ACAMS CAMS Dumps

European Commissions

Financial Action Task Forces

Wolfsberg Groups

Financial Intelligence Units

private banks agree that transparency of client beneficial ownership Is necessary and appropriate.

due diligence requirements tor private banking customers are necessary to prevent predicate offenses.

risk based approaches are insufficient to address the heightened risk presented through private banking

private banks need to better coordinate and align their global AML control environment strategies.

Who made the decision not to file the SAR

Why the officer deemed that the case did not merit filing a SAR

How much money was involved in the case

How the money flowed through the institution

When the unusual activity occurred

Consistency of approach

Periodic training of the function

Qualification of the team

Independent testing

Section 319(b)

Section 314(b)

Section 314(a)

Section 319(a)

Permanent US resident aliens regardless of location

Merchants that offer US-origin goods for sale regardless of location

Non-US financial institutions that offer accounts in USD regardless of location

US citizens regardless of location

US incorporated entities and their foreign branches

Determining whether the potential suspicious activity is consistent with the customer's transactional behavior, nature of business, and occupation

Contacting the country's financial intelligence unit's (FIU's) officers to seek advice on whether the potential suspicious activity is indeed a suspicious activity

Gathering and assessing internal sources of information, including information obtained from the customer, transactions, and value and volume

Identifying and reviewing external information, including online presence, customer-related entities, and relevant media

Digital identification on mobile devices

Different applications to connect and communicate

Authentication via artificial intelligence (AI) and biometrics

Quick CDD and client traits analysis during onboarding

Prioritizing resources towards lower-risk areas to reduce workload

Regularly reassessing risks to adjust resource allocation

Allocating more resources to areas with higher financial crime risk

Providing equal resources to all departments to maintain consistency

Using a fixed resource allocation plan without adjustments

Oversight of the Financial Intelligence Units in FATF Member countries

Providing a unique platform for information exchange regarding anti-money laundering efforts

Regulation of financial markets through directives and executive orders

Enhancement of international cooperation to foster anti-money laundering efforts via recommendations and guidance

Focus on understanding the risks presented by new clients within the assessment period, and the controls to mitigate associated money laundering risks.

Include appropriate measures and controls to mitigate money laundering risks stemming from higher-risk customers, products, and geographies.

Focus on the inherent risk in the FI's product and service offerings and the controls to mitigate potential money laundering risks.

Use a framework provided by a third-party vendor and used by other FIs in the jurisdiction.

Designated AML compliance officer

Chief executive officer

Chief operating officer

Board of directors

Ensuring sanctions coy on international bodies like the UN because there is no requirement to adhere to local laws.

Ensuring group policies and procedures prioritize adherence to US regulations because they are the most influential worldwide.

Applying global AFC and sanctions policies to ensure consistency without the need to adapt to local regulations.

Ensuring group policies cater to compliance with each country's specific AML and sanctions regulations.

have never worked in previous assignments within the AMUCFT departments.

have no involvement with the organization's AML/CP T compliance staff.

have been screened by the board of directors before the audit starts

be sufficiently trained in AML to be able to provide an independent review.

Information security office (ISO)

Marketing and sales

Human resources (HR)

Data privacy office (DPO)

Information provided by a prospective customer

Photocopy of a copy of a government-issued identity document

Information obtained from an open-source database

Information obtained directly from a government-managed registry

Helping overcome data protection and information sharing limitations

Enhancing the quality of reporting and additional informational input

Helping to alleviate the financial cost burden on law enforcement

Helping to design common approaches and identify desired deliverables

Offering flexibility, agility, and opportunities to adjust to the ML/TF threat environment

The customer is attempting to convert illicit funds into “clean” withdrawals

The customer is attempting to avoid high fees by minimizing gambling activity

The customer is testing the gaming platform’s payout system for potential fraud

The customer is a high-risk gambler who regularly places large bets

The residual risk would be eliminated entirely because the controls are sufficient to mitigate all potential risks

The residual risk would be significantly reduced due to the effectiveness of the controls in place

The residual risk would remain high due to the inherent nature of the private banking business

