ACAMS Updated CAMS Exam Questions and Answers by marcel

According to the FATF Recommendation 40, which sets the standards for international cooperation in relation to money laundering, associated predicate offences and terrorist financing, countries should ensure that exchanged information is used only for the purpose for which it was sought or provided, and that any dissemination or use of the information beyond the original scope is subject to prior authorization by the requested competent authority. Moreover, countries should have safeguards in place to ensure that the information exchanged is protected in a manner that is consistent with the way they protect their own information of a similar nature. One of the possible safeguards is to require the use of non-disclosure agreements or other legal instruments to prevent unauthorized access or disclosure of the exchanged information.

References: = FATF Recommendation 40, Section A.3; Compliance Trends: AML Information Sharing, Section: Cross-border AML information sharing; Safeguarding AML Information Exchanged with Other Countries, Section: Answers.

According to the Certified Anti-Money Laundering Specialist (CAMS) Sixth Edition manual, elements that can trigger a review of the existing relationship during the opening of a new account include recent adverse media on the client (page 60) and incoming transfers from high-risk jurisdictions (page 61). The other elements listed, such as regular checks on the flow of funds, a false positive result for name screening, and an estimated total income decrease, are not triggers for a review.

According to the ACAMS CAMS Certification Study Guide (6th edition), one of the red flags for money laundering is the structuring of cash transactions to avoid reporting thresholds. Structuring is the practice of breaking down large amounts of cash into smaller deposits or withdrawals that are below the reporting threshold of $10,000 in the United States or equivalent amounts in other jurisdictions. Structuring is done to evade the detection and reporting of cash transactions by financial institutions to the authorities. Therefore, when an accountable institution identifies that a customer is engaging in structuring or other forms of cash transaction manipulation, it should file a SAR/STR to report the suspicious activity1

References: 1: ACAMS CAMS Certification Study Guide (6th edition), page 64.

The customer’s profile and transactions are highly suspicious and indicative of possible money laundering. The customer’s income, source of wealth, and investment plans do not match with the large and frequent transfers from a diamond distributor, which is a high-risk business sector for money laundering. The customer’s transfers to Hong Kong, which is a high-risk jurisdiction for money laundering, also raise red flags. The anti-money laundering specialist should recommend contacting the competent authority and local law enforcement to report the suspicious activity and cooperate with any investigation. This is in accordance with the FATF Recommendation 20, which states that "If a financial institution suspects or has reasonable grounds to suspect that funds are the proceeds of a criminal activity, or are related to terrorist financing, it should be required, by law, to report promptly its suspicions to the financial intelligence unit (FIU)"1. The other options are not appropriate, as they do not address the urgency and severity of the situation.

References: 1: FATF (2012), International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation, FATF, Paris, France, www.fatf-gafi.org/recommendations.html, p. 19.