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

According to a report by the OECD, government officers are among the occupations that are particularly vulnerable to the use of false identities and identity theft. This is because government officers have access to sensitive and confidential information, such as personal data, tax records, social security benefits, passports, visas, and licenses. Identity fraudsters may target government officers to obtain or alter such information, or to impersonate them to access restricted areas or systems. Identity fraud involving government officers may facilitate tax evasion, money laundering, corruption, terrorism, and other crimes1.

Some examples of identity fraud schemes involving government officers are:

Rogue agents in the immigration services sector who issue fake or fraudulent documents, such as passports, visas, orresidence permits, to facilitate the entry or stay of illegal immigrants, criminals, or terrorists12.

Corrupt tax officials who use false identities to create fictitious taxpayers or employers, or to modify tax records, to evade taxes or to claim fraudulent refunds or credits13.

Impostors who pose as government officers, such as police, customs, or revenue agents, to extort money or information from unsuspecting victims, or to access secure facilities or databases1 .

REPORT ON IDENTITY FRAUD: TAX EVASION AND MONEY LAUNDERING VULNERABILITIES

Identity Fraud and Immigration Services

Identity Theft and Tax Fraud

[Identity Theft and Government Impersonation Scams]

According to the Egmont Group of Financial Intelligence Units, which is a network of over 160 FIUs that promotes international cooperation and information exchange, FIUs should share information with foreign FIUs spontaneously, without prior request, when they have reasonable grounds to believe that the information is relevant for the receiving FIU1. This principle is also reflected in the FATF Recommendation 40, which states that FIUs should exchange information with other FIUs, especially when this information concerns money laundering, predicate offences, or terrorist financing2. Spontaneous information sharing can enhance the effectiveness of FIUs, as it can help to identify new leads, trends, patterns, or typologies, as well as to prevent or disrupt criminal activities1.

The other options are not consistent with the best practices of FIU information sharing. For example:

In accordance with Wolfsberg guidelines, submit the information to the other FIU in written form. The Wolfsberg Group is an association of 13 global banks that issues guidance and standards on anti-money laundering and counter-terrorist financing. However, the Wolfsberg guidelines are not binding for FIUs, and they do not specify the format or channel of informationexchange between FIUs3. Moreover, submitting information in written form may not be the most efficient or secure way of communication, as it may cause delays, errors, or breaches of confidentiality.

Take no action until contacted by the other FIU. This option contradicts the principle of spontaneous information sharing, as it implies that the FIU with the relevant information will wait for a formal request from the other FIU, instead of proactively sharing the information. This may result in missed opportunities, inefficiencies, or failures in detecting or preventing money laundering or terrorist financing.

Request approval from the Egmont Group prior to sharing the information with the other FIU. This option is unnecessary and impractical, as the Egmont Group does not have the authority or the capacity to approve or deny individual information requests or exchanges between FIUs. The Egmont Group provides a platform and a framework for FIU cooperation, but it does not interfere with the operational autonomy or the bilateral relations of its members4.

FATF Recommendation 40: Other Forms of International Co-operation

Egmont Group of Financial Intelligence Units Principles for Information Exchange Between Financial Intelligence Units

Wolfsberg Group

Egmont Group

Vendors and third-party relationships pose financial crime risks, particularly when theyoperate in sanctioned jurisdictions. Organizations must ensure thatthey are not directly or indirectly violating economic sanctionswhen engaging with vendors.

Option D (Correct):If a vendor provides services tosanctioned entities or individuals, an organizationrisks violating OFAC, EU, or UN sanctions laws, potentially leading tofines, legal action, or reputational damage. Engaging in business in asanctioned regionrequires strictdue diligence and licensing.

Option A (Incorrect):Thepersonal backgroundof an employee isnot relevantunless theycurrently have direct ties to a sanctioned jurisdiction or person.

Option B (Incorrect):Alack of majority ownershipdoes not automatically indicateAML risk; however, organizations should still assessownership structures for opacity.

Option C (Incorrect):Privately held companiescan betransparentif theydisclose ownership and operate within compliance standards.

Why This Matters:

Failing toscreen vendors for sanctions riskscan result insevere penalties, reputational harm, and regulatory scrutiny.OFAC (U.S.), EU, and UN sanctions prohibit business transactions with specific countries, entities, and individuals. Organizations mustconduct thorough due diligencetoidentify and mitigate sanctions risks.

SAR information ishighly sensitive, and institutionsmust follow strict confidentiality rulesto 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 riskswithout disclosing confidential details.

Option A (Incorrect):Providingall possible detailsmay violateSAR confidentiality laws.

Option B (Incorrect):Sharing full SAR copieswith non-compliance staff isnot permittedunder AML regulations.

Option C (Incorrect):Naming specific customers under SAR reviewrisks"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.

Trade-based money laundering (TBML) involves manipulating trade transactions to move illicit funds rather than goods. One common technique is over-invoicing, where an exporter intentionally inflates the invoice value of goods. In this scenario, an England-based exporter would over-invoice a shipment to Cyprus. By doing so, the exporter creates a surplus amount that can be transferred back to the terrorist organization in England, effectively disguising the movement of illicit funds12.

An enterprise-wide compliance culture is a centralized, coordinated approach to ethics and compliance program design and assessment that cuts across multiple business units within an organization1. One key aspect of promoting such a culture is that the relevant information should be shared throughout the organization, so that all employees are aware of the compliance risks, policies, procedures, and expectations, and can act accordingly2. Sharing information also facilitates collaboration, communication, and feedback among different functions and levels of the organization, and helps identify and address any gaps or issues in the compliance program3. By contrast, the other options are not conducive to an enterprise-wide compliance culture, as they either create silos, conflicts, or inefficiencies in the compliance function.

1: Enterprise Compliance Risk Management Services | Deloitte US

2: Enterprise Risk Management and Risk Culture - McKinsey & Company

3: FRB: Speech, Bies–Enterprise-wide Compliance Programs–February 4, 2004