The residual risk would be moderately reduced, but further controls may be necessary to achieve an acceptable level

Use of cash to purchase property

Unlicensed real estate agents acting as front companies

Use of a registered trust for the purchase of property

Use of a company for the purchase of property

Manipulation of the value of a property

Economic and societal

Political and regulatory

Governance and compliance

Sectoral and jurisdictional

Keep an account open upon verbal request

Produce documents and testimony without a subpoena

Seize privileged documents upon written request

Freeze an account in terms of a court order

funds being stolen from other users.

obscuring the source of illicit funds.

layering transactions to hide the origin of funds derived from illicit activity.

difficulty converting into physical currency.

facilitating payment for other illicit activities and goods.

Inquiring about the source of wealth and source of funds

Asking to provide a list of immediate family members

Verifying the financial crime awareness of the client

Collecting necessary documents to verify the veracity of information

Close the client's account by informing the client of the subpoena.

Perform a transaction review and respond fully to the subpoena.

File a suspicious activity report (SAR), including the receipt of the subpoena in the SAR narrative.

Adjust the client's risk score and close the case.

To avoid sanctions breach related to payments

To avoid onboarding customers previously exited due to true match

To meet international regulatory requirements and identify risks across jurisdictions

To be in line with the risk appetite statement

Make an official request directly from the head of Country A's anti-corruption authority to Country B's corresponding law enforcement authority

Make a request for the required evidence using Country A's mutual legal assistance treaty with Country B

Use the International Criminal Police Organization (INTERPOL) network to obtain the required evidence from Country B

Use the Egmont Secure Web to obtain the required evidence from Country B's financial intelligence unit

Devaluation

Smart contract vulnerabilities

Potential for anonymity

Global reach

High transaction fees

Use to layer illicit funds

Money services business (MSB)

Multinational corporations

Individual foreign customers

Non-profit organizations with international operations

Consumer protection laws may intersect will) AML/CFT requirements when handling customer complaints or disputes, potentially affecting how FIs implement their compliance programs.

AML/CFT laws are the primary focus for FIs, and other regulations like data privacy and consumer protection may only indirectly influence their compliance obligations

Environmental, social, and governance (ESG) frameworks can influence a Fl's risk management strategies but are generally considered separate from core AML/CFT compliance requirements

Data privacy laws can restrict the sharing of customer information, while financial inclusion initiatives require FIs to avoid excessive de-risking that could exclude vulnerable populations.

The use of new technologies to facilitate the onboarding of customers remotely

The prevalence of international wire transfers

Domestic business with small and medium-sized enterprises

The cash-intensive nature of the services offered

The use of digital channels and traceable payment methods

Periodic review of suspicious activity reports (SARs) filed with FinCEN to determine whether any should be withdrawn.

Periodic and ad hoc cooperation with the legal team to appropriately investigate and monitor the transactions of subjects of subpoenas or government inquiries.

Periodic review of client profiles to ensure that the most up-to-date information is on file for high-risk clients in line with the bank’s internal policies and procedures.

Periodic review of the transaction monitoring scenarios and their productivity to ensure that appropriate AML typologies are reflected.

executing cross-border transactions for their own business which is not commensurate to the PEP's wealth.

in a position to provide more information regarding the PEP's whereabouts and hidden properties.

travelling to offshore jurisdictions often on holiday which exposes them to higher risks for AML.

used as intermediaries to facilitate bribery or corruption or to conceal the illicit wealth of the PEP.

Advising private financial institutions on how to enhance their profitability through AML efforts

Establishing and enforcing legal frameworks to detect, prevent, and punish money laundering and related financial crimes

Providing funding to private and non-governmental organizations (NGOs) for the development of advanced compliance technologies

Acting as intermediaries between private sector firms and non-governmental organizations (NGOs) to streamline AML compliance programs

PPPs improve financial crime detection and prevention by sharing intelligence between banks and law enforcement.

PPPs help banks reduce compliance costs by automating information sharing.

PPPs allow banks to manage their own suspicious activity report (SAR) filing process without the need to involve the Financial Intelligence Unit (FIU).

PPPs maximize the efficiency of the bank's compliance program by providing real-time intelligence from law enforcement.

