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ACAMS Certified Anti-Money Laundering Specialist (CAMS7 the 7th edition) Sample Questions (Q76-Q81):
NEW QUESTION # 76
A company contracts a life insurance policy with a savings feature of 100,000 USD for an individual in a high-risk country. The policy receives monthly cash deposits from unknown third parties. A minimal part of the deposit is invested and the rest is withdrawn by the end of the month. Which are the circumstances to consider as a risk for money laundering? (Select Two.)
- A. Unidentified third parties depositing cash to the policy
- B. A policy for an amount of 100,000 USD is to be considered high and suspicious
- C. The regular withdrawals from the policy by the end of the month
- D. A life insurance policy with a savings feature for a national from a high-risk country
- E. A company established in a high-risk country contracting a policy for a domestic individual
Answer: A,C
Explanation:
According to the ACAMS CAMS Study Guide (the 6th edition), one of the common methods of money laundering in the insurance sector is to purchase policies with illicit funds, overpay premiums, and then cancel or surrender the policies to receive refunds or payouts1. This allows criminals to move and disguise the source of their funds through the insurance company. Therefore, the regular withdrawals from the policy by the end of the month could indicate a money laundering scheme. Moreover, the FATF Guidance for a Risk-Based Approach for the Life Insurance Sector states that unidentified third parties depositing cash to the policy could also pose a high money laundering risk, as cash transactions are difficult to trace and third parties may act as intermediaries or nominees for the real beneficiaries2. Therefore, the insurance company should conduct enhanced due diligence on the policyholder and the third parties, and monitor the transactions for any suspicious activity.
Reference:
ACAMS CAMS Study Guide (the 6th edition), Chapter 2: Money Laundering Risks and Methods, page 671 FATF Guidance for a Risk-Based Approach for the Life Insurance Sector, pages 18-192
NEW QUESTION # 77
Combating the Financing of Terrorism (CFT)]
Whichpractices should financial institutions (FIs) adoptfor the process ofterminating customer relationships? (Select Three.)
- A. Implementing a standardized procedure for customer termination that includes risk assessments and necessary documentation.
- B. Performing a final review of a customer's transaction history and records to address any unresolved issues prior to termination.
- C. Notifying the customer of the termination decision only after completing the termination process to prevent possible disputes.
- D. Keeping records of the termination process, including the justification for the decision and any correspondence with the customer.
- E. Utilizing a flexible communication style that adapts to different customer situations during the termination process.
Answer: A,B,D
Explanation:
Terminating customer relationships due toAML risksrequiresclear procedures and documentation.
* Option B (Correct):Astandardized termination procedureensurescompliance, fairness, and consistency.
* Option C (Correct):Afinal review of transactionshelps identifysuspicious activity before closure.
* Option D (Correct):Documenting termination decisionsprotects the FI fromlegal and regulatory risks.
* Option A (Incorrect):Whileclear communication is important, termination decisions should be consistent and policy-driven.
* Option E (Incorrect):Customers should benotified appropriatelybut not necessarilyaftertermination.
Reference:FATF Risk-Based Approach Guidance for FIs, Wolfsberg Group Customer Exit Best Practices, FCA AML Guidance on De-risking.
NEW QUESTION # 78
A customer brings $15,000 worth of chips into a casino and plays various games. The customer redeems all the remaining chips and requests a wire transfer of the proceeds to an unrelated third party.
What are two red flags that indicate money laundering? (Choose two.)
- A. Playing various games before cashing out
- B. Customer redeeming all remaining chips
- C. Requesting a wire transfer to an unrelated third party
- D. Bringing $15,000 worth of chips into the casino
Answer: C,D
Explanation:
Bringing $15,000 worth of chips into the casino is a red flag because it could indicate that the customer is trying to avoid the currency transaction reporting (CTR) requirement for cash transactions over
$10,0001. Requesting a wire transfer to an unrelated third party is another red flag because it could indicate that the customer is trying to conceal the source or destination of the funds, or transfer them to a high-risk jurisdiction2.
References:
1: ACAMS CAMS Certification Video Training Course, Module 3: Casinos and Gaming, Section 3.1:
Regulatory Requirements, Slide 8 2: ACAMS CAMS Certification Video Training Course, Module 3: Casinos and Gaming, Section 3.2: Money Laundering Methods and Red Flags, Slide 11
NEW QUESTION # 79
According to the Financial Action Task Force 40 Recommendations, Designated Non-Financial Businesses and Professions include
- A. money services businesses.
- B. hawala operators.
- C. real estate agents.
- D. commodities traders.
Answer: C
NEW QUESTION # 80
Which methods are typically used to launder money using insurance companies? (Choose two.)
- A. The policy holder purchases a bond and redeems it at a discount prior to its full term.
- B. The policy holder overpays the policy and moves the funds out of the policy despite paying early withdrawal penalties.
- C. The policy holder is strongly interested in how many costs are incurred when taking out an insurance policy.
- D. The policy holder uses an offshore company to pay the insurance installments.
- E. The policy holder enters a sibling as a beneficiary of the insurance policy rather than themselves.
Answer: B,D
Explanation:
The methods that are typically used to launder money using insurance companies are:
The policy holder overpays the policy and moves the funds out of the policy despite paying early withdrawal penalties. This method involves placing large amounts of illicit funds into an insurance policy, usually a life insurance or an annuity, and then requesting a refund or a surrender of the policy. The policy holder may incur some fees or penalties for the early withdrawal, but they will receive a check or a wire transfer from the insurance company that appears to be a legitimate source of income. This method allows the launderer to layer and integrate the funds into the financial system.
The policy holder uses an offshore company to pay the insurance installments. This method involves setting up a shell company or a trust in a jurisdiction with low or no tax and weak or no anti-money laundering regulations. The launderer then uses the offshore entity to purchase an insurance policy or a bond from a reputable insurance company. The offshore entity pays the premiums or the installments using the illicit funds, and the launderer can claim thebenefits or the returns from the policy or the bond as clean money. This method allows the launderer to hide the true ownership and origin of the funds.
The other options are not typical methods of money laundering using insurance companies, because:
The policy holder enters a sibling as a beneficiary of the insurance policy rather than themselves. This method does not involve any movement or disguise of the illicit funds, and it does not generate any income or return for the launderer. The beneficiary of the policy will only receive the payout upon the death of the policy holder, and the insurance company will conduct due diligence on the beneficiary before releasing the funds.
The policy holder purchases a bond and redeems it at a discount prior to its full term. This method does not make sense for a money launderer, because it involves losing money rather than gaining money. A bond is a fixed-income instrument that pays a regular interest and a principal amount at maturity. If the bond is redeemed before its full term, the bond holder will receive less than the face value of the bond, and will also forfeit the future interest payments. This method does not help the launderer to conceal or legitimize the source of the funds.
The policy holder is strongly interested in how many costs are incurred when taking out an insurance policy.
This method does not indicate any money laundering activity, but rather a prudent and rational behavior of a potential customer. The policy holder may want to compare different insurance products and providers, and to understand the fees, charges, commissions, and taxes associated with the policy. This method does not involve any placement, layering, or integration of the illicit funds.
ACAMS Study Guide for the CAMS Certification Examination - 6th Edition, Chapter 1: Risks and Methods of Money Laundering and Terrorism Financing, Section 1.2: Methods of Money Laundering, Subsection
1.2.5: Insurance Products, pp. 19-20
AML in Insurance: How to Detect & Combat Money Laundering, Section: Common Money Laundering Methods in Insurance, Paragraphs 1-3
NEW QUESTION # 81
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