Introduction to Money Laundering and CFT
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Questions and Answers

Which of the following best describes an electronic funds transfer?

  • A transfer of funds that always crosses international borders.
  • A physical movement of cash between two locations.
  • A transfer via a courier service.
  • Any transfer of funds initiated through electronic means. (correct)
  • Why are electronic funds transfers commonly used in money laundering schemes?

  • Because they are the slowest way to move money.
  • Because they can be easily tracked by law enforcement.
  • Because the vast volume makes it easy to hide illicit transactions. (correct)
  • Because they involve physical movement of cash.
  • Which of the following is NOT a common method for money launderers to use electronic transfers?

  • Purchasing merchandise with stolen cards for later resale.
  • Using SWIFT and CHIPS systems to transfer money internationally.
  • Initiating unauthorized domestic transfers using stolen credit cards.
  • Making large, easily traceable transfers to obscure origins. (correct)
  • In the context of money laundering, what is the purpose of 'layering' using electronic transfers?

    <p>To move funds through multiple accounts and jurisdictions to obscure their origin. (D)</p> Signup and view all the answers

    What is a common precaution money launderers take when using electronic transfers to avoid detection?

    <p>Varying the amounts sent and keeping them relatively small. (B)</p> Signup and view all the answers

    What is the role of transaction monitoring software in regards to electronic transfers?

    <p>To detect and trigger alerts for suspicious activities. (D)</p> Signup and view all the answers

    What does the content suggest about the effectiveness of systems designed to detect money laundering via electronic transfer?

    <p>They are helpful but not perfect, and can sometimes be circumvented. (B)</p> Signup and view all the answers

    Which of the following is an example of a system that facilitates electronic funds transfers?

    <p>The Society for Worldwide Interbank Financial Telecommunication (SWIFT). (D)</p> Signup and view all the answers

    What is a key function of a comprehensive AML/CFT framework?

    <p>To discourage criminals by eliminating profits from crime and enforcing laws. (C)</p> Signup and view all the answers

    How do front companies gain an advantage over legitimate businesses?

    <p>By having access to substantial illicit funds, allowing them to subsidize products. (A)</p> Signup and view all the answers

    What is a potential consequence of using front companies and investments to launder money?

    <p>Monetary and economic instability due to misallocated resources and artificial price distortions. (B)</p> Signup and view all the answers

    How can money laundering and terrorist financing affect a country's financial sector?

    <p>By negatively affecting the soundness of the financial sector and potentially leading to bank failures. (D)</p> Signup and view all the answers

    What is a typical requirement for financial organizations concerning AML/CFT programs?

    <p>The establishment and maintenance of an effective AML/CFT program is usually part of their charter to operate. (D)</p> Signup and view all the answers

    What is a potential outcome for a financial organization that does not comply with its AML/CFT program?

    <p>The organization could face significant civil penalties and potentially lose its charter. (A)</p> Signup and view all the answers

    Why can money laundering lead to a misallocation of resources?

    <p>Because illicit funds result in artificial distortions in asset and commodity prices. (A)</p> Signup and view all the answers

    How does money laundering relate to tax evasion?

    <p>Money laundering provides a way to evade taxes, thus depriving the country of revenue. (D)</p> Signup and view all the answers

    Under the SM&CR, what explicit responsibility is given to a senior manager in relation to financial crime?

    <p>To ensure that efforts to combat financial crime are effectively designed and implemented. (A)</p> Signup and view all the answers

    According to the New York State Department of Financial Services (DFS) Final Rule, what is a key requirement for transaction monitoring and filtering programs?

    <p>They must be risk-based and commensurate with the organization's own risk assessment and profile. (D)</p> Signup and view all the answers

    What does 'Model Performance Calibration' refer to in the context of AML/CFT models, according to the DFS Final Rule?

    <p>Ongoing analysis and testing of the AML/CFT models to assess the scenario logic, performance, model technology, assumptions, and model parameter settings. (D)</p> Signup and view all the answers

    What specific type of testing is required for transaction monitoring systems under the DFS Final Rule to ensure rules are validated and data are complete and accurate?

    <p>End-to-end, pre- and post-model implementation testing. (C)</p> Signup and view all the answers

    Who is required to annually certify to the DFS that they have taken all necessary steps to comply with transaction monitoring and filtering program requirements?

