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

Specialized AML training must be relevant to the specific risks the corporate banking team faces, including legal/regulatory expectations and the ML/TF typologies applicable to their products and customer base.

Applicable AML laws and regulations (B):“Staff must be aware of the applicable AML/CFT laws and regulatory requirements relevant to their business area.”(CAMS 6th Edition, Chapter: AML Training and Awareness)

Money laundering typologies applicable to corporate loans (D):“Training should include typologies and red flags that are most relevant to the risks present in the specific business line, such as corporate lending.”(CAMS 6th Edition, AML Training for High-Risk Departments)

Incorrect Options:

A: Monetary instrument reporting is more relevant to retail/branch banking.

C: Regulatory exam best practices are for compliance teams, not business-line relationship managers.

The following were the key features of the Second Directive:

• It extended the scope of the First Directive beyond drug-related crimes. The definition of “criminal activity” was expanded to cover not just drug trafficking, but all serious crimes, including corruption and fraud against the financial interests of the European community.

• It explicitly brought bureaux de change and money remittance offices under AML coverage.

• It clarified that knowledge of criminal conduct can be inferred from objective factual circumstances.

Reputational risk is the potential for negative publicity, public perception, or legal action to adversely affect a financial entity’s image, brand, or customer loyalty1. Violating AML laws can have significant reputational risks for financial entities, as they may be perceived as facilitating or enabling money laundering, terrorist financing, or other illicit activities. This can result in a loss of trust, credibility, and revenue from existing and potential customers, especially those who are high-profile, sensitive, or socially responsible23. Moreover, violating AML laws can also attract negative media attention, regulatory scrutiny, and legal action, which can further damage the reputation of the financial entity and expose it to additional sanctions, fines, or penalties4.

1: ACAMS, CAMS Study Guide, 6th Edition, Chapter 1, page 16

2: ComplyAdvantage, 5 AML Reputational Risk Considerations for 2023, link

3: Exam-Answer, Reputational Risk Consequences for Violating AML Laws, link

4: Unit21, 8 AML Penalties, Fines, and Sanctions + Examples You Should Avoid, link

the Office of Foreign Assets Control (OFAC) has the authority to prohibit or reject any trade or financial transactions involving specified countries, entities, and individuals that are subject to U.S. economic sanctions, unless such transactions are authorized by a general or specific license issued by OFAC. This applies to transactions that occur within the U.S. territory, as well as transactions that involve U.S. persons, U.S. goods, or the U.S. financial system, regardless of where they take place. This is one of the key aspects of OFAC’s extraterritorial reach, which means that OFAC can enforce its sanctions programs beyond the U.S. borders.

Home | Office of Foreign Assets Control, section “Mission”: “The Office of Foreign Assets Control ("OFAC") of the US Department of the Treasury administers and enforces economic and trade sanctions based on US foreign policy and national security goals against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the United States.”

The Aggressive Extraterritorial Reach of U.S. Economic Sanctions: Foreign Company Exposure to OFAC Enforcement, section “A. Bases for OFAC jurisdiction over foreign parties”, paragraph 1: “One key aspect of the Office of Foreign Assets Control’s extraterritorial reach includes the blocking of certain non-United States initiated transactions for or through the United States (U.S.) for benefit of a restricted person or entity.”

The global reach of OFAC sanctions, section “The global reach of OFAC sanctions”, paragraph 1: “OFAC sanctions are trade and economic sanctions administered by The U.S. Treasury Department’sOffice of Foreign Asset Control (OFAC). They are often intended to have extra-territorial effect, meaning that they apply outside the U.S. territory. In some instances a connection with the U.S. territory is required.”

"Prohibit or reject unlicensed trade and financial transactions with specified countries,

entities, and individuals. "

this activity is unusual and inconsistent with the expected behavior of an accounting firm’s operational account. The account should normally receive fees from clients that are proportional to the services rendered and reflect the market rates. Receiving international payments that are substantially higher than other fees could indicate that the account is being used to launder money or finance terrorism by disguising illicit funds as legitimate income. This could trigger a red flag for the bank and prompt a comprehensive review of the account.

ACAMS Study Guide 6th Edition, Chapter 1, Section 1.6, page 24: “Methods to launder money used in banks and other deposit taking institutions”.

ExamTopics, Question 446: “An accounting firm opened an account at a bank that is intended to be used as the operational account for the business. After a few months, a comprehensive review of the account was triggered due to unusual activity on the account. Which most likely triggered the review?”

TheFATF 40 Recommendationsprovide aglobal AML/CFT framework, and theImmediate Outcomesassess effectiveness.

Option A (Correct):Therisk-based approach (RBA)is the foundation ofmodern AML complianceand is mandated byFATF Recommendation 1.

Option B (Incorrect):Interpretive notes are public documentsavailable to all jurisdictions, not private.

Option C (Incorrect):The40 Recommendations are regularly updated, incorporating new technology (e.g., virtual assets in 2019).

Option D (Incorrect):The11 Immediate Outcomesassess theeffectiveness of AML systems globally, not just for high-risk countries.

If a financial institution wishes to close an account due to concerns about potential money laundering or other financial crimes, it is generally required to file a suspicious activity report (SAR) with the appropriate government agency. However, there may beinstances where the government requires the account to remain open for ongoing investigation purposes.

In such cases, the government must provide a written request under proper letterhead and authority to keep the account open. This document will serve as legal justification for the financial institution to maintain the account, even though it may pose a higher risk for money laundering or other financial crimes.