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ACAMS Certified Anti-Money Laundering Specialists Sample Questions (Q412-Q417):

NEW QUESTION # 412
What describes the Black Market Peso Exchange money laundering method?

A. The best known money laundering method used by known terrorists
B. A method primarily used by narcotics traffickers to transfer value back to the source country
C. An undercover technique to identify politically exposed persons who may assist money launderers
D. A method used to smuggle dollars or pesos across that border from the U.S. to Mexico, and vice versa

Answer: B

Explanation:
The Black Market Peso Exchange (BMPE) is a trade-based money laundering technique commonly used by narcotics traffickers based in Colombia and Mexico. The central feature is the use of a money trader to ensure that the revenue from drug sales in the U.S. doesn't actually cross any borders. Instead, those dollars are used to purchase any number of legitimate commodities from unsuspecting businesses on behalf of legitimate South American businesspersons, whose legitimate imports are used to obtain pesos for the drug cartels12. The BMPE involves six distinct steps:
Obtaining criminal proceeds: The drug cartels sell drugs for dollars in the U.S.
Involvement of intermediary services: The drug cartels sell the dollars to black market peso exchangers in Colombia at a discounted rate.
Identification of complicit companies: The black market peso exchangers identify exporting companies in the U.S. and importing companies in South America that are willing to participate in the scheme.
Placement of funds: The black market peso exchangers deposit the dollars into U.S. bank accounts or use money service businesses or other methods to transfer the funds.
Layering of funds: The black market peso exchangers use the funds to purchase monetary instruments such as checks, money orders, or wire transfers, or to pay for the goods ordered by the South American importers.
Integration of funds: The South American importers receive the goods or the monetary instruments and use them to pay for their imports or to sell them for pesos in the local market.
Reference:
1: Black Market Peso Exchange in Money Laundering - Financial Crime Academy
2: Overview - FinCEN.gov

NEW QUESTION # 413
A recent anti-money laundering audit revealed several regulatory reporting violations and lapses with the organization's anti-money laundering policy. As a result, the compliance officer has created a follow-up matrix to document progress in correcting the identified deficiencies.
To whom should the compliance officer provide regular updates of corrective action to help ensure the appropriate oversight?

A. Business line managers
B. Audit management
C. Human Resources
D. Designated board committee

Answer: D

Explanation:
The compliance officer should provide regular updates of corrective action to the designated board committee, as they are ultimately responsible for the oversight of the organization's anti-money laundering program. The board committee should be informed of the audit findings, the corrective action plan, the progress and challenges, and the completion of the remediation. This will help ensure that the board committee is aware of the risks and issues, and can provide guidance and support to the compliance officer and the management.
Reference:
ACAMS CAMS Certification Study Guide 6th Edition, Chapter 2, page 671
ACAMS CAMS Certification Exam Outline, Domain 2, Task 2.52
ACAMS CAMS Certification Flashcards, Question 893

NEW QUESTION # 414
Combating the Financing of Terrorism (CFT)]
Which Trust parties should be identified to determine the true nature of the Trust relationship according to Basel guidelines? (Choose three.)

A. Beneficiaries
B. Respondents
C. Payees
D. Settlors/grantors
E. Trust Administrators
F. Trustees

Answer: A,D,F

Explanation:
According to the Basel guidelines on customer due diligence for banks, a trust is a legal arrangement whereby a person (the settlor or grantor) transfers the legal ownership of specific assets to another person or entity (the trustee) to hold for the benefit of a third person or persons (the beneficiaries)1. The Basel guidelines recommend that banks should identify and verify the identity of the following parties to determine the true nature of the trust relationship:
* The trustee, who is the person or entity that has the legal authority and duty to manage the trust assets and distribute them to the beneficiaries according to the trust deed2. The trustee may also be the settlor, the beneficiary, or both, depending on the type and structure of the trust3.
* The beneficiaries, who are the persons or entities that have a beneficial interest in the trust assets or income, either presently or in the future4. The beneficiaries may be named individuals, classes of persons, or charitable causes.
* The settlor or grantor, who is the person or entity that creates the trust and transfers the legal ownership of the assets to the trustee. The settlor or grantor may also retain some rights or powers over the trust, such as the ability to appoint or remove trustees, beneficiaries, or protectors.
The other three options are incorrect because:
* Respondents are not trust parties, but rather financial institutions that maintain correspondent banking relationships with other financial institutions. Respondents are not relevant for the identification of the trust relationship, but rather for the due diligence of the correspondent banking relationship.
* Payees are not trust parties, but rather persons or entities that receive payments from the trust or other sources. Payees are not relevant for the identification of the trust relationship, but rather for the monitoring of the transactions and activities of the trust.
* Trust administrators are not trust parties, but rather persons or entities that provide administrative services to the trust, such as accounting, record-keeping, or tax compliance. Trust administrators are not relevant for the identification of the trust relationship, but rather for the assessment of the risk and complexity of the trust.
:
1: Basel Committee on Banking Supervision, Customer due diligence for banks, October 2001, 4, p. 17 2:
Basel Committee on Banking Supervision, Customer due diligence for banks, October 2001, 4, p. 17 3:
ACAMS, CAMS Study Guide, 6th Edition, Chapter 5,p. 111 4: Basel Committee on Banking Supervision, Customer due diligence for banks, October 2001, 4, p. 17 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 5, p. 111 : Basel Committee on Banking Supervision, Customer due diligence for banks, October
2001, 4, p. 17 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 5, p. 111 : Basel Committee on Banking Supervision, Customer due diligence for banks, October 2001, 4, p. 10 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 5, p. 112 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 5, p. 112