    <p>The board of directors or senior officers of the regulated organizations. (B)</p> Signup and view all the answers

    Which types of financial organizations are explicitly covered by the New York State DFS Final Rule?

    <p>Banks, trust companies, private bankers, savings banks, savings and loan associations chartered pursuant to the New York Banking Law as well as branches and agencies of foreign banking corporations licensed to conduct banking in New York, and certain nonbank financial organizations. (D)</p> Signup and view all the answers

    Besides chartered financial institutions, what other type of organization is included in the scope of the New York State DFS Final Rule, for example, a business with a banking law license?

    <p>Check cashers and money transmitters. (A)</p> Signup and view all the answers

    What is the consequence for a senior manager who is personally accountable for misconduct within an organization’s AML/CFT regime?

    <p>They are personally accountable for any misconduct within the organization’s AML/CFT regime. (B)</p> Signup and view all the answers

    Which of the following scenarios is LEAST indicative of potential money laundering activity involving electronic transfers?

    <p>Funds transfers to a known high-risk geographic location consistent with the customer's historical business operations. (D)</p> Signup and view all the answers

    A series of small, incoming transfers via checks and money orders followed by the majority of the funds wired to another account in a different location is an indicator of:

    <p>Potential money laundering. (B)</p> Signup and view all the answers

    What banking product allows customers to deposit checks remotely by scanning images, increasing convenience but also potential for abuse?

    <p>Remote Deposit Capture (RDC) (A)</p> Signup and view all the answers

    Why is Remote Deposit Capture (RDC) considered a risky service in the context of money laundering?

    <p>It allows for the processing of checks without the need for the physical transfer of paper. (B)</p> Signup and view all the answers

    What is a major way that money launderers are now abusing the convenience of Remote Deposit Capture (RDC)?

    <p>By arranging for others to set up accounts and then deposit checks through them using multiple devices. (B)</p> Signup and view all the answers

    What is 'correspondent banking'?

    <p>A service by one bank to another bank. (C)</p> Signup and view all the answers

    Which pattern of funds activity is considered a potential indicator of money laundering?

    <p>Unexplained, repetitive, or unusual patterns. (A)</p> Signup and view all the answers

    What is a key benefit of Remote Deposit Capture (RDC) for banks?

    <p>It reduces the cost to process checks. (B)</p> Signup and view all the answers

    What is a primary vulnerability of correspondent banking regarding financial crime?

    <p>Correspondent banks rely on respondent banks' internal controls and do not directly know the respondent's customers. (B)</p> Signup and view all the answers

    According to the Wolfsberg Group, what factor should primarily drive the due diligence a bank performs on a respondent bank?

    <p>The respondent bank's risk profile and the nature of the business relationship. (D)</p> Signup and view all the answers

    Which of these is NOT a specific risk indicator that should be addressed during due diligence on a respondent bank?

    <p>The correspondent banks technology infrastructure. (B)</p> Signup and view all the answers

    When should both a respondent bank and its ultimate parent undergo due diligence?

    <p>If the parent does not exercise substantial and effective control over the respondent bank. (D)</p> Signup and view all the answers

    What does the Wolfsberg Group provide to help standardized due diligence in correspondent banking?

    <p>A Correspondent Banking Due Diligence Questionnaire. (D)</p> Signup and view all the answers

    Which of these services would be least likely to be offered to a high-risk respondent bank by a correspondent bank?

    <p>International funds transfers. (C)</p> Signup and view all the answers

    Which of these best describes a risk found in correspondent banking?

    <p>Correspondents do not always have data to enable transaction monitoring controls. (B)</p> Signup and view all the answers

    What is a key limitation in a correspondent's ability to oversee their respondent?

    <p>The correspondent may know the respondent's regulators, but not the degree of supervision they perform. (B)</p> Signup and view all the answers

    Which of the following is NOT one of the three stages of the money laundering cycle?

    <p>Diversification (A)</p> Signup and view all the answers

    What is the primary risk associated with payable-through accounts?

    <p>They can be used to obscure the identity of the originator of funds (C)</p> Signup and view all the answers

    Which of the following best describes 'structuring' in the context of money laundering?

