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ACAMS Certified Anti-Money Laundering Specialists Sample Questions (Q389-Q394):

NEW QUESTION # 389
A compliance officer was recently reviewing transactional data for an international charity and found transactions that present a higher risk.
Which reason is cause for terminating the banking relationship?

A. The charity has several incoming international funds transfers
B. The charity has had a high a high turnover rate of official positions
C. The charity is headquartered in a country on the Office of Foreign Assets Control list
D. The flow of funds both in and out are complex and hard to trace

Answer: C

Explanation:
The Office of Foreign Assets Control (OFAC) is a US agency that administers and enforces economic and trade sanctions based on US foreign policy and national security goals1. OFAC has a list of sanctions programs and country information for various regions and topics, such as Russia, Iran, North Korea, Cuba, and more2. If a charity is headquartered in a country on the OFAC list, it means that the US government has imposed restrictions or prohibitions on transactions or dealings with that country, its government, entities, or individuals. This poses a high risk of violating the sanctions regulations and exposing the bank to legal, regulatory, or reputational consequences. Therefore, the bank may decide to terminate the banking relationship with the charity to avoid such risks.
The other options are not sufficient reasons to terminate the banking relationship, as they may not indicate illegal or suspicious activities by the charity. A high turnover rate of official positions may be due to various factors, such as organizational changes, staff turnover, or personal reasons. It does not necessarily imply that the charity is involved in money laundering or terrorist financing. However, the bank should verify the identity and authority of the new officials and update the customer due diligence information accordingly. The charity may have several incoming international funds transfers because it receives donations or grants from different sources or countries. This is not unusual for an international charity, as long as the funds are consistent with its stated purpose and activities. The bank should monitor the transactions and report any anomalies or red flags to the relevant authorities. The flow of funds both in and out may be complex and hard to trace because the charity operates in multiple jurisdictions or sectors, or has a decentralized or layered structure. This may increase the risk of money laundering or terrorist financing, but it does not necessarily mean that the charity is engaged in such activities. The bank should conduct enhanced due diligence and ongoing monitoring of the charity's transactions and beneficiaries, and apply a risk-based approach to mitigate the potential risks.

NEW QUESTION # 390
Combating the Financing of Terrorism (CFT)]
Which is a key aspect in the FATF Recommendations that best describes the essential foundation for allocating resources in AML/CFT regimes for countries and financial institutions (FIs)?

A. Applying a risk-based approach
B. Performing country peer-to-peer evaluations
C. Enforcing mutual legal assistance
D. Implementing targeted financial sanctions

Answer: A

Explanation:
The risk-based approach (RBA) is an essential foundation of the FATF Recommendations, as it allows countries, competent authorities and financial institutions to adopt a more flexible set of measures to target their resources more effectively and apply preventive measures that are commensurate to the nature of risks, in order to focus their efforts in the most effective way. The RBA is not optional, but a prerequisite for the effective implementation of the FATF Standards. The RBA requires the identification, assessment and understanding of the ML/TF risks to which the countries and FIs are exposed, and the implementation of AML
/CFT measures that are proportionate and tailored to those risks. The RBA is not a "zero failure" approach, but a way to mitigate the risks in the most efficient and effective manner.
:
FATF Recommendations, Introduction, page 11
FATF Guidance on the Risk-Based Approach to Combating Money Laundering and Terrorist Financing - High Level Principles and Procedures, page 3 Risk-based Approach (RBA), What is the Risk-based Approach (RBA)?

NEW QUESTION # 391
Which aspect of the USA PATRIOT Act impacts foreign financial institutions?

A. Providing authority to impose special measures on institutions that are of primary money-laundering concern
B. Requiring enhanced due diligence for foreign shell banks
C. Expanding the anti-money laundering program requirements to all foreign financial institutions
D. Expanding sanctions requirements to a U.S. financial institution's foreign branches

Answer: A

Explanation:
Reference: https://www.imf.org/external/np/leg/sem/2002/cdmfl/eng/tompki.pdf (8)

NEW QUESTION # 392
Release of the EU's Fourth AML Directive resulted in what change to member state*s procedures? (Select Two.)

A. The threshold for reporting suspicious transactions decreased from 15,000 EUR to 10,000 EUR.
B. The scope of obliged entities was enlarged from casinos to all providers of gambling services.
C. Money laundering and terrorist financing were defined as separate crimes, expanding the directive's measures.
D. All financial institutions were required to identify and verify the beneficial owner of legal entities.
E. Knowledge of criminal conduct could be inferred from objective factual circumstances.

Answer: A,D

Explanation:
Explanation
According to the Certified Anti-Money Laundering Specialist (the 6th edition), Section 2.2.2 The EU Fourth AML Directive, the release of the EU's Fourth AML Directive resulted in the threshold for reporting suspicious transactions decreasing from 15,000 EUR to 10,000 EUR (Answer A) and all financial institutions were required to identify and verify the beneficial owner of legal entities (Answer B). The directive also defined money laundering and terrorist financing as separate crimes, which expanded the directive's measures (Answer C). Answer D is incorrect as the scope of obliged entities was not enlarged from casinos to all providers of gambling services, but rather to all providers of payment services. Answer E is also incorrect as the directive does not provide that knowledge of criminal conduct can be inferred from objective factual circumstances. Reference: Certified Anti-Money Laundering Specialist (the 6th edition), Section 2.2.2 The EU Fourth AML Directive, p. 12.

NEW QUESTION # 393
the Financing of Terrorism (CFT)]
Afinancial institution (FI) is investigating an alertgenerated by theautomated transaction monitoring system. TheAML analystmust determine whether the alert should beescalated for further investigationor archived as afalse positive.
Which action might bereasonablefor the AML analyst to take?

A. Performbelow-the-line testingto ensure the automated monitoring system is operating effectively.
B. Send arequest for information (RFI)to the counterparty bank involved in the transaction that caused the alert.
C. Requestinformation from the relationship managerassigned to the account that caused the alert.
D. Restrict the client's access to the account.

Answer: C

Explanation:
TheAML analyst must gather additional informationbefore determining if an alert is suspicious.
* Option C (Correct):Requesting information from the relationship managerhelps determineif the transaction is in line with the customer's profile.
* Option A (Incorrect):Below-the-line testingis useful forcalibrating AML models, but it doesnot help in real-time case evaluation.
* Option B (Incorrect):Directly contacting a counterparty bankmaynot be appropriatewithout internal analysis first.
* Option D (Incorrect):Restricting accessis aserious actionthat should only be takenafter a full investigation.
Reference:FATF Recommendation 10 (Customer Due Diligence), Wolfsberg Group Guidance on AML Investigations, FinCEN Transaction Monitoring Guidelines.

NEW QUESTION # 394
......

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