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CAMS Exam Questions AndAnswers Latest Update
What is money laundering? Answer: taking CRIMINAL proceeds and
disguising their illegal sources to USE the funds for LEGAL or ILLEGAL acts.
Give an example of the SECOND stage of money laundering. Answer:
Layering - Electronically moving funds between countries; moving funds
between financial institutions; and converting cash placed into the system into
monetary instruments.
Give an example of the THIRD stage of money laundering. Answer:
Integration - Purchasing luxury assets; and investing in business enterprises.
Give an example of the FIRST stage of money laundering. Answer:
Placement - Co-mingling ILLEGITIMATE and LEGITIMATE funds; foreign
exchange transactions with illegal funds; and depositing small amounts of cash
into multiple accounts.
What does the (Sally Yates - Then-Deputy Attorney General of the Department
of Justice) Yates memo say? Answer: It reminds prosecutors that criminal
and civil corporate misconduct investigations should also focus on the
individuals who perpetrated the wrongdoing.
What are some indicators of money laundering using electronic funds
transfers? Answer: Funds transfers to or from a financial secrecy haven;
large, incoming fund transfers from a foreign client with little or no
,explanation or apparent reason; and fund transfers that have no apparent link
to legitimate business.
What is REMOTE DEPOSIT CAPTURE and what risk is associated with it?
Answer: A product offered by banks that allows customers to SCAN A
CHECK AND TRANSMIT an electronic image to the bank FOR DEPOSIT.
Associated risks include ENABLING a money launderer to deposit checks
without visiting the bank thus avoiding detection.
What are some of the money laundering RISKS pertaining to the use of
Payable Through Accounts (PTAs)? Answer: Where foreign institutions
licensed in offshore centers, each bank having its own supervision; where the
respondent bank (the foreign bank) fails to conduct adequate customer due
diligence; and where the sub-account
holders have currency deposit and withdrawal privileges.
What is a money laundering RISK pertaining to the use of CONCENTRATION
ACCOUNTS? Answer: The fact that CUSTOMER IDENTIFYING
INFORMATION MAY NOT BE INCLUDED, making the audit trail difficult or
impossible to follow.
What is a PEP or Politically Exposed Person, and what is the PRIMARY RISK
in dealing with a PEP? Answer: A person who has or has had a prominent
government or quasi-public position in a country. The PRIMARY RISK is that
THEIR SOURCE OF FUNDS MAY BE FROM CORRUPTION.
What is structuring? Answer: Taking a large cash deposit and breaking it
into smaller amounts deposited into separate banks, accounts or on separate
days to avoid currency transaction reports.
,When are CREDIT CARDS most likely used for money laundering and give an
example of money laundering using credit cards? Answer: NOT likely
INITIAL PLACEMENT. More LIKELY in LAYERING or INTEGRATION. For
EXAMPLE, OVERPAYING on the BALANCE and THEN ASKING FOR A
REFUND. Receiving a check from a reputable company makes the funds
appear legitimate.
What are some of the risks posed by Third-Party Payment Processors (TPPPs)?
Answer: Multiple financial institution relationships whereby their
suspicious ACTIVITY CANNOT BE Entirely SEEN by one institution;
engaging in ACH transactions from overseas whereby the suspicious
TRANSACTIONS GET HIDDEN by the large number of other transactions
they engage in; and the possibility of higher than average return rates
stemming from unauthorized transactions.
What are some ways MONEY SERVICES BUSINESSES can be used for money
laundering? Answer: Cashing checks without obtaining adequate proof of
identity; failing to file Currency Transaction Reports when required; and
transmitting funds overseas without sufficient due diligence.
What are some of the money laundering risks associated with securities
broker-dealers? Answer: Its international nature, speed of transactions,
ease of converting holdings into cash without significant loss of principal; large
volume of wires; competitive, commission-driven environment; practice of
maintaining securities accounts in the name of nominees or trusts; and weak
AML programs.
What are some red flags associated with casinos and gambling? Answer:
Paying off associated debts in cash just under the reporting requirements;
, purchasing chips, but engaging in minimal gambling and then cashing the
chips back in; using the gambling house for banking-like financial services,
including wiring funds overseas; betting on both "red" and "black" spaces in
roulette; and purchasing chips with cash just under the reporting
requirements.
What were FATF's KEY findings its report on "Money Laundering/Terrorist
Financing Risks and Vulnerabilities Associated With Gold," issued in July,
2015? Answer: It IS RELATIVELY COMPACT AND EASY TO
TRANSPORT; it is LUCRATIVE AND HOLDS ITS VALUE regardless of form.
List ways in which a TRAVEL AGENCY could be used to launder money.
Answer: Making expensive purchases and then ASKING FOR A REFUND;
purchases made with multiple wires just UNDER THE REPORTING
THRESHOLD; and CREATING FALSE BOOKINGS through tour operator
networks to justify significant payments from foreign travel groups.
Name various ways that a GATEKEEPER - an attorney, notary, accountant or
auditor could assist in a money laundering scheme. Answer: CREATING
and MANAGING corporate vehicles or other COMPLEX LEGAL
ARRANGEMENTS; buying or selling property as a COVER for transfers of
illegal funds; PERFORMING financial TRANSACTIONS, including making
deposits, withdrawing funds, engaging in foreign exchange operations, buying
or selling stock and sending international wires; and SETTING UP or
MANAGING a charity.
What is the primary concern with regard to the use of GATEKEEPERS?
Answer: Attorneys, notaries, accountants and auditors CAN BE USED TO
ENHANCE SECRECY and keep the beneficial account owner or transaction
hidden.
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