CAMS Reviews Questions

According to the ACAMS study guide, one of the training elements that should be delivered to new tellers during employee orientation is “large cash transaction reporting procedures” (p. 224). This is because tellers are often the first line of defense against money laundering and have the responsibility to identify and report any transactions that exceed the threshold of $10,000 or are otherwise suspicious. The other options are not relevant for tellers, as they are more suitable for higher-level or specialized staff.

A corporate account opened on behalf of several beneficial owners is a red flag because it may indicate an attempt to conceal the identity or source of funds of the ultimate beneficiaries1. The customer’s stated investment goal of long-term investment is not reflective of the account activity, which involves frequent and large transfers, currency exchanges, and account depletion within a short period of time. This discrepancy may suggest that the customer is using the account for money laundering or other illicit purposes2.

 The next course of action for the anti-money laundering officer to take is to determine if there is a readily identifiable cause for the increase in compliance deficiencies. This could involve analyzing the data, interviewing the staff, reviewing the procedures, or conducting a root cause analysis. The anti-money laundering officer should try to find out if the deficiencies are due to human error, system failure, policy ambiguity, training gap, external factors, or any other reason. By identifying the cause, the anti-money laundering officer can then take appropriate corrective or preventive measures to address the issue and improve the compliance performance.

According to the ACAMS Study Guide 6th Edition, Chapter 2, page 37, one of the red flags of money laundering or terrorist financing is the use of nominees, trusts, or third parties to hide the identity, ownership, or control of the funds or assets involved in the transaction. Nominees are individuals or entities that act on behalf of the actual or beneficial owners of a company, trust, or account, and may be used to conceal the source, destination, or purpose of the funds or assets. Nominees may also be used to evade taxes, sanctions, or regulatory requirements.

In this case, the compliance officer is unable to verify the identity of the beneficial owners of the company, and only information on the nominee owners was provided. This raises the suspicion that the company may be involved in money laundering or terrorist financing activities, and that the nominee owners may be acting as fronts or intermediaries for the actual or beneficial owners. The compliance officer should conduct further due diligence on the company, the nominee owners, and the beneficial owners, and report any suspicious or unusual activity to the relevant authorities.