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CAMS · Question #529

CAMS Question #529: Real Exam Question with Answer & Explanation

The correct answer is D. "Yes, also if the customer's account is used in a country other than the U.S. by suspected money. The bank's current anti-money laundering program is inadequate because it does not include a process for monitoring customer account activity, which is a key component of detecting and reporting suspicious transactions. The fact that the consultant and the bank have mutual client

Question

A non-U.S. bank asks its U.S. correspondent whether there is risk of having funds seized in their correspondent account if a customer is involved in a predicate offense.The correspondent bank's reply should be,

Options

  • A"No, only U.S. accounts for U.S. citizens can be seized and forfeited by the competent authority."
  • B"No, only correspondent accounts of U.S. banks can be seized and forfeited by govern-ment
  • C"Yes, if it is suspected that money laundering has occurred solely in the U.S."
  • D"Yes, also if the customer's account is used in a country other than the U.S. by suspected money

Explanation

The bank's current anti-money laundering program is inadequate because it does not include a process for monitoring customer account activity, which is a key component of detecting and reporting suspicious transactions. The fact that the consultant and the bank have mutual clients does not affect the risk rating of those customers, nor does it justify a lower level of scrutiny. The bank should revise its procedures to ensure that it has a comprehensive and risk-based approach to customer due diligence, transaction monitoring, and reporting.

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