ACAMS Updated CAMS Exam Questions and Answers by wilbur

The customer’s business activity as a domestic carpet cleaning company is not inherently suspicious, as it aligns with their registered business. However, the significant weekly transactions from an international reputable antique auction house raise red flags.

The sudden increase in the customer’s initial international receipt from $15,000 USD to an average of $30,000 USD per transaction per week is also noteworthy. Such a substantial change warrants further scrutiny.

The fact that 90% of the incoming deposits are matched by cash outgoings to non-related individuals could indicate layering or structuring activities associated with money laundering.

Overall, the combination of large international transactions, increased receipts, and cash outflows to unrelated parties from an antique auction house is the most concerning aspect.

ARisk Appetite Statement (RAS)helps financial institutions defineacceptable risk levelsand align them withregulatory compliance and business strategy.

Option A (Correct):Incorporating risk appetite adherence into internal reporting ensures consistent enforcementandaccountabilityacross business functions.

Option D (Correct):Embedding risk appetite into daily processes ensures that compliance is built into the organization’s culture and operations.

Option E (Correct):Training employees on risk appetite awareness helps them understand compliance limits and risk management principles.

Why Other Options Are Incorrect:

Option B (Incorrect):Whiletraining managers on "good" risk-takingis valuable,it does not directly enhance risk appetite awareness for compliance.

Option C (Incorrect):Describing risk controls is useful but insufficientfor embedding risk appetite into an organization’s structure.

Best Practices for Implementing Risk Appetite Awareness:

Ensure risk appetite is a key part of regulatory and operational reporting.

Train employees at all levels on risk tolerance boundaries.

Integrate risk appetite considerations into product development and customer onboarding processes.

The rules imposed by the Office of Foreign Assets Control (OFAC) for legal entities and persons related to the US are:

Nationals of the US must comply with OFAC rules, regardless of where they are located in the world. This means that US citizens, permanent residents, and entities organized under US law are subject to OFAC sanctions and prohibitions, even if they operate or reside outside the US12.

Any foreign corporation is also penalized if it conducts transactions with sanctioned countries under OFAC rules. This means that non-US entities that engage in trade or financial dealings with OFAC-designated countries, entities, or individuals are liable to face civil or criminal penalties, as well as secondary sanctions that could restrict their access to the US market or financial system34.

The other options are not correct, because:

A subsidiary of a legal entity of the US, which is formally registered in a foreign country, is not exempt from OFAC rules. This means that foreign-incorporated entities that are owned or controlled by US persons or entities are also subject to OFAC sanctions and prohibitions, unless they are specifically authorized or licensed by OFAC12.

A foreign individual visiting the US for a short vacation is not obligated to follow OFAC rules. This means that non-US persons who are temporarily present in the US are not subject to OFAC sanctions and prohibitions, unless they are involved in transactions that have a US nexus or violate other US laws.

The head office of a foreign legal entity which has a branch in the US does not need to comply with OFAC rules. This means that non-US entities that have a presence or operation in the USare not subject to OFAC sanctions and prohibitions, unless they are involved in transactions that have a US nexus or violate other US laws.

Casinos and gambling institutionsare highly vulnerable to money launderingbecause they allow theconversion of cash into chips, checks, or electronic credits, which can later be redeemed as “clean” funds.

Option A (Correct):A privately held company funding multiple patrons' betting accounts is highly suspiciousand may indicate:

Structuring/smurfing, where multiple individuals are used to move illicit funds.

Third-party money laundering, where the real source of funds is obscured.

Trade-based money laundering, if linked to non-gaming businesses.

Why Other Options Are Incorrect:

Option B (Incorrect):Placing multiple bets on the same eventis not inherently suspiciousunless linked tofraudulent betting patterns.

Option C (Incorrect):Large chip purchases in cashmay requirereporting, but they do not necessarily indicatemoney laundering.

Option D (Incorrect):Transferring winnings to another operator may beunusual, butnot automatically suspiciousunless the amount is large and unjustified.

Common Money Laundering Techniques in Casinos:

Chip Walking– Buying chips with illicit funds and cashing them out later as "clean" funds.

Casino Account Transfers– Using multiple accounts or third-party accounts to move funds.

High-Value Gambling with No Loss Intent– Betting on both sides of an event to ensure clean withdrawal of funds.

Best Practices for Casino AML Compliance:

Monitor suspicious large transactions and third-party funding activities.

Perform enhanced due diligence (EDD) on high-risk patrons.

File Suspicious Transaction Reports (STRs) for unusual gambling activity.