    <p>Breaking up large sums of money into smaller transactions to evade reporting thresholds (B)</p> Signup and view all the answers

    What is a key risk associated with the use of concentration accounts?

    <p>They can obscure the origin and destination of funds (C)</p> Signup and view all the answers

    What is the main purpose of a shell company in money laundering schemes?

    <p>To obscure the true ownership of assets and funds (A)</p> Signup and view all the answers

    What is a key characteristic of trade-based money laundering (TBML)?

    <p>It exploits the use of international trade transactions to move and conceal illicit funds (C)</p> Signup and view all the answers

    Which international organization is primarily responsible for setting global standards on combating money laundering and terrorist financing?

    <p>The Financial Action Task Force (FATF) (B)</p> Signup and view all the answers

    What is the primary function of the Egmont Group of Financial Intelligence Units (FIUs)?

    <p>To facilitate cooperation and the exchange of information among FIUs worldwide (D)</p> Signup and view all the answers

    What is the main purpose of the USA PATRIOT Act?

    <p>To strengthen US measures to prevent and combat money laundering and terrorist financing (B)</p> Signup and view all the answers

    Which of the following is NOT a typical method terrorists use to raise funds?

    <p>Government grants (A)</p> Signup and view all the answers

    What is the 'layering' stage of money laundering primarily designed to do?

    <p>To hide the original source of the money through a series of transactions (A)</p> Signup and view all the answers

    What is a 'politically exposed person' (PEP) in the context of AML/CFT?

    <p>An individual who holds or has held a prominent public position (C)</p> Signup and view all the answers

    What is the main focus of the Basel Committee on Banking Supervision?

    <p>Promoting best practices in banking regulation and supervision (A)</p> Signup and view all the answers

    Which of the following is a key risk associated with private banking?

    <p>It may involve high-net-worth individuals who are susceptible to corruption (D)</p> Signup and view all the answers

    In the context of money laundering, what is 'microstructuring'?

    <p>Breaking up large sums of money into very small transactions, often below reporting thresholds (B)</p> Signup and view all the answers

    Flashcards

    Front Companies

    Businesses that appear legitimate, but are controlled by criminals to mix illegal funds with legitimate ones, hiding the source of money.

    Competitive Disadvantage for Legitimate Businesses

    The practice of criminals using front companies to create an unfair advantage in the market by subsidizing products at below-market prices.

    Economic Instability

    The negative impact of money laundering on economic stability due to the misuse of resources caused by manipulated prices.

    Controlling Industries Through Money Laundering

    The practice of using front companies and investments in legitimate businesses to gain control over entire industries or sectors of a nation's economy.

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    Tax Evasion through Money Laundering

    Avoiding paying taxes by using money laundering techniques, depriving a country of crucial revenue.

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    Weakening of Financial Organizations

    The harmful impact of money laundering and terrorist financing on the stability of financial institutions like banks, securities firms, and insurance companies.

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    Loss of Financial License

    The potential loss of a financial organization's license to operate due to non-compliance with AML/CFT regulations.

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    Importance of AML/CFT Compliance

    The importance of establishing and maintaining effective AML/CFT programs for financial organizations to safeguard their operations and stability.

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    Electronic Funds Transfer

    Any form of money transfer initiated electronically, such as through internet banking, ACH, ATMs, mobile apps, etc.

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    SWIFT (Society for Worldwide Interbank Financial Telecommunication)

    A network used by banks to send large volumes of money electronically, often used for international transactions.

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    Layering (in money laundering)

    The process of moving illicit funds through a series of transactions to obscure their origin.

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    Structuring (in money laundering)

    Using small amounts of money in multiple transactions to avoid detection by systems designed to catch large suspicious transactions.

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    Unauthorized Transfers

    Sending funds from one bank account to another, either within the same country or across borders.

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    Automated Clearing House (ACH)

    A type of electronic funds transfer used by banks for routine transactions like bill payments and direct deposits.

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    Money Laundering (in general)

    The process of converting illegally obtained money into seemingly legitimate funds to conceal its origin.

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    Transaction Monitoring Software

    Software programs designed to identify suspicious financial transactions that could indicate money laundering.

