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

The Egmont Group is a global network of Financial Intelligence Units (FIUs) that aims to enhance the capabilities and cooperation of its members in combating money laundering, terrorist financing, and other financial crimes. The Egmont Group supports its FIU members by helping them to expand and systematize the exchange of financial intelligence and information, improve expertise and capabilities of personnel, and enable secure communication with one another12. The Egmont Group does not issue due diligence models for financial institutions, as this is the responsibility of national regulators and standard-setting bodies. The Egmont Group does not issue strategic products for law enforcement agencies and FIUs, as this is the role of other international organizations such as the Financial Action Task Force (FATF) and the United Nations Office on Drugs and Crime (UNODC). The Egmont Group does not expand the ability of FIUs to enforce laws and exchange information globally, as this depends on the legal and operational frameworks of each FIU and the bilateral or multilateral agreements they have with other FIUs.

References:

Egmont Group

Working Groups - Egmont Group

Overview of the Egmont Group of Financial Intelligence Units

The Egmont Group of Financial Intelligence Units | FinCEN.gov

Egmont Group - Qatar Financial Information Unit

An anti-money laundering officer should coordinate with the human resources department when implementing a new hire screening program. A new hire screening program is a process of conducting background checks and verifying the identity, qualifications, and suitability of prospective employees, especially those who will be involved in the bank’s anti-money laundering (AML) compliance program. The human resources department is responsible for managing the recruitment, hiring, and training of employees, and ensuring that they comply with the bank’s policies and procedures. Therefore, the human resources department is the most appropriate partner for the anti-money laundering officer in developing and executing a new hire screening program that meets the bank’s AML standards and regulatory requirements.

The other options are not relevant or necessary for the implementation of a new hire screening program. The internal auditor is responsible for evaluating the effectiveness and adequacy of the bank’s internal controls, including the AML compliance program, but not for screening new hires. The local financial intelligence unit is a government agency that collects, analyzes, and disseminates financial information related to money laundering and terrorist financing, but not for screening new hires. The institution’s regulator is the authority that supervises and examines the bank’s compliance with the applicable laws and regulations, including the AML requirements, but not for screening new hires.

References:

ACAMS Study Guide for the CAMS Certification Examination (6th Edition), Chapter 4: Developing an AML/CFT Program 1

FFIEC BSA/AML Manual, Assessing the BSA/AML Compliance Program, BSA/AML Training 2

AUSTRAC, Employee due diligence 3

The primary international authoritative body that designates sanctions is the United Nations (UN). The UN Security Council has the power to impose sanctions under Chapter VII of the UN Charter, which deals with threats to the peace, breaches of the peace, and acts of aggression. The UN sanctions are legally binding on all UN member states and aim to maintain or restore international peace and security. The UN sanctions can target individuals, entities, groups, sectors, or countries, and can include measures such as arms embargoes, travel bans, asset freezes, trade restrictions, or diplomatic isolation. The UN sanctions are implemented and enforced by the member states, with the assistance of the UN Secretariat and other specialized agencies. The UN sanctions are periodically reviewed and adjusted by the Security Council, based on the reports of the sanctions committees and expert panels.

References:

1: UN Sanctions1

2: UN Charter, Chapter VII2

3: ACAMS Study Guide for the CAMS Certification Examination3

 the compliance officer should cooperate with the law enforcement investigation, but only after receiving a formal written request that specifies the scope and purpose of the information sought. This is to ensure that the compliance officer complies with the legal and regulatory obligations of the bank, such as confidentiality, privacy, and data protection. The compliance officer should also document the request and the information provided, and report the incident to the senior management and the board of directors as appropriate.

References:

FFIEC BSA/AML Assessing the BSA/AML Compliance Program - BSA Compliance Officer, section “BSA Compliance Officer”, paragraph 3: “The BSA compliance officer is responsible for ensuring that the bank’s BSA/AML compliance program is implemented effectively, including timely updates in response to changes in regulations or business activities, and for managing all aspects of the BSA/AML compliance program. The BSA compliance officer is also responsible for ensuring that the bank’s BSA/AML compliance program is communicated to all personnel and that adequate training is provided to appropriate personnel.”

Guidelines on the role of AML/CFT compliance officers, section “Guidelines on the role of AML/CFT compliance officers”, paragraph 36: “The AML/CFT compliance officer should ensure that the institution cooperates with the competent authorities, including by providing them with all the information they require in a timely manner, in accordance with the applicable legal and regulatory framework.”

Anti-Money Laundering Compliance Officer Job Description, section “Responsibilities of an AML Compliance Officer”, bullet point 6: “Cooperate with law enforcement and regulatory bodies as required.”

Economic sanctions are penalties imposed by one or more countries against another country, group, or individual for violating international norms or threatening national interests1. The ultimate goal of economic sanctions is to protect national security by changing the behavior or policies of the target, or by weakening its capabilities or resources2. Sanctions can be used to advance various foreign policy objectives, such as counterterrorism, nonproliferation, democracy promotion, human rights protection, conflict resolution, and cybersecurity1. Sanctions can take different forms, such as travel bans, asset freezes, trade embargoes, arms restrictions, and aid reductions1. Sanctions can be applied unilaterally by one country, or multilaterally by a coalition of countries or an international organization, such as the United Nations or the European Union1.