Periodic and ad hoc cooperation with the legal team to appropriately investigate and monitor the transactions of subjects of subpoenas or government inquiries

Periodic review of client profiles to ensure that the most up-to-date information is on file for high-risk clients in line with the bank's internal policies and procedures

Periodic review of suspicious activity reports (SARs) filed with FinCEN to determine whether any should be withdrawn

Periodic review of the transaction monitoring scenarios and their productivity to ensure that appropriate AML typologies are reflected

Policies are detailed instructions for specific processes. Procedures are an overarching framework. Neither policies nor procedures are mandatory for knowledge and adherence

Policies are broad guidelines. Procedures are detailed Instructions for specific processes. Only procedures are mandatory for knowledge and adherence.

Policies are detailed instructions for specific processes Procedures are an overarching framework Both policies and procedures are mandatory for knowledge and adherence.

Policies define the principles of an organization and influence the drafting of procedures. Procedures are detailed instructions for specific processes.

An existing local league footballer trying to open a bank account with a bank in their local jurisdiction

The current prime minister of a country trying to open a bank account in another country

The former personal secretary to the minister of transport in a low-risk country 25 years ago opening a bank account at a bank in a neighboring low-risk country

A bank located in a higher risk country trying to establish a correspondent-respondent banking relationship with a bank in a lower-risk country

An individual with a current bank account who resides in one country becoming the ambassador of another country

protect the rights of the citizens of the state target against their own government and improve financial stability in the region.

indicate that the use of military force is likely unless the state or non-state target complies with the government's

interests encourage non-governmental organizations to increase the provision of humanitarian and charitable aid to the target

alter the behavior of the state or non-state target that threatens the interests of that government or violates international norms

has a general understanding of virtual assets.

consistently reviews transactions between fiat and virtual currencies.

implements enhanced KYC measures.

owns virtual currencies itself.

Work with the front-line to understand their strategic growth targets specifically aimed at increasing their market share around military technology and dual-use products

Review the organization's sanction risk assessment to better understand the potential for exposure to Russia and the Democratic People's Republic of Korea

Read and analyze the most recent National Proliferation Financing Risk Assessment produced by the relevant body of the organization's jurisdiction

Undertake a detailed review of all payment-related transactions to any clients identified as defense contractors, paying special attention to the beneficial owners of those clients

The Organisation for Economic Co-operation and Development (OECD)

The Egmont Group

The Wolfsberg Group

The International Monetary Fund (IMF)

Memorandum of Agreement.

Declaration of Understanding.

Memorandum of Understanding.

Mutual Legal Assistance Treaty.

Request for Urgent Information.

Allow beneficial owners to provide proxies lot voting on corporate decisions

Obscure beneficial ownership

Allow domicile in the nominee's jurisdiction

Derail investigations

Conduct an open-source intelligence investigation using artificial intelligence tools to gain more information on the activities of the suspected employee

Use the FI's whistleblowing channel to report the suspected employee

Question their co-worker to determine if their suspicions are correct before reporting to the FI's Human Resources department

Warn colleagues and customers of the FI that the employee's suspicious financial investment proposals could be a scam

Report the suspected employee to the line manager of the FI to take the required action

identification of the customer's occupation.

identification and verification of the customer's identity.

identification of the customer's work address.

identification of the beneficial owner.

verification of the customer's credit history.

[verification of the customer's income sources.

A lack of professional body oversight or required use of accounting and auditing standards in the country of incorporation of the entity

Criminals posing as individuals seeking financial advice to place assets out of reach to avoid future liabilities

Incomplete records being provided during bookkeeping, making them difficult to audit

Accountants being used as intermediaries to introduce criminals to financial institutions

Section 314(a)

Section 314(b)

Section 319(b)

Section 319(a)

up to date and reflects all relevant regulatory developments

signed off by the board of directors and regulators

approved by the clients and third parties

clearly communicated and understood by staff

It reduces the overall cost of compliance programs.

It eliminates the need for periodic audits of low-risk customers.

It ensures focus on high-risk areas while maintaining operational efficiency.