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    Financial Secrecy Haven Transfers

    Fund transfers to or from a country with known financial secrecy or high risk of money laundering, without a clear business reason or matching the customer's normal activity.

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    Unexplained Foreign Transfers

    Large sums received for a foreign client with minimal or no explanation, seeming unusual for the customer's profile.

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    Small Deposits, Big Transfers

    Multiple small deposits made using checks or money orders, with subsequent immediate transfers to another account in a different location.

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    Unusual Financial Patterns

    Financial activities lacking a clear explanation, showing repeating patterns or unusual behavior.

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    Unrelated Payments

    Payments or income without clear links to legitimate contracts, goods, or services.

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    Multiple Accounts, Same Person

    Transfers involving the same person, but to or from different accounts.

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    Remote Deposit Capture (RDC)

    A banking service that allows customers to scan checks and submit electronic images for deposit, avoiding physical bank visits.

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    RDC Abuse Risk

    The potential for abuse of RDC due to the ease of moving checks through accounts and allowing multiple devices or individuals to process them, facilitating money laundering activities.

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    Correspondent Bank

    A bank that provides services to other banks, allowing them to access financial markets and conduct transactions globally.

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    Respondent Bank

    A bank that uses the services of a correspondent bank to access global financial markets and conduct transactions.

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    Due Diligence on Respondent Banks

    The process of verifying the identity, reputation, and operations of a correspondent bank before establishing a business relationship.

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    Respondent Bank Risk

    The risk that a respondent bank may engage in money laundering or other financial crimes, putting the correspondent bank at risk.

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    Know Your Customer's Customer (KYCC)

    The practice of knowing the customers of your customers, which is crucial for correspondent banks to identify potential financial crime risks.

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    Transaction Monitoring of Respondent Banks

    The ability of a correspondent bank to monitor the transactions of a respondent bank to identify suspicious activity.

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    Regulatory Oversight of Respondent Banks

    The level of oversight and control exercised by a respondent bank's ultimate parent company.

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    Wolfsberg Group Correspondent Banking Due Diligence Questionnaire

    A questionnaire used by the Wolfsberg Group to perform due diligence on respondent banks, providing standardized questions.

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    Money Laundering Reporting Officer (MLRO)

    A senior manager, such as an MLRO, who is responsible for ensuring that a financial institution's anti-money laundering (AML) program is effectively designed and implemented.

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    Transaction Monitoring

    The process of analyzing and monitoring transactions after they occur to detect suspicious activity and prevent illegal transactions.

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    AML/CFT Regime

    A set of rules and procedures designed to detect and prevent money laundering and terrorist financing.

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    Model Performance Calibration

    The process of evaluating the effectiveness of a financial organization's AML/CFT program through regular analysis and testing.

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    End-to-End Testing

    Testing the entire AML/CFT system from beginning to end to ensure accuracy and effectiveness.

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    Risk-Based Approach

    The requirement for financial institutions to tailor their AML/CFT program to their unique risks and vulnerabilities.

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    Money Laundering

    The process of legally obtaining money or assets that were derived from illegal activities, making them appear legitimate.

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    Placement

    The initial step in the money laundering process, where illegally obtained funds are introduced into the financial system. This can involve cash deposits, wire transfers, or even the purchase of assets.

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    Layering

    The second stage of money laundering, where the origin of the funds is obscured by moving them through a series of transactions. This can involve layering funds through different accounts or using complex financial instruments.

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    Integration

    The final stage of money laundering, where the funds are integrated back into the legitimate economy, often through investments, purchases, or other seemingly legitimate activities.

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    Structuring

    The process of making multiple smaller transactions to avoid triggering reporting requirements. It involves breaking up large amounts of cash into smaller amounts to evade detection.

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    Correspondent Banking

    A financial institution that provides banking services to other financial institutions. They facilitate international transactions by acting as intermediaries between banks.

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    Concentration Accounts

    A system used by banks to handle large volumes of transactions more efficiently. It involves creating a central account where multiple client accounts are bundled together for processing.

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    Private Banking

    A type of banking service offered to high-net-worth individuals and families. It involves personalized financial advice, investment management, and access to exclusive banking products.

