Practice with ACAMS's Realistic CAMS Exam Questions and Get Accurate Answers for the Best Results
Practice with ACAMS's Realistic CAMS Exam Questions and Get Accurate Answers for the Best Results
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ACAMS Certified Anti-Money Laundering Specialists Sample Questions (Q73-Q78):
NEW QUESTION # 73
In the summer, an institution identifies anti-money laundering concerns regarding a customer's account activity. The customer, an ice cream, has deposited a lot of checks drawn on banks in foreign countries, sent large number of high dollar international wires to different countries, made cash deposits of a few hundred dollars every few days and written multiple checks for a few hundred dollars to the same dozen payees every two weeks.
Which two transaction types warrant investigation? (Choose two.)
- A. Regular cash deposits
- B. Checks drawn on banks in foreign countries
- C. The wires to foreign countries
- D. Repeated checks to the same payees
Answer: B,C
NEW QUESTION # 74
In the FATF 40 recommendations, the focus of AML efforts has been expanded beyond Financial Institutions.
Which three businesses and/or professions are covered? Choose 3 answers
- A. Trust and company service providers
- B. Dealers in art, when they engage in any cash transaction with a customer at or above a designated threshold
- C. Real estate agents when they are involved in transactions for clients concerning buying and selling properties
- D. casinos, when customers engage in financial transactions equal to or above a designated Threshold
Answer: A,C,D
Explanation:
According to the FATF 40 recommendations, the focus of AML efforts has been expanded beyond financial institutions to include other businesses and professions that are vulnerable to money laundering and terrorist financing risks. These include:
Casinos, when customers engage in financial transactions equal to or above a designated threshold.
Casinos are required to identify and verify the identity of their customers, keep records of transactions, report suspicious transactions, and implement internal controls and compliance programs to prevent money laundering and terrorist financing. The designated threshold is USD/EUR 3,000 or more1.
Real estate agents, when they are involved in transactions for clients concerning buying and selling properties. Real estate agents are required to identify and verify the identity of their customers and beneficial owners, keep records of transactions, report suspicious transactions, and implement internal controls and compliance programs to prevent money laundering and terrorist financing. Real estate transactions can involve large amounts of money and complex legal arrangements that can be used to conceal the source or destination of illicit funds2.
Trust and company service providers, when they prepare for or carry out transactions for a client concerning the creation, operation or management of legal persons or arrangements. Trust and company service providers are required to identify and verify the identity of their customers and beneficial owners, keep records of transactions, report suspicious transactions, and implement internal controls and compliance programs to prevent money laundering and terrorist financing. Trust and company service providers can facilitate the misuse of legal persons or arrangements, such as shell companies or trusts, to hide the true ownership and control of assets or funds3.
The other option, dealers in art, when they engage in any cash transaction with a customer at or above a designated threshold, is not covered by the FATF 40 recommendations. However, dealers in precious metals and stones are covered when they engage in any cash transaction with a customer at or above a designated threshold of USD/EUR 15,000 or more. Dealers in art may be subject to national or regional regulations that impose AML obligations on them, depending on the jurisdiction.
References:
FATF Recommendation 22: Designated Non-Financial Businesses and Professions: Customer Due Diligence FATF Recommendation 23: Designated Non-Financial Businesses and Professions: Other Measures FATF Recommendation 24: Transparency and Beneficial Ownership of Legal Persons
[FATF Recommendation 25: Transparency and Beneficial Ownership of Legal Arrangements]
NEW QUESTION # 75
Which of the following indicates potential money laundering activity by a lawyer?
- A. A lawyer's trust account receives a large-value wire transfer from a regulated insurance company and immediately transfers the same amount of funds received to the beneficiary's bank account in a low-risk country.
- B. A lawyer located in a higher-risk country deposits their firm's bank draft issued from their trust account to another lawyer's trust account located in a low-risk country for legal services rendered.
- C. A lawyer's trust account receives a large wire transfer deposit from a client that wanted to purchase a piece of property and then transfers the same amount to the property seller's lawyer's trust account.
- D. A lawyer's trust account regularly receives wire transfers from unknown remitters from a higher-risk country and immediately transfers the same amount of funds to a known beneficiary's account in a low-risk country.
Answer: D
Explanation:
Lawyers and legal professionals are frequently used in money laundering schemes, particularly through trust accounts that offer anonymity and client privilege protections.
Option A (Correct): Repeated wire transfers from unknown sources followed by immediate outward transfers suggest that the lawyer's trust account is being used as a pass-through account for laundering funds.
Option B (Incorrect): If legal services were actually rendered, this is a normal transaction unless other risk factors exist.
Option C (Incorrect): Receiving funds from a regulated insurance company is not inherently suspicious, unless the transaction is inconsistent with the lawyer's usual business activity.
Option D (Incorrect): Large transactions are normal in real estate purchases, as long as proper documentation exists.
Red Flags in Legal Sector Money Laundering:
Use of lawyer trust accounts to move funds with no legitimate business purpose.
Frequent transactions from high-risk jurisdictions.
Transactions that are inconsistent with the lawyer's area of practice.
Clients who refuse to disclose the source of funds.
Best Practices:
Apply AML measures to law firms handling financial transactions, as required by FATF's Designated Non-Financial Businesses and Professions (DNFBPs) guidelines.
Require enhanced due diligence (EDD) for high-risk clients and unusual transactions.
Reference:
FATF Report on Legal Professionals & Money Laundering
Wolfsberg Group Legal Sector AML Guidance
6th EU Anti-Money Laundering Directive (6AMLD) on DNFBPs
NEW QUESTION # 76
One of the red flags of microstructuring is:
- A. single activity in an account immediately following the opening of the account.
- B. frequent visits to make cash deposits of nominal amounts.
- C. check deposits followed by ATM withdrawals using debt card in retail store.
- D. depositing sequentially numbered checks.
Answer: B
Explanation:
Reference: https://www.acamstoday.org/developing-terrorist-financing-typologies-for-aml-programs/
NEW QUESTION # 77
What should a financial institution (FI) do in response to a formal law enforcement request to produce documents?
- A. Keep senior management informed at all times to strategically organize a defense to terminate the law enforcement request.
- B. Ask for an extension to review the Fl's privacy policy and confidentiality policy before providing any information under the law enforcement request.
- C. Verify the officer's identification and ask for the law enforcement request to be served when the Chief Executive Officer is available to sign for it.
- D. Designate a person responsible for the internal investigation in preparation of documents for the request.
Answer: D
Explanation:
According to the CAMS Study Guide (the 6th edition), page 184, when an FI receives a formal law enforcement request to produce documents, such as a subpoena, a search warrant, or a court order, it should designate a person responsible for the internal investigation in preparation of documents for the request. This person should be familiar with the FI's policies and procedures, the applicable laws and regulations, and the nature and scope of the request. The designated person should also coordinate with the FI's legal counsel, compliance officer, and senior management, and ensure that the FI preserves the confidentiality and integrity of the documents and the investigation.
References:
CAMS Study Guide (the 6th edition), page 1841
CAMS Certification Video Training Course, Module 4, Lesson 22
NEW QUESTION # 78
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