It standardizes compliance processes across all regions.

Cryptoassets can be transferred across borders quickly, but the volatility of their value still makes them less attractive for money laundering compared to traditional assets

Mandatory reporting requirements have been implemented for certain types of crypto transactions, but gaps in regulation and enforcement still leave room for money laundering activities.

The transparency of blockchain technology helps law enforcement trace transactions, but it can also provide criminals with ways to obscure their financial activities through complex layering techniques.

The pseudonymous nature of transactions allows criminals to hide their identities while transferring large sums of money globally, making it difficult to trace the ultimate beneficial owner.

The foreign bank will not allow indirect use of the correspondent bank accounts by Politically Exposed Persons (PEPs)

The jurisdictions in which the foreign bank maintains a physical presence

The foreign bank's operations will be limited to the country of incorporation

The ownership details of the foreign bank

The foreign bank will not allow indirect use of the correspondent bank accounts by shell banks

FIs may disclose customer information to any third party

FIs may provide information about their internal compliance programs to law enforcement agencies without any limitations

FIs are required to report all transactions involving foreign entities to FinCEN so that FinCEN can share this information with other financial institutions

FIs may share information about suspected money laundering activities with other FIs to aid in identifying and reporting suspicious transactions

Whether the vendor has documented appropriate internal controls for designing system and data integration schema

Whether the permissions and user access settings for reviewing, investigating, and reporting details of alerts generated by the system are commensurate with those in use at other banks

Whether the monitoring system is adequate with respect to the bank's size, activities, complexity, and risks

Whether the monitoring system can be configured to enable the bank to execute trend analysis of transaction activity and to identify unusual business relationships and transactions

Buying property allows for the movement of large amounts of funds in a single transaction

Criminal networks could purchase real estate for use as supply houses or locations to grow, manufacture, or distribute illicit narcotics

Markets can be volatile, and buyers may not achieve a strong return on their investment

Beneficial ownership information might be opaque, and criminals may abuse arrangements like shell companies and trusts

Real estate transactions often involve financial institutions and other professional gatekeepers

The high value of properties may require multiple types of financing, which can make it more difficult to identify the source of funds

identify and address the current financial crime trends through the issuance of typologies originating in members outside of their FSRB's Jurisdiction.

provide AM L/C FT technical assistance needed by members in their FSRB junsdiction.

coordinate technical assistance for members in their FSRB jurisdiction

set and amend the FATF 40 Recommendations for members in their FSRB jurisdiction.

identify and address any gaps in the AML/CFT policies for members outside of their FSRB jurisdiction.

offer mutual evaluation and follow-up processes for members in their FSRB Jurisdiction.

A low-priced security sees a sudden spike in investor demand with a rising price

A trading customer maintains a portfolio of securities concentrated in one specific emerging market

A firm sees an unexpected increase in demand for electronically traded funds

A security sees a transactional pattern of a steady decrease in both trading volume and prices

Management structure

Governance framework

Asset structure

Origin of the funds

Document the customer's transaction history and keep the investigation confidential until further suspicious activity is detected.

Immediately escalate the case to senior management, recommending the closure of the customer's accounts due to potential reputational risk.

Report the investigation to external auditors and await further guidance before taking any action.

Draft a SAR that includes a detailed chronology of the transactions, customer background and the rationale for suspicion, and submit it to the relevant financial intelligence unit (FIU) within the regulatory timelines.

Enterprise-wide risk assessments and the employee handbook for any limitations on sharing commercially sensitive customer data

The risk rating of the customers to avoid sharing data relating to higher risk customers

The organization's AML compliance policies to ensure that customer data can be easily shared internally and internationally

Applicable data privacy laws in relevant jurisdictions and the organization's data security and privacy policies for any limitations

cross-border purchases.

purchases in the name of a natural person.

paying true market price for a property.

non-financed purchases.

Financial crime does enormous damage to society, undermining market integrity and consumers' and market participants' confidence

Financial crime risk incidents always result in fines and losses for the financial firm

Financial crime prevention processes make the onboarding process for clients unnecessarily burdensome and complex but create work

Financial crime prevention is important as it reduces costs and improves customer services.