References:

1: What Are Economic Sanctions? | Council on Foreign Relatio

2: How Economic Sanctions Work - Investopedia

 Enhanced due diligence (EDD) is a set of additional measures that must be applied by financial institutions (FIs) in higher-risk situations, such as when dealing with customers or transactions from high-risk third countries, customers who are politically exposed persons (PEPs), or customers who present a higher risk of money laundering or terrorist financing. EDD may include obtaining more information on the customer’s identity, source of funds, source of wealth, business relationships, and purpose of the transaction, as well as conducting more frequent and intensive ongoing monitoring of the customer’s activities.

However, EDD may be bypassed for certain situations where the risk of money laundering or terrorist financing is low, and where the customer is subject to adequate supervision and regulation in the EU or the US. According to the CAMS Study Guide - 6th Edition1, one such situation is when on-boarding a casino 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. This is because such a casino is likely to have a low risk profile, as it is not the main source of income for the hotel chain, and it adheres to the same standards and controls as the rest of the group. Therefore, EDD may not be necessary for this situation, and the FI may apply simplified due diligence (SDD) instead.

The other situations listed in the question are not eligible for bypassing EDD, as they involve higher-risk factors, such as dealing with customers or entities from high-risk third countries, customers with complex ownership structures, or customers who are PEPs. These situations require FIs to apply EDD measures to mitigate the risk of money laundering or terrorist financing.

References:

CAMS Study Guide - 6th Edition, Chapter 3, Section 3.4, page 84

White Paper on KYC — Enhanced Due-Diligence, page 2

Anti-money laundering – a guide to customer due diligence, page 3

Enhanced Due Diligence for High-risk Customers, page 1

A compliance officer should consider the following three factors as part of the approach to implement an enterprise-wide anti-money laundering program for a bank that operates in multiple countries:

The types of customers serviced by the bank: Different types of customers may pose different levels of money laundering risk, depending on their nature, source of funds, geographic location, transaction patterns, and other factors. A compliance officer should identify and assess the money laundering risk associated with each customer type and segment, and apply appropriate due diligence measures, monitoring systems, and risk mitigation strategies accordingly12.

The extent of anti-money laundering regulations in the various countries: A compliance officer should be aware of the legal and regulatory requirements and expectations for anti-money laundering compliance in each country where the bank operates, and ensure that the bank’s policies and procedures are consistent with them. A compliance officer should also monitor any changes or updates in the anti-money laundering laws and regulations in the various countries, and adjust the bank’s program accordingly34.

The anti-money laundering risk posed by the products and services offered by the bank: Different products and services may have different features and functionalities that could be exploited by money launderers, such as anonymity, cross-border transfers, cash transactions, complex structures, or new technologies. A compliance officer should evaluate the money laundering risk associated with each product and service offered by the bank, and implement appropriate controls, safeguards, and oversight mechanisms to prevent and detect money laundering activities5 .

References:

1: ACAMS, CAMS Study Guide, 6th Edition, Chapter 2: Risk Assessments

2: FATF, Guidance for a Risk-Based Approach: The Banking Sector

3: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT)

4: Deloitte, AML Program Effectiveness Reform

5: ACAMS, CAMS Study Guide, 6th Edition, Chapter 4: AML Program Design

[6]: OCC, Money Laundering: A Banker’s Guide to Avoiding Problems

This action is the most appropriate because it demonstrates the local manager’s responsibility and accountability for the sanctions compliance program. Sanctions screening is an important part of the Know Your Customer (KYC) and Anti-Money Laundering (AML) processes, as it helps to identify and prevent transactions with sanctioned individuals or entities, which could expose the financial institution to legal, regulatory, and reputational risks. Failing to perform sanctions screening could result in violations of sanctions laws and regulations, which could lead to fines, penalties, sanctions, or even criminal prosecution. Therefore, the local manager should immediately inform senior management of the issue, so that they can take corrective actions, such as implementing screening procedures, conducting a risk assessment, reviewing existing customers, reporting any potential violations, and providing training and guidance to the staff.

The other actions are not appropriate because they either do not address the root cause of the problem, or they could worsen the situation. Starting screening new customers without informing senior management could create a false sense of compliance, and it could also miss the existing customers who may be sanctioned. Immediately informing the regulators without informing senior management could undermine the trust and communication within the organization, and it could also trigger an investigation or enforcement action before the issue is resolved internally. Doing nothing because the department only handles a very small number of mortgages could be a sign of negligence or indifference, and it could also expose the financial institution to significant risks, as even one transaction with a sanctioned party could have serious consequences.

References:

CAMS Certification Package - 6th Edition | ACAMS, Chapter 4: Developing and Implementing an AML Training Program, pp. 97-98

CAMS Certifications: How to Get CAMS Certified | ACAMS, CAMS Study Guide, pp. 76-77

What is Sanctions Screening and How Does It Work? | Jumio, Introduction and Benefits of Sanctions Screening

Sanctions Screening: Challenges and Control Considerations, Background and Regulatory Expectations for Sanctions Screening

Sanction Screening: A Complete Guide | KYC AML Guide, What is Sanction Screening and Why is it Important?