CAMS Exam Dumps - Certified Anti-Money Laundering Specialist (the 6th edition)

MSBs arevulnerable to financial crimedue to theircash-intensive natureandremittance services.

Option D (Correct):Hesitation to provide beneficiary detailssuggestsanonymity concerns, a common money laundering tactic.

Option E (Correct):Usingmultiple accounts under different namesis aknown structuring techniquetoevade detection.

Option A (Incorrect):Exchanging foreign currency is normal, though higher-risk transactions require monitoring.

Option B (Incorrect):Cash deposits are expectedin MSBs but needadditional risk factorsto be considered suspicious.

Option C (Incorrect):Frequent small transfersmay be normal forremittance businesses.

TheBasel Committee’s AML guidelinesemphasizerisk-based customer due diligence (CDD) and beneficial ownership transparency.

Option A (Correct):CDD policies must be risk-basedto applyenhanced due diligence (EDD) for high-risk customersandsimplified due diligence (SDD) for low-risk customers.

Option C (Correct):Banksmust verify the identity of customers and beneficial ownersto prevent financial crime risks.

Why Other Options Are Incorrect:

Option B (Incorrect):Numbered accountsare not strictly prohibitedbut requirestrict transparency and due diligence measures.

Option D (Incorrect):CDD proceduresmust be risk-based, not uniform across all customers.

Option E (Incorrect):Transactionsshould not be processed until full due diligence is completed, except in rare cases where regulatory exceptions apply.

Best Practices for Risk-Based Customer Due Diligence:

Apply EDD for high-risk entities (e.g., PEPs, offshore companies).

Ensure full beneficial ownership transparency.

Implement ongoing transaction monitoring for risk assessment.

TheUSA PATRIOT Actincludes provisions allowingthe U.S. government to seize assets linked to financial crime, even when held in foreign financial institutions.

Option A (Correct):Section 319(a) of the USA PATRIOT Actprovides U.S. regulators with the authority toseize funds deposited in U.S. correspondent accounts of foreign banks if linked to illicit activity.

Option B (Incorrect):Section 314(a)focuses oninformation sharing between law enforcement and financial institutions.

Option C (Incorrect):Section 319(b)enables U.S. authorities toseize funds linked to foreign correspondent banking accounts, but319(a) specifically deals with extraterritorial forfeiture.

Option D (Incorrect):Section 314(b)allowsfinancial institutions to voluntarily share AML-related information.

Why This Matters:

Foreign banks using U.S. correspondent accounts can be subject to U.S. jurisdiction.

Helps U.S. law enforcement disrupt global money laundering networks.

Encourages financial institutions to enhance correspondent banking due diligence.

ASuspicious Activity Report (SAR)is required when afinancial institution detects activity that raises suspicion of money laundering, terrorist financing, or fraud.

Option A (Correct):Inability to verify customer identification documentsis ared flag for potential financial crimeand may requirereporting to the Financial Intelligence Unit (FIU).

Option B (Incorrect):PEPs require enhanced due diligence (EDD), but their involvement alone does not automatically trigger a SAR.

Option C (Incorrect):Dealers in precious metals/stones are high-risk, but being in this industry alonedoes not warrant an automatic SAR.

Option D (Incorrect):Crypto-to-fiat transactions are not inherently suspicious, but they requiremonitoring for unusual activity.

Key SAR Filing Triggers:

Transactions that do not match the customer’s expected activity.

Incomplete, fraudulent, or unverifiable customer identification.

Use of shell companies or unusual intermediaries.

Large or structured transactions with no apparent legitimate purpose.

Best Practices for SAR Compliance:

Implement robust customer due diligence (CDD) processes.

Monitor transaction behavior against expected patterns.

Follow jurisdictional SAR filing deadlines to avoid penalties.

The USA PATRIOT Act of 20011 is a comprehensive anti-terrorism and anti-money laundering legislation that grants various powers and authorities to the US government to combat money laundering, terrorist financing, and other financial crimes. Among its provisions, Title III of the Act, also known as the International Money Laundering Abatement and Anti-Terrorist Financing Act of 20012, specifically addresses the issue of correspondent banking and the risks of money laundering and terrorist financing through foreign banks that maintain accounts with US banks. Section 319 of Title III3 authorizes the US Attorney General or the Secretary of the Treasury to issue a subpoena or summons to any foreign bank that maintains a correspondent account in the US, and to request any records relating to such account, including records maintained outside the US. Furthermore, Section 319(b) of Title III4 allows the US authorities to seize the funds of the foreign bank held with the US bank, if the foreign bank fails to comply with such a subpoena or summons, or if the US authorities initiate a civil forfeiture action against the funds in the correspondent account. Therefore, the USA PATRIOT Act is the correct answer, as it enables the US authorities to seize the funds of the foreign bank held with the US bank, if the correspondent account is found to have facilitated a transaction involving tainted funds.

Asset management companies handlelarge amounts of funds, making themprime targets for money launderers.

Option A (Correct):Negative news (adverse media) screeningis essential for identifyingpotential financial crime risks.

Option D (Correct):Understanding thesource and origin of assetsensures that fundscome from legitimate sources.

Option B (Incorrect):PEPs should not be automatically rejected, butenhanced due diligence (EDD)is required.

Option C (Incorrect):While onboarding interviews help,they are not a mandatory AML measure.

Option E (Incorrect):Financial stability reportsare useful, butnot directly linked to AML compliance.

AML Risks in Asset Management:

High-value transactions that may mask illicit wealth.

Layering through investment portfolios to hide the origin of funds.

Use of offshore structures to evade regulatory scrutiny.

Best Practices for AML in Asset Management:

Conduct enhanced due diligence (EDD) on high-net-worth clients.

Monitor large and unusual transactions.

Screen customers against PEP, sanction, and adverse media databases.

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.