Online CAMS Questions Video

---Wire transfers are one of the most common methods of moving funds across borders and jurisdictions, and therefore pose a high risk of violating OFAC sanctions. A bank’s OFAC sanctions screening audit program should include a test to review the wire transfer screening processes to ensure that potential name hits are investigated promptly and appropriately, and that any blocked or rejected transactions are reported to OFAC in a timely manner. This test would help the bank to assess the effectivenessof its screening system, identify any gaps or weaknesses, and demonstrate its compliance with OFAC regulations.

A Framework for OFAC Compliance Commitments1, page 4, section 4: Testing and Auditing

OFAC Framework for Sanctions Compliance Programs2, page 2, section 4: Testing and Auditing

OFAC Sanctions List Search Tool3

The most important risk factor in this scenario is the proposed offshore jurisdiction that is known for its strong privacy laws limiting access to customer information by law enforcement. This indicates that the customer may be trying to evade tax, hide the source or destination of funds, or engage in other illicit activities that could expose the bank to money laundering or terrorist financing risks. Offshore jurisdictions are often used by criminals to create complex corporate structures that obscure the beneficial ownership and control of the entities involved. The bank should conduct enhanced due diligence on the customer, the offshore company, and the nature and purpose of the transactions.

ACAMS CAMS Certification Study Guide, 6th Edition, Chapter 2, page 35-36, 38-39

ACAMS CAMS Certification Video Training Course, Module 2, Lesson 2.3, Offshore Financial Centers

1, CAMS Certification Package - 6th Edition | ACAMS, Offshore Financial Centers and Money Laundering

2, CAMS Certifications: How to Get CAMS Certified | ACAMS, CAMS Exam Outline, Domain 2, Task 2.3

According to the research report by the Council of Europe1, one of the typologies of money laundering through online gambling is the use of multiple accounts and identities to conceal the source and destination of funds. This can be done by opening several accounts under the same name using different IP addresses, or by using false or stolen identification documents to create multiple accounts. Another typology is the use of online gambling platforms that are not regulated or authorized by the jurisdiction where the customer is located, or that do not require know-your-client information from users. This can allow money launderers to access the online gambling services from multiple countries, without being subject to any verification or monitoring by the authorities.

1: Research report - The use of online gambling for money laundering and the financing of terrorism purposes, Council of Europe, April 2013.

The customer activity that poses the highest risk of money laundering is making multiple cash deposits slightly below a required reporting limit. This could indicate a practice known as structuring or smurfing, which is a method of breaking down large amounts of cash into smaller transactions to avoid detection or reporting by financial institutions12. Structuring is a common technique used by money launderers to conceal the source, ownership, or destination of illicit funds3.

The other options are not necessarily indicative of money laundering, although they may require further due diligence or monitoring depending on the customer profile and the nature of the transaction. For example:

Transferring funds to pay for flight training lessons could be a legitimate educational expense, or it could be related to terrorist financing or other criminal activities. The financial institution should verify the identity and background of the customer and the recipient, and check for any red flags or suspicious indicators4.

Paying a supplier of precious metals at regular quarterly intervals could be a normal business practice, or it could be a way of moving or storing value in an alternative asset class. The financial institution should assess the customer’s source of funds, business rationale, and market conditions, and monitor for any changes or inconsistencies.

Conducting business in a country that represents a high risk of money laundering could be a legitimate commercial opportunity, or it could be a sign of involvement in illicit activities or tax evasion. The financial institution should apply enhanced due diligence measures, such as verifying the identity and reputation of the customer and the counterparties, obtaining information on the purpose and nature of the business relationship, and screening for any sanctions or adverse media.

ACAMS CAMS Certification Video Training Course - Exam-Labs3

Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)4

ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 2, page 29:

ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 6, page 121:

ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 7, page 139:

ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 4, page 77: