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

According to the Anti-Money Laundering Specialist (the 6th edition) study guide, one of the main challenges of providing on-line services to customers is the verification of theiridentity and the authentication of their transactions1. The lack of face-to-face contact and the use of electronic documents increase the risk of identity fraud, impersonation, and account takeover2. Therefore, financial institutions offering on-line services need to implement robust customer due diligence (CDD) measures, such as using multiple sources of information, verifying biometric data, and applying risk-based monitoring3.

1: CAMS Study Guide, 6th Edition, Chapter 4, Section 4.1, page 103

2: CAMS Study Guide, 6th Edition, Chapter 4, Section 4.2, page 104

3: CAMS Study Guide, 6th Edition, Chapter 4, Section 4.3, page 105

 According to the ACAMS Study Guide, an effective AML program should include four key elements: internal controls, independent testing, designated compliance officer, and training1. Internal controls are policies, procedures, and processes that help prevent, detect, and report money laundering and terrorist financing activities. One of the essential components of internal controls is customer due diligence (CDD), which involves identifying and verifying the customer, understanding the nature and purpose of the customer relationship, and conducting ongoing monitoring of customer transactions and risk profiles2. Ongoing monitoring is crucial for detecting and reporting suspicious activities, updating customer information, and reassessing customer risk ratings3.

In this case, the bank’s written AML program does not address monitoring of customer account activity, which is a significant gap in its internal controls. The bank serves high-income, high net-worth clients who include non-residents and offshore businesses, which are considered high-risk customers for AML purposes4. The bank should have enhanced due diligence (EDD) measures for these customers, such as obtaining additional information, conducting more frequent reviews, and applying stricter transaction limits5. The fact that the consultant and the bank have mutual clients does not affect the risk rating or the due diligence requirements of those customers. Therefore, the consultant should recommend the bank to revise its procedures to better assess ongoing customer activity and comply with the AML standards.

1: ACAMS Study Guide, Chapter 2: Developing an Effective Anti-Money Laundering Program

2: ACAMS Study Guide, Chapter 3: Conducting Customer Due Diligence

3: ACAMS Study Guide, Chapter 4: Ongoing Monitoring and Suspicious Activity Reporting

4: ACAMS Study Guide, Chapter 5: Identifying High-Risk Customers

5: ACAMS Study Guide, Chapter 6: Applying Enhanced Due Diligence Measures

Microstructuring is a method of money laundering that involves breaking down large transactions into smaller amounts that are below the reporting threshold or the level of scrutiny of financial institutions. One of the red flags of microstructuring is frequent visits to make cash deposits of nominal amounts, as this may indicate an attempt to avoid detection and conceal the source or destination of illicit funds. Other red flags of microstructuring include checking accounts receiving cash deposits in amounts under $1,000 as infrequently as several times a month, followed by ATM withdrawals in foreign countries, or deposits that are inconsistent with the customer’s profile or business activity.

FinCEN Advisory – FIN-2010-A001, page 4

Red Flags of Money Laundering | PPT, slide 9

Red Flags of Microstructuring | CAMS Exam Preparation | ACAMS

Structured transactions are a common method of money laundering, where large amounts of cash are broken down into smaller deposits or withdrawals to avoid reporting thresholds or detection. The most effective tool to detect such transactions is a software program that can link apparently unrelated transactions by using various criteria, such as customer name, address, account number, identification number, transaction amount, date, time, location, etc. Such a program can help identify patterns, trends, and anomalies that may indicate money laundering activity.

ACAMS CAMS Certification Study Guide1, Chapter 2: Money Laundering Risks and Methods, Section 2.2: Common Money Laundering Methods, pp. 51-52

ACAMS CAMS Certification Video Training Course2, Module 2: Money Laundering Risks and Methods, Lesson 2.2: Common Money Laundering Methods

ACAMS CAMS Certification Exam Outline3, Domain 2: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), Task 2.2: Implement risk-based CDD, EDD and ongoing due diligence policies, procedures and processes, p. 13

Making payments via a company located in a jurisdiction that is known to have lax anti-money laundering controls is a sign of suspicious activity and should be reported. When making a payment of this nature, the insurance company should be aware of the client's source of funds and the possible risks associated with the transaction.

The most suspicious transaction indicators related to casino activities are:

A client requests a winnings check (cheque) in a third party’s name. This could indicate an attempt to conceal the source or ownership of the funds, or to evade reporting requirements.

Acquaintances bet against each other in even-money games and it appears they are intentionally losing to one of the parties. This could indicate a scheme to launder money through the casino by transferring funds from one party to another without attracting attention.

A client requests the transfer of winnings to the bank account of a third party in a country without an effective anti-money laundering regime. This could indicate an attempt to move funds to a high-risk jurisdiction or to a person or entity that is involved in illicit activities.

The option that is not suspicious is:

A new client who is a large volume player asks the casino operator about the ability to transfer the funds to other locations in the same country. This could be a legitimate inquiry from a high-net-worth individual who travels frequently and wants to access their funds conveniently.

ACAMS CAMS Certification Video Training Course - Exam-Labs1

Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)2

ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 8, page 173

https://www.acams.org/wp-content/uploads/2019/08/ACAMS-Study-Guide-6th-Edition-Chapter-8.pdf

A large cash deposit is a red flag for money laundering when it is inconsistent with the customer’s profile, behavior, or business activity. A customer who has never conducted a transaction in cash before may be trying to avoid detection or conceal the source of the funds. A customer who transacts in segments smaller than the reporting thresholds at various times during the day may be engaging in structuring or smurfing, which are techniques to evade currency transaction reporting requirements. A customer who follows a large cash deposit with an immediate wire transfer to an offshore secrecy haven may be attempting to layer or move the funds to a jurisdiction with weak anti-money laundering controls or high confidentiality. These scenarios indicate a high risk of money laundering and warrant further investigation and reporting.

A customer who operates a cash-based business may have a legitimate reason to make a large cash deposit, depending on the nature and scale of the business. However, this does not mean that the customer is exempt from scrutiny or monitoring, as cash-based businesses are also vulnerable to money laundering abuse. The bank should verify the source and purpose of the funds, and compare the deposit with the customer’s expected activity and turnover.

CAMS Certification Package - 6th Edition, Chapter 4: Conducting and Supporting the Investigation Process, pp. 97-98.

Warning signs of money laundering | The Law Society, Section: Cash deposits and withdrawals.

According to the Anti-Money Laundering Specialist (the 6th edition) study guide, an effectiveanti-money laundering program should be subject to periodic independent testing by a qualified party, such as an internal or external auditor, a consultant, or a compliance professional1. This ensures that the program is compliant with the applicable laws and regulations, and that it meets the standards of sound risk management and internal controls2. The regulatory authorities, a member of senior management, or the anti-money laundering specialist may not have the necessary expertise, objectivity, or independence to conduct a thorough and unbiased evaluation of the program.

1: CAMS Study Guide, 6th Edition, Chapter 2, Section 2.3, page 51

2: CAMS Study Guide, 6th Edition, Chapter 2, Section 2.4, page 52