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ACAMS Certified Anti-Money Laundering Specialists (the 6th edition) Sample Questions (Q372-Q377):
NEW QUESTION # 372
The bank's Compliance Officer is tasked with designing standards based on Basel's KYC principles. Which essential elements should be included in the program? (Choose two.)
- A. Establishing on-going monitoring of high-risk accounts
- B. Appointing an independent audit function
- C. Conducting a money laundering risk assessment
- D. Documenting a customer acceptance policy
- E. Reporting suspicious activity
Answer: D,E
NEW QUESTION # 373
During the course of work on behalf of a client, a lawyer participated in the movement of money. If the lawyer suspects an act of money laundering, which of the following should the lawyer do according to European Union Money Laundering Directives?
- A. Adhere to business confidentiality laws.
- B. Follow bank secrecy laws.
- C. Report the facts to the competent authorities.
- D. Inform the client of the intent to terminate services.
Answer: A
Explanation:
According to the FATF Recommendations, financial institutions should maintain all necessary records on transactions and customers for at least five years, and make them available to competent authorities upon appropriate authority1. This includes records and documents related to suspicious transactions that have been reported to the financial intelligence unit (FIU) or other designated authorities. Providing the supporting documentation to competent authorities upon request is essential for the investigation and prosecution of money laundering and terrorist financing offences, as well as for the identification and tracing of criminal assets2.
Hinting to the customer that she should come in and explain her behavior is not a correct answer, as it may tip off the customer about the suspicion and compromise the effectiveness of the reporting system. Financial institutions should not disclose to the customer or to third parties that a suspicious transaction report (STR) or related information is being reported to the FIU3.
Maintaining adequate written documentation of all individuals and transactions reported is not a sufficient answer, as it does not imply cooperation with competent authorities. Financial institutions should not only keep records, but also provide them to the authorities when requested.
Submitting information upon receiving a legal request from parties involved in a civil lawsuit is not a relevant answer, as it does not relate to the cooperation with competent authorities for AML/CFT purposes. Civil lawsuits are not part of the AML/CFT framework, and financial institutions should not disclose confidential information to private parties without proper legal grounds.
References:
FATF Recommendation 11: Record-keeping 1
FATF Recommendation 31: Powers of law enforcement and investigative authorities 2 FATF Recommendation 21: Tipping-off and confidentiality 3
NEW QUESTION # 374
UN sanctions are the most effective and legitimate non-violent multilateral tools to respond to international security threats when they:
- A. Are swiftly adopted by all member states together with a strong enforcement mechanism.
- B. Can be applied internationally while being enforced at the domestic level.
- C. Can be implemented faster than other sanctions regimes.
- D. Are more clearly articulated than other sanctions regimes.
Answer: A
Explanation:
United Nations (UN) sanctions are binding on all UN member states, but their effectiveness depends on swift adoption and enforcement by national governments.
Option B (Correct): For UN sanctions to be effective, they must be enforced by all member states through strong domestic legal mechanisms.
Option A (Incorrect): UN sanctions are not necessarily implemented faster than unilateral sanctions (e.g., U.S. OFAC sanctions).
Option C (Incorrect): While UN sanctions apply internationally, enforcement depends on national governments, making implementation inconsistent.
Option D (Incorrect): Clarity of sanction measures is important, but enforcement is the primary factor determining effectiveness.
Key Features of UN Sanctions:
Mandated by the UN Security Council under Chapter VII of the UN Charter.
Binding on all 193 UN member states.
May include asset freezes, travel bans, and trade embargoes.
Best Practices for UN Sanctions Compliance:
Ensure national enforcement aligns with UN Security Council resolutions.
Monitor sanctioned individuals/entities through real-time screening tools.
Cooperate with international organizations to prevent sanctions evasion.
Reference:
FATF Recommendation 6 (Targeted Financial Sanctions)
United Nations Security Council (UNSC) Sanctions Guidelines
EU & OFAC Guidance on Sanctions Implementation
NEW QUESTION # 375
What are two legal risks of having inadequate privacy policies and procedures? (Choose two.)
- A. Diminished reputation
- B. Charges of deceptive business practices
- C. Industry of regulatory sanctions
- D. Higher marketing and public relations costs
Answer: B,C
Explanation:
Having inadequate privacy policies and procedures can expose an organization to legal risks such as industry or regulatory sanctions and charges of deceptive business practices. Industry or regulatory sanctions can result from violating the laws and regulations that govern data privacy and protection, such as the GDPR, the CCPA, or the GLBA. These sanctions can include fines, penalties, injunctions, or revocation of licenses. Charges of deceptive business practices can arise from misleading or false statements about how the organization collects, uses, or discloses personal data, or from failing to comply with its own privacy policies and procedures. These charges can lead to lawsuits, settlements, or enforcement actions by authorities such as the FTC or the state attorneys general.
References: =
The 4 Biggest Risks of Non-Compliance With Data Privacy Regulations
Security and privacy laws, regulations, and compliance: The complete guide An Ethical Approach to Data Privacy Protection
NEW QUESTION # 376
Enhanced due diligence (EDD) may be bypassed for which situation?
- A. On-boarding a casino headquartered in the EU or US that is part of an international hotel chain, provides less than 50% of overall revenue and that fully complies with group-wide policies and procedures.
- B. On-boarding a subsidiary in a high-risk country with a complex ownership structure of a long-standing and reputable customer based in the EU or US.
- C. On-boarding a branch or majority-owned subsidiary of an EU or US FI located in a high-risk third country that fully complies with group-wide policies and procedures.
- D. On-boarding a reputable Politically Exposed Person (PEP) from the EU onto the wealth management arm of a US financial institution (FI).
Answer: C
NEW QUESTION # 377
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