ACAMS Updated CAMS Exam Questions and Answers by maja

 Bearer shares are unregistered equity securities owned by the possessor of the physical share documents. The issuing company does not record the identity or ownership of the shareholders, nor does it track the transfers of ownership. This means that the holder of the bearer share can claim ownership and exercise the rights associated with the share, such as voting and receiving dividends, by simply presenting the physical certificate. This also makes the transfer of ownership very easy, as it only requires the delivery of the physical document, without any formalities or intermediaries. Bearer shares are therefore attractive for those who seek anonymity, privacy, and flexibility in their corporate structures.

Investopedia: Bearer Share

SuperMoney: Bearer Shares: Definition, Examples, and Implications

ACAMS: Bearer Shares

An anti-money laundering officer should coordinate with the human resources department when implementing a new hire screening program. A new hire screening program is a process of conducting background checks and verifying the identity, qualifications, and suitability of prospective employees, especially those who will be involved in the bank’s anti-money laundering (AML) compliance program. The human resources department is responsible for managing the recruitment, hiring, and training of employees, and ensuring that they comply with the bank’s policies and procedures. Therefore, the human resources department is the most appropriate partner for the anti-money laundering officer in developing and executing a new hire screening program that meets the bank’s AML standards and regulatory requirements.

The other options are not relevant or necessary for the implementation of a new hire screening program. The internal auditor is responsible for evaluating the effectiveness and adequacy of the bank’s internal controls, including the AML compliance program, but not for screening new hires. The local financial intelligence unit is a government agency that collects, analyzes, and disseminates financial information related to money laundering and terrorist financing, but not for screening new hires. The institution’s regulator is the authority that supervises and examines the bank’s compliance with the applicable laws and regulations, including the AML requirements, but not for screening new hires.

ACAMS Study Guide for the CAMS Certification Examination (6th Edition), Chapter 4: Developing an AML/CFT Program 1

FFIEC BSA/AML Manual, Assessing the BSA/AML Compliance Program, BSA/AML Training 2

AUSTRAC, Employee due diligence 3

This action is the most appropriate because it demonstrates the local manager’s responsibility and accountability for the sanctions compliance program. Sanctions screening is an important part of the Know Your Customer (KYC) and Anti-Money Laundering (AML) processes, as it helps to identify and prevent transactions with sanctioned individuals or entities, which could expose the financial institution to legal, regulatory, and reputational risks. Failing to perform sanctions screening could result in violations of sanctions laws and regulations, which could lead to fines, penalties, sanctions, or even criminal prosecution. Therefore, the local manager should immediately inform senior management of the issue, so that they can take corrective actions, such as implementing screening procedures, conducting a risk assessment, reviewing existing customers, reporting any potential violations, and providing training and guidance to the staff.

The other actions are not appropriate because they either do not address the root cause of the problem, or they could worsen the situation. Starting screening new customers without informing senior management could create a false sense of compliance, and it could also miss the existing customers who may be sanctioned. Immediately informing the regulators without informing senior management could undermine the trust andcommunication within the organization, and it could also trigger an investigation or enforcement action before the issue is resolved internally. Doing nothing because the department only handles a very small number of mortgages could be a sign of negligence or indifference, and it could also expose the financial institution to significant risks, as even one transaction with a sanctioned party could have serious consequences.

CAMS Certification Package - 6th Edition | ACAMS, Chapter 4: Developing and Implementing an AML Training Program, pp. 97-98

CAMS Certifications: How to Get CAMS Certified | ACAMS, CAMS Study Guide, pp. 76-77

What is Sanctions Screening and How Does It Work? | Jumio, Introduction and Benefits of Sanctions Screening

Sanctions Screening: Challenges and Control Considerations, Background and Regulatory Expectations for Sanctions Screening

Sanction Screening: A Complete Guide | KYC AML Guide, What is Sanction Screening and Why is it Important?

account opening documents and account statements are examples of supporting documentation that can help the law enforcement agency to verify the identity, profile, and activity of the customer involved in the suspicious transaction. These documents can provide useful information such as the customer’s name, address, date of birth, identification number, occupation, source of funds, transaction history, and beneficiaries. These documents can also help to establish the baseline of normal and expected activity for the customer, and to identify any deviations or anomalies that may indicate money laundering, fraud, or other criminal activities.

Suspicious Activity Report Supporting Documentation, section “What Constitutes Supporting Documentation”, paragraph 2: “Supporting documentation may include, for example, transaction records, new account information, tape recordings, e-mail messages, and correspondence.”

Documentation Requirements: Suspicious Activity Report Supporting Documentation, section “SARs Documentation Requirements”, paragraph 2: “Keep all documents with evidence of the background, the purpose of the transactions, the trigger, the investigation carried out, and all findings and conclusions.”

BSA/AML Manual, section “Assessing the BSA/AML Compliance Program - BSA Compliance Officer”, paragraph 3: “The BSA compliance officer is responsible for ensuring that the bank’s BSA/AML compliance program is implemented effectively, including timely updates in response to changes in regulations or business activities, and for managing all aspects of the BSA/AML compliance program. The BSA compliance officer is also responsible for ensuring that the bank’s BSA/AML compliance program is communicated to all personnel and that adequate training is provided to appropriate personnel.”