ACAMS STUDY GUIDE
Explain: "Principles of Information Exchange Between Financial Intelligence Units
(FIUs)" - Answers - Best practices on information exchange between FIU members of
the Egmont Group. Generally, they span:
1. FIUs scope of competency to cover all definitions of predicate offences and after the
exchange of free information
2. Reduction of intermediaries
3. Informal and expedient information exchange
4. FIU memoranda of understanding independent approval
5. Reciprocity and spontaneous exchange
What are Financial Intelligence Units (FIUs)? What is the informal international
association of FIUs? - Answers - National agencies which analyse and disseminate
financial intelligence to local law enforcement and foreign FIUs to combat ML/CFT.
They receive reports of suspicious transactions from financial institutions.
The Egmont Group
Generally, what do law enforcement agencies require when applying for search
warrants of financial institutions? - Answers - Probablecause that evidence will be
located in the premises.
Define: Wash Trading - Answers - The offsetting of gains and losses in different trading
accounts that do not appear to be commonly controlled in order to launder money
(layering).
According to the Wolfsberg Group Principles on Private Banking, what factors lead to
enhanced due diligence? - Answers - 1. Politically Exposed Persons
2. High-risk jurisdictions (not simply foreign)
3. High-risk sectors and business activities
What legal entity has extraterritorial reach of its regulations? - Answers - Office of
Foreign Assets Control enforcing US Treasury Department's trade sanctions based on
US foreign policy and national security goals
Which business categories have FATF's 40 Recommendations post-2003 expanded to?
- Answers - Real estate, precious metal dealers, lawyers, accountants and trust service
providers.
With respect to force of law, what makes EU fundamentally different than other
international organizations? - Answers - Eu can adopt and enforce regulations which
have force of law even without approval of member states superseding those of local
ones in the case of directives.
, Upon which is the Third Directive of the EU on AML based? - Answers - FATF's revised
40 Recommendations (2005)
Define: Mutual Legal Assistance Treaties (MLAT). - Answers - Legal bases to transmit
evidence for judicial and prosecution proceedings from foreign jurisdictions
Define: Numbered accounts. Per Basel's 2001 paper on Customer Due Diligence, are
they allowed in banking? - Answers - Banking accounts which are intended to conceal
the owner's identity through code.
Yes, they are allowed provided that they are subject to KYC and CDD procedures even
if the customer's identity is known for a select group of staff.
Per Basel's 2001 paper on CDD, are there exceptions to Private Banking accounts on
KYC processes? - Answers - None: No exceptions allowed
Define: Wolfsberg Group. Does it have enforcement powers? - Answers - An
association of 13 global banks which communed at Wolfsberg castle to develop
financial industry standards and policies on AML and KYC to manage money laundering
risks. It does not have enforcement powers.
What are sample vulnerabilities securities broker-dealers have on money laundering? -
Answers - 1. Speed of transactions
2. Ease of conversion of securities to cash even at loss of principal
3. Competitive and commission-based environment
4. International nature
5. Routine practice of wire transfers across jurisdictions
How does a regulatory body obtain international assistance in a money laundering
inquiry? - Answers - By submitting an overseas request from an the corresponding
regulatory body
For at least how long should banks retain CDD and suspicious activity investigations
for? - Answers - 5 years
Per Wolfsberg Principles on Correspondent Banking, what are the recommendations for
financial institutions on their dealings with shell banks? - Answers - Do not have
business arrangements with shell banks and confirm that the correspondent bank (non-
shell bank) also does not have any dealings with shell banks.
I.e. No Shell Banks Allowed
What is the difference between gateways on MLAT and FIUs (under Egmont
Principles)? - Answers - MLAT gateways are typically used to gather overseas
Explain: "Principles of Information Exchange Between Financial Intelligence Units
(FIUs)" - Answers - Best practices on information exchange between FIU members of
the Egmont Group. Generally, they span:
1. FIUs scope of competency to cover all definitions of predicate offences and after the
exchange of free information
2. Reduction of intermediaries
3. Informal and expedient information exchange
4. FIU memoranda of understanding independent approval
5. Reciprocity and spontaneous exchange
What are Financial Intelligence Units (FIUs)? What is the informal international
association of FIUs? - Answers - National agencies which analyse and disseminate
financial intelligence to local law enforcement and foreign FIUs to combat ML/CFT.
They receive reports of suspicious transactions from financial institutions.
The Egmont Group
Generally, what do law enforcement agencies require when applying for search
warrants of financial institutions? - Answers - Probablecause that evidence will be
located in the premises.
Define: Wash Trading - Answers - The offsetting of gains and losses in different trading
accounts that do not appear to be commonly controlled in order to launder money
(layering).
According to the Wolfsberg Group Principles on Private Banking, what factors lead to
enhanced due diligence? - Answers - 1. Politically Exposed Persons
2. High-risk jurisdictions (not simply foreign)
3. High-risk sectors and business activities
What legal entity has extraterritorial reach of its regulations? - Answers - Office of
Foreign Assets Control enforcing US Treasury Department's trade sanctions based on
US foreign policy and national security goals
Which business categories have FATF's 40 Recommendations post-2003 expanded to?
- Answers - Real estate, precious metal dealers, lawyers, accountants and trust service
providers.
With respect to force of law, what makes EU fundamentally different than other
international organizations? - Answers - Eu can adopt and enforce regulations which
have force of law even without approval of member states superseding those of local
ones in the case of directives.
, Upon which is the Third Directive of the EU on AML based? - Answers - FATF's revised
40 Recommendations (2005)
Define: Mutual Legal Assistance Treaties (MLAT). - Answers - Legal bases to transmit
evidence for judicial and prosecution proceedings from foreign jurisdictions
Define: Numbered accounts. Per Basel's 2001 paper on Customer Due Diligence, are
they allowed in banking? - Answers - Banking accounts which are intended to conceal
the owner's identity through code.
Yes, they are allowed provided that they are subject to KYC and CDD procedures even
if the customer's identity is known for a select group of staff.
Per Basel's 2001 paper on CDD, are there exceptions to Private Banking accounts on
KYC processes? - Answers - None: No exceptions allowed
Define: Wolfsberg Group. Does it have enforcement powers? - Answers - An
association of 13 global banks which communed at Wolfsberg castle to develop
financial industry standards and policies on AML and KYC to manage money laundering
risks. It does not have enforcement powers.
What are sample vulnerabilities securities broker-dealers have on money laundering? -
Answers - 1. Speed of transactions
2. Ease of conversion of securities to cash even at loss of principal
3. Competitive and commission-based environment
4. International nature
5. Routine practice of wire transfers across jurisdictions
How does a regulatory body obtain international assistance in a money laundering
inquiry? - Answers - By submitting an overseas request from an the corresponding
regulatory body
For at least how long should banks retain CDD and suspicious activity investigations
for? - Answers - 5 years
Per Wolfsberg Principles on Correspondent Banking, what are the recommendations for
financial institutions on their dealings with shell banks? - Answers - Do not have
business arrangements with shell banks and confirm that the correspondent bank (non-
shell bank) also does not have any dealings with shell banks.
I.e. No Shell Banks Allowed
What is the difference between gateways on MLAT and FIUs (under Egmont
Principles)? - Answers - MLAT gateways are typically used to gather overseas
