ACAMS Updated CAMS Exam Questions and Answers by abu

According to section 312 of the USA PATRIOT Act, U.S. financial institutions that maintain correspondent accounts for foreign financial institutions must apply due diligence to such accounts. The due diligence must include obtaining information relating to the foreign bank’s anti-money laundering program, as well as the identity of any person who owns 10% or more of the foreign bank, unless the foreign bank is publicly traded. These requirements are intended to prevent the use of correspondent accounts by foreign shell banks or other entities that may pose a high risk of money laundering or terrorist financing.

References:

USA PATRIOT Act | FinCEN.gov

FACT SHEET for Section 312 of the USA PATRIOT Act Final Regulation and Notice of Proposed Rulemaking | FinCEN.gov

US PATRIOT ACT | State Street

CAMS Exam: USA PATRIOT Act Requirements for Opening a Correspondent Account

Structuring is the intentional evasion of a reporting or recordkeeping requirement by breaking down a large transaction into smaller ones, or by using multiple accounts, institutions, or persons to avoid triggering the threshold for reporting or recordkeeping. Structuring is also known as smurfing, and it is a common technique used by money launderers to conceal the source, ownership, or control of illicit funds.

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ACAMS Study Guide for the CAMS Certification Examination, 6th Edition, Chapter 2, Section 2.1.1, page 511

ACAMS CAMS Certification Video Training Course, Module 2, Lesson 2.1, video time 7:00-8:002

ACAMS CAMS Certification Practice Exam, Question 134, page 2853

An institution should incorporate on-going training, periodic audits, and ability to incorporate relevant legislative and regulatory AML changes in its AML policies and procedures. These are essential elements of an effective AML program, as they ensure that the staff are aware of their roles and responsibilities, the institution is compliant with the applicable laws and regulations, and the AML program is updated and adapted to the changing risks and environment.

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CAMS Certification Package - 6th Edition | ACAMS1

CAMS Certifications: How to Get CAMS Certified | ACAMS2

ACAMS CAMS Certification Video Training Course - Exam-Labs3

Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)4

https://www.naic.org/documents/committees_d_antifraud_meetingcc_faqsinsurance_103105.pdf

Paying the quarterly life insurance premium using money orders from two different banks is considered a red flag for potential money laundering. This is because money orders are often used by money launderers to avoid the scrutiny of banks and regulators, and to disguise the source and origin of funds12. Using money orders from two different banks also suggests that the client is trying to evade the reporting thresholds or the record-keeping requirements that apply to cash transactions3. The other transactions are not necessarily indicative of money laundering, although they may warrant further due diligence depending on the risk profile of the client and the nature of the insurance product.

References: 1: AML in Insurance: How to Detect & Combat Money Laundering, ComplyAdvantage, 5; 2: AML fraud flags: best practices for insurers, Thomson Reuters, 6; 3: Money Laundering ‘Red Flags’: How To Spot Risky Scenarios, ThinkAdvisor, 7