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ACAMS Certified Anti-Money Laundering Specialists Sample Questions (Q147-Q152):
NEW QUESTION # 147
What correspondent banking risk factor increases the risk for a Correspondent Bank?
- A. Major service provider to money service businesses
- B. Multi-national financial institution with global operations
- C. Offers international funds transfer to customers
- D. Limited product offering to customers in high-risk jurisdictions
Answer: A
NEW QUESTION # 148
An anti-money laundering audit identifies a significant weakness in how transaction monitoring alerts are cleared. Audit sampling identified potentially suspicious activity that was cleared as not suspicious. Management accepts the audit finding and develops a remediation plan.
What is the role of the auditor during the correction phase?
- A. Developing procedures to provide sufficient risk-based documentation for clearing alerts
- B. Providing training to the alert clearing department on the importance of effective alert clearing
- C. Validating the successful remediation of the issue once management indicates the issue is resolved
- D. Directing the remediation of the deficiency in a timely manner
Answer: C
NEW QUESTION # 149
To ensure that an institution's anti-money laundering program is current, which step should be taken?
- A. The program should be reassessed at least annually
- B. The program should be reviews by a federal law enforcement officer for gaps in controls
- C. The program should be evaluated and updated at least every six months be the Board of Directors
- D. The program should be sent to the institution's government regulator on a periodic basis
Answer: A
NEW QUESTION # 150
Which situation involving a vendor presents increased AML and/or sanctions risk to an organization?
- A. The vendor provides services to end users located in an area subject to economic sanctions.
- B. The vendor has no individuals that own or control more than 10% of the company.
- C. The vendor is organized as a privately held company.
- D. The vendor's sales representative was a refugee from a sanctioned jurisdiction as a child.
Answer: A
Explanation:
Option D (Correct): If a vendor provides services to sanctioned entities or individuals, an organization risks violating OFAC, EU, or UN sanctions laws, potentially leading to fines, legal action, or reputational damage. Engaging in business in a sanctioned region requires strict due diligence and licensing.
Option A (Incorrect): The personal background of an employee is not relevant unless they currently have direct ties to a sanctioned jurisdiction or person.
Option B (Incorrect): A lack of majority ownership does not automatically indicate AML risk; however, organizations should still assess ownership structures for opacity.
Option C (Incorrect): Privately held companies can be transparent if they disclose ownership and operate within compliance standards.
Why This Matters:
Failing to screen vendors for sanctions risks can result in severe penalties, reputational harm, and regulatory scrutiny. OFAC (U.S.), EU, and UN sanctions prohibit business transactions with specific countries, entities, and individuals. Organizations must conduct thorough due diligence to identify and mitigate sanctions risks.
Reference:
OFAC Sanctions Guidelines & Compliance Framework
EU Sanctions Regulations
FATF Recommendation 6 (Targeted Financial Sanctions Related to Terrorism & Proliferation)
NEW QUESTION # 151
An anti-money laundering consultant audits a bank's current anti-money laundering policies, procedures and controls. The bank serves high-income, high net-worth clients who include non-residents and offshore businesses. During a review of the custom list, the anti-money laundering consultant determines that he and the bank have mutual clients. The bank's written anti-money laundering program includes a process for the bank to establish the identity of the person with whom they conduct business, but does not address monitoring of customer account activity.
The consultant should recommend the bank:
- A. Revise the procedures to better assess ongoing customer activity.
- B. Continue to follow the current written anti-money laundering program.
- C. Focus on high-risk customer acceptance procedures.
- D. Reduce the risk rating on the mutual customers.
Answer: A
Explanation:
According to the ACAMS Study Guide, an effective AML program should include four key elements: internal controls, independent testing, designated compliance officer, and training1. Internal controls are policies, procedures, and processes that help prevent, detect, and report money laundering and terrorist financing activities. One of the essential components of internal controls is customer due diligence (CDD), which involves identifying and verifying the customer, understanding the nature and purpose of the customer relationship, and conducting ongoing monitoring of customer transactions and risk profiles2. Ongoing monitoring is crucial for detecting and reporting suspicious activities, updating customer information, and reassessing customer risk ratings3.
In this case, the bank's written AML program does not address monitoring of customer account activity, which is a significant gap in its internal controls. The bank serves high-income, high net-worth clients who include non-residents and offshore businesses, which are considered high-risk customers for AML purposes4. The bank should have enhanced due diligence (EDD) measures for these customers, such as obtaining additional information, conducting more frequent reviews, and applying stricter transaction limits5. The fact that the consultant and the bank have mutual clients does not affect the risk rating or the due diligence requirements of those customers. Therefore, the consultant should recommend the bank to revise its procedures to better assess ongoing customer activity and comply with the AML standards.
Reference:
1: ACAMS Study Guide, Chapter 2: Developing an Effective Anti-Money Laundering Program
2: ACAMS Study Guide, Chapter 3: Conducting Customer Due Diligence
3: ACAMS Study Guide, Chapter 4: Ongoing Monitoring and Suspicious Activity Reporting
4: ACAMS Study Guide, Chapter 5: Identifying High-Risk Customers
5: ACAMS Study Guide, Chapter 6: Applying Enhanced Due Diligence Measures
NEW QUESTION # 152
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