CAMS Questions Bank

The foreign bank must always request approval by its national anti-financial crime authority to share any information cross-border.

The bank should report this to the Financial Crimes Enforcement Network (FinCEN) and receive formal guidance before sharing the information.

The bank should consider jurisdictional privacy requirements and its own policies and procedures to determine what information to share.

The information should only be shared on a need-to-know basis.

Ensure that the second line reviews, monitors, and escalates risk-related issues as needed to senior management while maintaining independent oversight from the third line

Have senior management handle risk-related issues directly when possible because they are ultimately responsible for the organisation's overall risk management strategy

Delegate some risk-related issues to the first line to avoid overwhelming the second line and to ensure operational efficiency

Assign risk-related oversight duties to the third line to provide an independent review and address issues more effectively by avoiding conflicts of interest in the first and second lines

A client frequently submits financial statements much earlier than required appearing overly eager

A client insists on using a personal bank account for business transactions despite being advised otherwise

A new client shows a preference for minimal direct interaction and relies primarily on indirect communication methods, citing convenience or time constraints

The client is a publicly listed company but very diversified

The ultimate beneficial ownership is unclear

Send a 314(b) request to the corporation's bank in Hong Kong

Call the receiving individual to review identity verification documents

Confirm that neither the beneficiary nor the originator are sanctioned parties

Request supporting documents, including invoices and contracts to confirm the purpose of the payment

Check for negative news in public sources on the sender and receiver