Complete CAMS ACAMS Materials

1. Information Technology Staff: These employees handle systems, databases, and software used for transaction monitoring, customer due diligence (CDD), and other AML processes. They need to understand how to configure and maintain AML systems, recognize suspicious patterns, and ensure data security.

2. Customer Facing Staff: Frontline employees, such as tellers, relationship managers, and customer service representatives, interact directly with customers. They play a crucial role in identifying red flags, conducting enhanced due diligence (EDD), and reporting suspicious activities. Training helps them recognize unusual behavior and follow proper procedures.

3. AML/Compliance Staff: These professionals are directly responsible for AML program management, policy development, and regulatory compliance. They need in-depth knowledge of AML laws, regulations, and best practices. Training ensures they stay updated and can effectively implement AML controls.

Section 319(b) of the USA PATRIOT Act allows U.S. authorities to seize funds from correspondent accounts held by foreign banks in the U.S.

Option A (Correct):Section 319(b) grants the U.S. government authority to seize assets in U.S. correspondent bank accounts belonging to foreign financial institutions involved in illicit activities.

Option B (Incorrect):Section 314(b) facilitates voluntary information sharing among financial institutions but does not authorize asset seizure.

Option C (Incorrect):Section 314(a) relates to law enforcement requests for financial intelligence, not asset seizures.

Option D (Incorrect):Section 319(a) concerns record-keeping requirements for foreign banks but does not authorize asset seizures.

Best Practices for Foreign Banks with U.S. Correspondent Accounts:

Ensure full AML compliance to avoid regulatory scrutiny.

Avoid processing high-risk transactions that may trigger U.S. jurisdiction.

Monitor cross-border transactions to detect potential financial crime exposure.

The scenario described in the question presents several indicators of potential money laundering through real estate, which the broker should be aware of and report accordingly. The most relevant red flags are:

Value: The student wants to buy a home that is overvalued, meaning that the asking price is higher than the market value or the appraisal value of the property. This could indicate that the student is trying to launder a large amount of illicit funds in one transaction, or that the seller is colluding with the student to inflate the price and receive a kickback. Overvaluing or undervaluing properties is a common technique used by money launderers to manipulate the price of real estate and conceal the source or destination of their funds12.

Inconsistency: The student’s behavior and profile are inconsistent with the typical characteristics of a legitimate home buyer. The student cancels the viewing of the home at the last minute due to illness, which could suggest a lack of interest or a pretext to avoid scrutiny. The student also wants to buy an expensive home despite being a student, which could indicate a discrepancy between the student’s income and the source of funds. Moreover, the student disregards the broker’s objections to the asking price, which could imply that the student is not concerned about the value or quality of the property, but rather the amount of money that can be laundered through it34.

Transaction speed: The student wants to quickly buy the home, which could indicate a sense of urgency or pressure to move the illicit funds before they are detected or seized by the authorities. Money launderers often use fast transactions to avoid raising suspicion or leaving a paper trail. Transaction speed is especially relevant when combined with other red flags, such as cash payments, anonymous buyers, or overvalued properties5 .

AnEnterprise-Wide Risk Assessment (EWRA)helpsfinancial institutionsidentify and mitigatemoney laundering risks.

Option B (Correct):Wolfsberg Group and FATF emphasize that an EWRA should focus onhigher-risk customers, products, and geographies, ensuringappropriate controlsare in place.

Option A (Incorrect):Institutions shouldnot blindly adopt third-party frameworkswithoutcustomizing themto their specific risk exposure.

Option C (Incorrect):While new clients are important, an EWRA mustassess risks across all customers and transactions.

Option D (Incorrect):EWRAmust address residual risk, not just inherent risk. Effectivemitigation strategiesare essential.