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

ASuspicious Activity Report (SAR)is required when afinancial institution detects activity that raises suspicion of money laundering, terrorist financing, or fraud.

Option A (Correct):Inability to verify customer identification documentsis ared flag for potential financial crimeand may requirereporting to the Financial Intelligence Unit (FIU).

Option B (Incorrect):PEPs require enhanced due diligence (EDD), but their involvement alone does not automatically trigger a SAR.

Option C (Incorrect):Dealers in precious metals/stones are high-risk, but being in this industry alonedoes not warrant an automatic SAR.

Option D (Incorrect):Crypto-to-fiat transactions are not inherently suspicious, but they requiremonitoring for unusual activity.

Key SAR Filing Triggers:

Transactions that do not match the customer’s expected activity.

Incomplete, fraudulent, or unverifiable customer identification.

Use of shell companies or unusual intermediaries.

Large or structured transactions with no apparent legitimate purpose.

Best Practices for SAR Compliance:

Implement robust customer due diligence (CDD) processes.

Monitor transaction behavior against expected patterns.

Follow jurisdictional SAR filing deadlines to avoid penalties.

The6th AML Directive (6AMLD)introducedtighter rulesto combat financial crime, particularly aroundbeneficial ownership transparency.

Option D (Correct):6AMLD enhances transparencyby requiring accurate and verified datain central beneficial ownership registries, making it harder to hide illicit funds behind shell companies.

Option A (Incorrect):While some entities face increased scrutiny,crowdfunding platforms and football clubs were not the primary focusof 6AMLD.

Option B (Incorrect):6AMLD does not remove the EU’s obligation to conduct risk assessments;risk-based approaches remain centralto AML efforts.

Option C (Incorrect):TheEU AML Authority (AMLA), planned for2024, will centralize enforcement, but6AMLD did not createthis entity.

A bank’s risk assessment is a process of identifying, measuring, and mitigating the potential risks that the bank faces in its operations, products, services, and customers. According to the ACAMS Study Guide, a bank should focus on the following areas when performing a risk assessment1:

The type and location of the institution’s clients. This involves analyzing the customer base, the types of accounts and transactions, the source and destination of funds, the level of due diligence and verification, and the risk profile of the customers. For example, a bank should consider whether its customers are individuals or entities, domestic or foreign, politically exposed persons, high-net-worth individuals, non-profit organizations, or cash-intensive businesses. The location of the customers may also indicate the level of exposure to money laundering, terrorist financing, sanctions, or tax evasion risks.

The nature and breadth of the services and products the institution provides. This involves evaluating the range and complexity of the products and services offered by the bank, the delivery channels, the payment methods, and the innovation and technology involved. For example, a bank should consider whether it offers wire transfers, correspondent banking, trade finance, private banking, trust and fiduciary services, prepaid cards, mobile banking, or cryptocurrency services. The nature and breadth of the services and products may also affect the level of transparency, traceability, and compliance of the transactions.

The geographic locations where the institution does business. This involves assessing the jurisdictions where the bank operates, where its customers reside, where its counterparties are located, and where the funds flow. For example, a bank should consider whether it has branches, subsidiaries, or affiliates in high-risk countries, whether it serves customers from high-risk countries, whether it engages in cross-border transactions, and whether it complies with the local laws and regulations of the countries where it does business. The geographic locations where the institution does business may also influence the level of exposure to political, legal, regulatory, or reputational risks.

1: ACAMS Study Guide, Chapter 2: Risk Assessments, 1

A: The main objective of anti-bribery and corruption regulations is to prohibit bribes to government officials or employees of state-owned enterprises for the purpose of obtaining or retaining business or securing improper advantages.

“Anti-bribery and corruption regulations, such as the FCPA and UK Bribery Act, prohibit offering anything of value to public officials to gain a business advantage.”(CAMS 6th Edition, Anti-Bribery and Corruption)

When a financial institution is requested to provide data and information to a law enforcement agency for matters related to the financing of terrorism, assistance cannot be refused on the grounds of tipping-off. Tipping-off refers to disclosing to a customer or any third party that a suspicious activity report (SAR) has been filed. However, in this specific context, the obligation to provide information to law enforcement takes precedence over any concerns related to tipping-off. Financial institutions must cooperate fully with law enforcement agencies in such cases to combat money laundering and terrorist financing12.

A: The absence of professional oversight or accounting/auditing standards creates a high-risk environment for financial statement manipulation. Without external checks or mandated standards, criminals can more easily falsify statements to hide illicit assets.

“The lack of regulatory oversight and professional standards in accounting and auditing significantly increases the risk of manipulation and fraud in financial reporting.”(CAMS 6th Edition, Professional Service Providers; FATF Guidance on the Risk-Based Approach for Accountants)

The compliance officer should recommend an audit for cash transactions since the last compliance review, as this would help to identify the extent of the problem, the root causes, and the potential risks involved. The audit would also provide evidence for corrective actions and remedial measures to prevent future occurrences of non-compliance. The compliance officer should not recommend terminating or suspending the teller’s employment, as this would be premature and disproportionate without a thorough investigation and due process. The compliance officer should not recommend formally reprimanding the branch manager, as this would not address the underlying issues and could create a hostile work environment.

ACAMS CAMS Certification Study Guide, 6th Edition, Chapter 5, page 1251

ACAMS CAMS Certification Video Training Course, Module 5, Lesson 12

ACAMS CAMS Certification Exam Outline, Domain 5, Task 33

D

After filing a suspicious activity report (SAR), an investigator should prepare a summary for senior management recommending client off-boarding. This is because client off-boarding is a risk-based decision that requires senior management approval and may involve legal considerations. Informing other local financial institutions about the client, restraining or blocking the client’s account(s), or contacting law enforcement directly are not appropriate actions for an investigator to take after filing a SAR, as they may compromise the confidentiality of the SAR, violate privacy laws, or interfere with ongoing investigations.