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Download Certified Anti-Money Laundering Specialists Exam Dumps

NEW QUESTION 45
What kind of person should perform the independent testing of an institution's anti-money laundering program?

• A. A retired government regulator or federal law enforcement officer
• B. A former anti-money laundering officer from a similar institution
• C. A certified specialist in the anti-money laundering field
• D. A person who reports directly to the Board of Directors or a Board Committee

Answer: C

NEW QUESTION 46
An anti-money laundering expert is hired by a new Internet bank to assess the money laundering threat to the bank. What is the most important recommendation for the expert to make given it is an on-line bank?

• A. The bank should set up automated programs to analyze transactions for money launderingactivity
• B. The bank should ensure that a firewall is set up to protect the transactions
• C. The bank should limit the amount of money which can be processed per transaction
• D. The bank should ensure that prospective new customers can be properly identified

Answer: C

NEW QUESTION 47
How do payable through accounts (PTAs) differ from normal foreign correspondent accounts?

• A. The customers can hide their identity through the use of cover payments in U.S. dollars
• B. The customers can contact the correspondent bank directly to send wire transfers
• C. The customers have the ability to directly control funds at the correspondent bank
• D. The customers do not have to worry about sanctions list screening such as OFAC

Answer: D

Explanation:
Explanation
Explanation/Reference:
Payable-Through, Pass Through, and Pass-By Accounts | Definitions and Summary A payable-through account (PTA) is also referred to as a pass through account or a pass-by account. These types of accounts are offered by US financial institutions as banking products and are used by foreign financial firms to provide their customers with access to the US financial system.
A payable-through account (PTA) is a demand deposit account through which banking agencies located in the United States extend cheque writing privileges to the customers of other institutions, often foreign banks.
PTA accounts are a concern to bank regulators because the banks or agencies providing the accounts may not subject the end customers to the same level of scrutiny as they would their own customers. These concerns were addressed in Title 3A, especially Section 311(b)(4), of the Patriot Act.
Foreign financial institutions use PTAs, also known as "pass-through" or "pass-by" accounts, to provide their customers with access to the U.S. banking system. Some U.S. banks, Edge and agreement corporations, and
U.S. branches and agencies of foreign financial institutions (collectively referred to as U.S. banks) offer these accounts as a service to foreign financial institutions. Law enforcement authorities have stated that the risk of money laundering and other illicit activities is higher in PTAs that are not adequately controlled.
What is the difference between a regular correspondent bank account and a "payable-through, pass through, or pass-by account"?
With a payable-through, pass through or pass-by account, a foreign financial firm is able to create a corresponding account in the US. However, the foreign bank also provides checks to its foreign customers who might be interested in conducting US transactions. These foreign customers are then able to write checks to withdraw from or make deposits into the account.
In general, these foreign customers of a foreign bank are not subject to anti-money laundering screening, but they end up having full access to the US financial system.
Higher Money Laundering Risk
Based on their nature, payable-through, pass through, and pass-by accounts are considered as posing higher money laundering risk concerns.
Risk Factors
PTAs may be prone to higher risk because U.S. banks do not typically implement the same due diligence requirements for PTAs that they require of domestic customers who want to open checking and other accounts.
For example, some U.S. banks merely request a copy of signature cards completed by the payable through customers (the customer of the foreign financial institution). These U.S. banks then process thousands of sub- accountholder checks and other transactions, including currency deposits, through the foreign financial institution's PTA. In most cases, little or no independent effort is expended to obtain or confirm information about the individual and business subaccountholders that use the PTAs.
Foreign financial institutions' use of PTAs, coupled with inadequate oversight by U.S. banks, may facilitate unsound banking practices, including money laundering and related criminal activities. The potential for facilitating money laundering or terrorist financing, OFAC violations, and other serious crimes increases when a U.S. bank is unable to identify and adequately understand the transactions of the ultimate users (all or most of whom are outside of the United States) of its account with a foreign correspondent. PTAs used for illegal purposes can cause banks serious financial losses in criminal and civil fines and penalties, seizure or forfeiture of collateral, and reputation damage.

NEW QUESTION 48
In which two ways does a government Financial Intelligence Unit interact with public and private sectors?
(Choose two.)

• A. It receives and analyzes disclosures filed by financial and non-bank institutions
• B. It disseminates information and the results of its analysis to competent authorities
• C. It mediates disputes between financial institutions and investigative authorities
• D. It governs the methods of investigation used by competent authorities

Answer: A,B

Explanation:
Explanation/Reference: http://pubdocs.worldbank.org/en/834721427730119379/AML-Module-2.pdf

NEW QUESTION 49
What are two requirements of United States financial institutions when conducting business with an international financial institution as a result of the USA PATRIOT Act? (Choose two.)

• A. Complying with Special Measures issued under the USA PATRIOT Act
• B. Performing due diligence on correspondent accounts
• C. Performing enhanced due diligence on shell banks
• D. Visiting the head office of the international financial institution

Answer: A,B

NEW QUESTION 50
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