laundering, The Basics: Installment 1, Section 3.2, page 5
NEW QUESTION # 156
下列哪一個屬於洗錢的金融階段?
- A. 結構化
- B. 展示位置
- C. 集成
- D. 離岸外包
Answer: B
Explanation:
According to the CAMS study guide, chapter 1, page 91, placement is the first stage of money laundering, where the illicit funds are introduced into the financial system. This stage involves the highest risk of detection, as the money launderers may use various methods to avoid suspicion, such as structuring, commingling, or using cash-intensive businesses. Placement is followed by layering and integration, which are the second and third stages of money laundering, where the illicit funds are moved and disguised through multiple transactions and entities, and then integrated into the legitimate economy as seemingly legal assets.
The other options are not the financial stages of money laundering, although they may be related to some aspects or techniques of money laundering. Option A, integration, is the final stage of money laundering, not the first. Option B, structuring, is a method of placement, not a stage of money laundering. Structuring, also known as smurfing, is the practice of breaking down large amounts of cash into smaller deposits or transactions to avoid reporting thresholds or scrutiny. Option C, off shoring, is a term that refers to the relocation of assets or activities to another jurisdiction, usually for tax or regulatory advantages. Off shoring may be used by money launderers to exploit the differences or loopholes between jurisdictions, but it is not a stage of money laundering.
References:
1: ACAMS CAMS Study Guide - 6th Edition, Chapter 1, page 9:
https://www.acams.org/wp-content ... ition-Chapter-1.pdf
NEW QUESTION # 157
歐盟反洗錢指令的關鍵目標是什麼?
- A. 允許成員國與歐盟金融情報機構 (FIU) 合作討論立法草案
- B. 解決歐盟國家的支付控制問題,以減少洗錢
- C. 在整個歐盟建立一致的監管環境以防止洗錢
- D. 建立金融機構 (FI) 網絡,共同防止整個歐盟洗錢
Answer: C
Explanation:
The key goal of EU Directives on money laundering is to establish a consistent regulatory environment across the EU to prevent money laundering and terrorist financing, and to align EU policy with international standards and best practices. EU Directives are legal acts that set out the objectives and principles that member states must achieve, but leave the choice of methods and measures to the national authorities. EU Directives on money laundering aim to harmonize the rules and obligations for FIs and other obliged entities in the areas of customer due diligence, record-keeping, reporting, supervision, and sanctions. They also aim to address the emerging threats and vulnerabilities of the financial system, such as the use of virtual assets, prepaid cards, high-risk third countries, and beneficial ownership. By creating a consistent regulatory environment across the EU, the Directives seek to enhance the effectiveness and cooperation of the AML
/CFT regime, and to protect the integrity and stability of the internal market and the financial system.
1: Guide to EU Anti Money Laundering Directives (AMLD) - ComplyAdvantage1
2: Directive - 2015/849 - EN - Fourth Anti-Money Laundering Directive - EUR-Lex2
3: EU context of anti-money laundering and countering the financing of terrorism3
NEW QUESTION # 158
歐盟 (EU) 國家的一家企業服務供應商擁有來自從事石油和天然氣交易的非洲國家的潛在客戶。該潛在客戶打算利用由第三方擔保的 7,500 萬美元貸款在其祖國開發一個石油碼頭,該第三方是在加勒比海島嶼上成立的信託公司,其控股公司位於歐洲的一個秘密天堂。一位年輕女士被描繪成最終受益所有人,她透過祖國的一家健身工作室獲得了財富。
可能表示洗錢或資助恐怖主義的兩個危險信號是什麼?(選兩個。)
- A. 潛在客戶希望在歐盟國家建立控股公司的公司架構
- B. 由第三方擔保人提供的價值 7,500 萬美元的貸款
- C. 擔保公司股權結構過於複雜
- D. 最終受益所有人是透過小型企業獲得財富的年輕女士
Answer: C,D
Explanation:
According to the ACAMS study guide1, some of the common red flags for money laundering or financing terrorism are:
* Customers who provide insufficient or suspicious information, such as unusual or unverifiable identification documents, different taxpayer identification numbers, or vague or inconsistent information about their business or source of funds.
* Transactions that have unusual features, such as large cash payments, unexplained payments from a third party, use of multiple or foreign accounts, complex or illogical transactions, or transactions that are inconsistent with the customer's profile or expected behavior.
* Geographic concerns, such as transactions involving high-risk jurisdictions, offshore financial centers, secrecy havens, or countries subject to sanctions or embargoes.
* Ultimate beneficial ownership that is unclear, such as customers who use shell companies, trusts, or other legal entities to obscure their identity or the identity of the true owners or controllers of the funds or assets.
In this scenario, two red flags that could indicate money laundering or financing terrorism are:
* B. The guarantor company's ownership structure is overly complex. This could be an attempt to hide the true source or destination of the funds, or to evade regulatory or law enforcement scrutiny. The use of a trust formed in a Caribbean island and a holding company based in a European secrecy haven could also indicate geographic concerns, as these jurisdictions are known for their low transparency and high confidentiality.
* D. The ultimate beneficial owner is a young lady who has gained her wealth through a small business.
This could be a case of false or misleading information, as the source of funds is not commensurate with the size or nature of the transaction. The fitness studio business could be a front or a cover for illicit activities, or the young lady could be a nominee or a straw man for the real owner or beneficiary.
= 1 ACAMS. (2020). Study Guide for the Certification Examination: Sixth Edition. Miami, FL: ACAMS.
NEW QUESTION # 159
FATF的互評和跟進過程涉及哪些評估?
- A. 技術合規性評估與有效性評估
- B. 國家審計評估與交易監控評估
- C. 制裁風險評估和該國的國家風險評估
- D. 風險評估與技術標準評估
Answer: A
Explanation:
The FATF conducts peer reviews of each member on an ongoing basis to assess levels of implementation of the FATF Recommendations, providing an in-depth description and analysis of each country's system for preventing criminal abuse of the financial system. The FATF Methodology for assessing compliance with the FATF Recommendations and the effectiveness of AML/CFT systems sets out the evaluation process.
Assessments focus on two areas, effectiveness and technical compliance. The effectiveness component will assess whether the AML/CFT systems are working, and the extent to which the country is achieving the defined set of outcomes. The technical compliance component will assess whether the necessary laws, regulations or other required measures are in force and effect, and whether the supporting AML/CFT institutional framework is in place.
References:
* Mutual Evaluations - Financial Action Task Force
* FATF Methodology for assessing compliance with the FATF Recommendations and the effectiveness of AML/CFT systems
* Procedures for the FATF Fourth Round of AML/CFT Mutual Evaluations
Reference: https://www.fatf-gafi.org/public ... mutual-evaluations.
html?hf=10&b=0&s=desc(fatf_releasedate)
NEW QUESTION # 160
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