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    Private Investment Companies (PICs)

    A financial entity that provides investment management services, often targeting private clients. They may be used to obscure the true owner of funds.

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    Politically Exposed Persons (PEPs)

    Individuals who hold prominent public positions, such as government officials, politicians, or high-ranking executives. They are at a higher risk of being targeted for corruption or money laundering.

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    Credit Unions

    A financial institution that provides banking services to its members, typically those with a common bond, often by offering lower interest rates on loans and higher rates on deposits.

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    Third-Party Payment Processors

    A type of payment processor that acts as an intermediary between merchants and their customers, enabling online payments and other financial transactions. They can be used for money laundering if they don't have robust AML controls.

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    Money Services Businesses (MSBs)

    Businesses that provide money transfer services, such as remittances, wire transfers, and check cashing. They handle large sums of cash and are at a high risk of being used for money laundering activities.

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    Trade-Based Money Laundering (TBML)

    A type of money laundering scheme that involves exploiting the global trade system. It uses legitimate trade transactions as a cover to move illicit funds. Examples include over-invoicing and under-invoicing of goods.

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    Study Notes

    Introduction to Money Laundering and Terrorist Financing

    • ACAMS (Association of Certified Anti-Money Laundering Specialists) is an organization focused on anti-money laundering (AML) and combating the financing of terrorism (CFT).
    • Access to this document is strictly for personal study purposes and is not permissible for any other usage without formal consent from ACAMS.
    • ISBN: 978-0-9777495-2-2

    Risks and Methods of Money Laundering and Terrorist Financing

    • Money Laundering: The process of disguising illicitly obtained funds as legitimate.
    • Three Stages of Money Laundering:
    • Placement: Initially transferring illicit funds into legitimate financial systems.
    • Layering: Complex transactions to mask the original source of funds.
    • Integration: The proceeds appear to be legitimate funds.
    • Money laundering and terrorist financing harm a nation's financial sector and private sector.
    • Illicit activity can destabilize individual financial institutions and banks, shown by instances of past bank closures.
    • Non-compliance with AML/CFT programs can lead to harsh civil penalties and loss of operating licenses.

    Banks and Other Depository Institutions

    • Electronic Funds Transfers: Rapid and versatile, easily concealing illicit transactions among legitimate ones.

    • Various methods like ACH, ATM, mobile phones are used by perpetrators.

    • Risks include unauthorized transfers, credit card fraud, and layering.

    • Remote Deposit Capture (RDC): A service allowing customers to electronically deposit checks.

    • Increased convenience but also easily abused by criminals.

    • Correspondent Banking: One bank providing services to another.

    • High risk from lack of direct customer knowledge.

    • Banks should evaluate respondent banks for risks in due diligence.

    • Questions based on risk profile, geography, management, and services are key.

    • Payable-Through Accounts: Account used as an intermediary; Money laundering through these accounts are made possible by their inherent opacity.

    • Concentration Accounts: Account designed to collect and aggregate funds from multiple sources.

    • Private Banking: High-net-worth individuals can be high risk for engaging in money laundering.

    • Private Investment Companies (PICs): Used for intricate money laundering schemes due to their obscurity; Funds are commingle into legitimate companies masking the source of assets .

    • Politically Exposed Persons (PEPs): Individuals holding prominent positions who are significantly at risk of money laundering given their status.

    • Structuring: Manipulating transactions to avoid regulatory reporting thresholds, this is a technique of avoiding triggering AML compliance protocols.

    • Microstructuring: A type of structuring aimed to evade reporting requirements.

    • Credit Unions and Building Societies (CU/BS): Similar AML risk to banks but face some unique challenges.

    Non-bank Financial Institutions

    • Credit Cards: High-volume transactions; potential avenue for illicit activity.
    • Third-Party Payment Processors: Facilitating electronic payments; may be involved in money laundering.
    • Money Services Businesses (MSBs): Companies involved in financial transactions; prone to money laundering (ex: Bureaus and money transfer services).