NEW QUESTION # 415
The local manager of a remote mortgage origination department of a financial institution has just discovered that sanctions screening of new customers is not being performed.
Which action should the local manager take in this situation?

A. Do nothing because the department only handles a very small number of mortgages
B. Immediately inform the regulators
C. Start screening new customers
D. Immediately inform senior management

Answer: D

Explanation:
This action is the most appropriate because it demonstrates the local manager's responsibility and accountability for the sanctions compliance program. Sanctions screening is an important part of the Know Your Customer (KYC) and Anti-Money Laundering (AML) processes, as it helps to identify and prevent transactions with sanctioned individuals or entities, which could expose the financial institution to legal, regulatory, and reputational risks. Failing to perform sanctions screening could result in violations of sanctions laws and regulations, which could lead to fines, penalties, sanctions, or even criminal prosecution. Therefore, the local manager should immediately inform senior management of the issue, so that they can take corrective actions, such as implementing screening procedures, conducting a risk assessment, reviewing existing customers, reporting any potential violations, and providing training and guidance to the staff.
The other actions are not appropriate because they either do not address the root cause of the problem, or they could worsen the situation. Starting screening new customers without informing senior management could create a false sense of compliance, and it could also miss the existing customers who may be sanctioned.
Immediately informing the regulators without informing senior management could undermine the trust and communication within the organization, and it could also trigger an investigation or enforcement action before the issue is resolved internally. Doing nothing because the department only handles a very small number of mortgages could be a sign of negligence or indifference, and it could also expose the financial institution to significant risks, as even one transaction with a sanctioned party could have serious consequences.
References:
* CAMS Certification Package - 6th Edition | ACAMS, Chapter 4: Developing and Implementing an AML Training Program, pp. 97-98
* CAMS Certifications: How to Get CAMS Certified | ACAMS, CAMS Study Guide, pp. 76-77
* What is Sanctions Screening and How Does It Work? | Jumio, Introduction and Benefits of Sanctions Screening
* Sanctions Screening: Challenges and Control Considerations, Background and Regulatory Expectations for Sanctions Screening
* Sanction Screening: A Complete Guide | KYC AML Guide, What is Sanction Screening and Why is it Important?

NEW QUESTION # 416
A financial institution's monitoring system triggers an alert and an internal investigation has confirmed the activity as suspicious. Which of the following should an anti-money laundering specialist do before submitting the suspicious transaction report?

A. Secure documents related to the suspicious circumstances and the decision to report.
B. Check with other financial institutions in accordance with the relevant law.
C. Contact the customer for further information without disclosing the suspicion.
D. Add information related to the suspicious activity to the customer's account-opening file.

Answer: A

Explanation:
The anti-money laundering specialist should secure all the documents related to the suspicious activity and the decision to report before submitting the suspicious transaction report (STR). This is to ensure that the evidence is preserved, the confidentiality is maintained, and the audit trail is documented. The documents may include the customer identification, transaction records, account statements, monitoring alerts, investigation reports, and any other relevant information12.
Checking with other financial institutions, adding information to the customer's file, or contacting the customer are not appropriate actions to take before submitting the STR. These actions may compromise the confidentiality of the report, alert the customer of the suspicion, or interfere with the investigation by the competent authorities12.
References: 1: ACAMS (2020), Study Guide for the Certification Examination, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams-certification-package-6th-edition, pp. 35-36. 2: ACAMS (2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams-certification-package-6th-edition, Module 2.

NEW QUESTION # 417
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