Use of wire transfers

Loitering

Instructions or involvement from third parties

Amended letters of credit without reasonable justification

Non-standard settlement arrangements

In-person training sessions

Comprehensive curriculum delivered by senior management

Comprehensive content with engaging delivery methods

Generalized content designed to apply to a broad audience

Partial automation of data collection and analysis

Cost-effective access to a wide range of data

Real-time monitoring of selected transactions and data sources

Ability to conduct investigations with minimal human oversight

Enhanced ability to identity connections across various data sets

Assist financial institutions conducting business in jurisdictions with high data privacy standards in working with industries susceptible to money laundering

Advise banks to accept only those clients whose source of funds and beneficial ownership is understood

Establish rules for private bankers on how to deal with politically exposed persons (PEPs) and persons residing in high-risk countries

Require banks to better manage reputational risk and protect the privacy of wealthy clients

A limited liability company incorporated in a foreign jurisdiction

A private company that has no activity in a tax haven jurisdiction

A company with nominee shareholders and directors in a local jurisdiction

A company with bearer shares incorporated in a tax haven jurisdiction

A private investment company incorporated in a tax haven jurisdiction with strict secrecy laws

Establish policies and procedures to ensure due diligence activities are identical for all customers.

Establish policies and procedures to identify and verify customers, beneficial owners, and any individuals that can transact on behalf of their customers.

Establish policies and procedures for customer due diligence that vary based on risk.

Are prohibited from offering numbered accounts to customers, even if procedures are established to gather and maintain due diligence information.

Establish policies and procedures that encourage processing transactions while due diligence information is being established and verified.

waste management sector companies based in high-risk jurisdictions with payments or trade invoices tor types of waste aligned with those they are authorized to process.

frequent payments from companies in the logging. milling, or waste trade sectors to individuals or beneficiaries unrelated to the legal parson activity or business.

unexplained wealth and cash transfers involving senior officials or politically exposed persons for their family members) with a position of responsibility related to the management or preservation of natural resources.

small cash transfers from cash-Intensive businesses to beneficiaries in areas known as a source of gold mining, illegal logging, and Illegal land clearing.

using shell companies or trusts for privacy, lax planning, or asset protection.

in the names of unrelated thud patties.

using the proceeds from selling a prior property or liquidating investments to make an all-cash purchase

using legal entities and intermediaries to protect the privacy of the purchasers.

using loans backed by cash or certificates of deposit.

public administration.

legal assessment.

law enforcement.

legal activity.

An external audit highlights several deficiencies

The company is merging with or acquiring another entity

Extensive AML legislation is proposed by a legislative body in the company's jurisdiction

A high-profile money laundering case involving another industry is publicized

buy in-game items with virtual in-game currencies.

exchange in-game items with other players.

trade in-game items with other players that can be exchanged for fiat currency

obtain in-game materials by performing in-game activities.

Formal assessment

Regulatory overview

Technical analysis

Mutual evaluation

impose sanctions lo maintain of restore international peace and security

impose sanctions on countries that lack AML/CFT controls.

conduct research on and analyze the impacts of sanctions to improve the effectiveness of sanctions regimes.

impose sanctions on economic targets to maintain or restore financial stability within a country.

Adaptable to new AFC typologies through continuous model training

Completely unbiased and without error through continuous model training

More consistent and reliable detection outcomes

Transparent and easy to explain algorithms for regulator and compliance purposes

Dissuade government tax incentive programs

Reduce confidence in the country's financial sector.

Dissuade foreign investment.

Lower the employment rate.

Reduce volatility in exchange and interest rates.

The institution has observed an increase in customer demand for large-denomination banknotes.

The institution maintains a sequentially numbered log of the monetary instruments it sells.

The institution has observed a reduced settlement time in the transaction services that support the rapid movement or remittance of funds.

The institution has observed an increase in the adoption of its digital products and services.