    Insurance Companies, Securities Broker-Dealers, and Nonfinancial Businesses

    • Insurance Companies and Securities Broker-Dealers: These institutions are vulnerable to money laundering. Dealers frequently handle large volume of assets from high-value transactions.
    • Casinos: High-value transactions without extensive oversight, increasing vulnerability to money laundering.
    • Dealers in High-Value Items: Dealers in precious metals, gems, art, etc. face elevated money laundering risks as these assets easily conceal illicit capital.
    • Travel Agencies and Websites: Facilitating international travel, vulnerable to money laundering.
    • Vehicle Sales: Selling luxury vehicles and use of vehicles as fronts for money laundering.
    • Gatekeepers: Notaries, accountants, auditors, and lawyers can be instrumental in facilitating suspicious activity.
    • Investment and Commodity Advisors: Expertise in financial instruments; potential facilitators in money laundering schemes.
    • Trust and Company Service Providers: Assist in setting up complex structures concealing beneficial ownership; facilitate concealing assets in trust schemes.
    • Real Estate: Can be used to launder assets through shell entities or property ownership.

    International Trade Activity (Trade-Based Money Laundering)

    • Free Trade Zones: Designated areas; money can be moved easily given the reduced regulatory oversight.
    • Trade-Based Money Laundering (TBML): Using international trade processes to conceal illicit funds.
    • Black Market Peso Exchange (BMPE): A type of trade-based money laundering, characterized by the use of an illicit market.
    • Wildlife Trafficking: another avenue to launder funds.

    Risk Associated with New Payment Products and Services

    • Prepaid Cards, Mobile Payments, and Internet-Based Payment Services: Newer payment methods can obfuscate transactions making them vulnerable.
    • Virtual Currency (Crypto-currency): Cryptocurrency can be used to hide transactions.
    • Dark Web: A portion of the internet used anonymously; serves as a hub for illicit financial activities involving cryptocurrency.

    Corporate Vehicles Used to Facilitate Illicit Finance

    • Public Companies and Private Limited Companies: Corporations can be used to conceal ownership and transactions.
    • Shell and Shelf Companies: Companies with minimal activities used to hide true ownership.
    • Trusts: Used to obscure ownership and control in asset transfers.

    Terrorist Financing

    • Differences and Similarities between Terrorist Financing and Money Laundering: Both involve financial transactions.
    • Detection of Terrorist Financing: Evaluating suspicious transactions and sources of funds used by terrorist organizations.
    • Use of Hawala and Informal Value Transfer Systems: Cryptographic mechanisms used by terrorist organizations to conceal financial activities.
    • Use of Charities and Nonprofit Organizations (NPOs): Fundraising through NGOs (Non-profit organizations) to channel funds.

    International AML/CFT Standards

    • Financial Action Task Force (FATF): Develops standards and guidelines for AML and CFT.
    • FATF 40 Recommendations: Key guidelines; 40 specific recommendations to facilitate money laundering compliance.
    • FATF-Style Regional Bodies: Regional organizations following the FATF model (ex: APG, CFATF).

    Key US Legislative and Regulatory Initiatives

    • USA PATRIOT Act: Important US Law; significantly increases US AML and CFT measures.
    • Anti-Money Laundering Act (AMLA) of 2020: Updated legislation, aimed at curbing money laundering.
    • Office of Foreign Assets Control (OFAC): US department; enforced US sanctions.
    • Bank Secrecy Act (BSA): US Act; imposes requirements on US. Financial organizations regarding recordkeeping and reporting suspicious activity.
    • New York State Department of Financial Services (DFS): Key regulator in US; responsible for enforcing AML compliance in financial institutions.

    AML/CFT Compliance Programs

    • Assessing AML/CFT Risk: Evaluating the probability and impact of financial crimes.
    • Risk-based models are crucial in accurately assessing the susceptibility to money laundering
    • AML/CFT Program: Essentials of a compliance program include Policies, procedures, training, monitoring, and independent audit.
    • Compliance Officer Accountability: Senior officers are accountable for AML program effectiveness.
    • AML/CFT Training: Comprehensive training is required to ensure operational staff has an understanding of money laundering

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    CAMS Study Guide v6.5 PDF

    Description

    This quiz explores the essential concepts of money laundering and terrorist financing, as introduced by ACAMS. It covers the risks associated with these financial crimes and elaborates on the three stages of money laundering: placement, layering, and integration. Gain insights into how these activities affect the financial sector and measures to combat them.

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