Make a note in the customer's account that the customer's gambling activities are frequently conducted below the reporting limit

Follow internal reporting procedures to escalate the activity as suspicious and report to appropriate authorities

Inform the customer their activity Is suspicious and request an explanation

Contact law enforcement to launch an Investigation into the customer's financial activities

Ensure the jurisdiction risks and other relevant factors have been taken into consideration in the EWRA and the residual risks are within the corporation's risk appetite

Partnering with established local businesses to leverage their knowledge and connections while sharing risks

Ensuring the company has strong ties with local government officials to influence policy and avoid negative scrutiny

Committing to open communication, ethical practices, and community engagement to build trust with stakeholders

Minimizing the company's direct presence in the country to reduce exposure to potential risks

The employee was originally from a high-risk jurisdiction

The employee had friends in high-risk industries

The employee had a lavish lifestyle for her income

The employee was constantly evasive about the reasons for leaving her previous corporate finance job

Determining detailed risk profiles for customers based on their activities and relationships

Focusing monitoring primarily on previously flagged customers while using standard controls for others

Choosing and applying effective controls that align with the identified risk levels

Performing a comprehensive risk assessment to identify customer, transaction, and geographic risks

Allocating resources equally across all customer segments to ensure fairness

The payment of company secretarial retainer fees to a foreign company in a tax-efficient jurisdiction

The payment of virtual offices services overseas

Inter-company loans from the holding company to the subsidiary company to finance the shipment of machinery

The payment of consultancy fees to unrelated companies and service providers established in a foreign jurisdiction

Reputational risk

Operational risk

Sanctions risk

Compliance risk

Lending risk

Submit a referral to file a suspicious activity report (SAR)

Evaluate the KYC review process to understand why the review did not occur as required and take corrective action as necessary

Contact the customer's relationship manager to suspend account access until the periodic KYC review is completed

Remove the customer from the bank's high-risk list

The Dutch bank should limit any information sharing to what is necessary, reasonable, and proportionate, in line with applicable laws and regulations

The Dutch bank's legal obligations to protect customer privacy and bank secrecy prohibit it from sharing any such information

The Dutch bank should require a production order from the Italian bank and receive approval from its legal department before sharing the requested information

The need to fight financial crime outweighs the EU's data protection and privacy regulations

remote verification of identity by third-party program managers

heavy usage by senior political figures.

heightened risks of returned transactions.

informal networks used for cross-border transactions outside of the formal banking system

difficulty in tracking the originator recipient, and source of transactions.

Wolfsberg Group

Transparency International

Financial Action Task Force (FATF)

Tax Justice Network

International cooperation provides actionable information to use against criminals

Those convicted of money laundering offenses are denied access to basic banking services

Money laundering offenses are investigated and criminally prosecuted

Financial intelligence information is collected by authorities and shared with the FATF for further investigation

Supervisors regulate financial institutions and non-bank financial institutions and their risk-based AML/CFT programs

Sanctions can only be placed on certain individuals in foreign countries as designated by OFAC

Blocked funds must be placed into an interest-bearing account on a financial institution's books

Sanctions can be either comprehensive or selective using the blocking of assets and trade restrictions to accomplish foreign policy and national security goals

OFAC sanctions automatically expire after five years unless renewed by Congress

directly contact financial institutions in another country and share information pertinent to the investigation.

directly contact other FlUs in another country and share information pertinent to the investigation.

deputize its law enforcement investigators to assist in a material ongoing investigation in another country

assist law enforcement in another country with a material ongoing investigation.

The bank is likely to face secondary sanctions from global financial institutions despite addressing many of the previous concerns.

The bank may face civil or criminal penalties if it is unable to demonstrate sustained improvement in addressing the previous concerns.

The bank may face the risk of regulatory orders to remediate its AML program despite addressing many of the previous concerns.

The bank is protected from reputational risk arising from any regulatory action because regulatory orders must remain confidential.

The regulatory agency may require the bank's board of directors to publicly share the actions taken to address the previous concerns in order to limit its reputational risk.

Securely share sensitive information in the fight against money laundering and the financing of terrorism

Establish an environment to foster trust amongst countries

Sign memoranda of cooperation that recognize and allow room for case-by-case solutions to specific problems

Improve global cooperation between FIUs

Propose legislation to combat financial crime, including money laundering and the financing of terrorism