Study Guide. for the. Fourth Edition. Examination. Certification

Transcription

1 Study Guide for the Certification Examination Fourth Edition ACAMS.org ACAMS.org/español

2 Study Guide for the Certification Examination Fourth Edition

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4 Study Guide for the Certification Examination Fourth Edition a publication of the

5 Study Guide for the Certification Examination Fourth Edition Executive Director Gregory Calpakis, CAMS Editor Saskia Rietbroek, CAMS Contributors Mary Bhawnani John Byrne, CAMS Garry Clement, CAMS Michael R. McDonald, CAMS Christopher Myers, CAMS Eugene M. Propper John Pyrik, CAMS Nancy Saur, CAMS Jeffrey Sklar, CAMS Production Assistants Gabrielle Hartmann,CAMS Rebecca Lentz-Fernandes,CAMS Association of Certified Anti-Money Laundering Specialists (ACAMS) Brickell Bayview Center 80 Southwest 8th Street Suite 2350 Miami, FL United States ACAMS.org ACAMS.org/espanol Tel: Fax: Fax: ACAMS.org Copyright 2007 by the Association of Certified Anti-Money Laundering Specialists (ACAMS). Miami, USA. All rights reserved. No part of this publication may be reproduced or distributed, and may not be made available in any electronic format, without the prior written permission of ACAMS. ISBN:

6 Table of Contents Table of Contents Chapter 1: Introduction... 1 About the Association of Certified Anti-Money Laundering Specialists...1. The Mission of the Association of Certified Anti-Money Laundering Specialists...2. Objectives...3. Membership...4 CAMS-A Unique Certification...5. Why CAMS...5. Purpose of Certification...6. CAMS Certification Provides Career Benefits...6. How Is The CAMS Examination Developed?...7. Who May Take The CAMS Certification Examination?...8. Content of the CAMS Examination...9. The CAMS Candidate Handbook and the Process for Applying for the Certification Examination CAMS Recertification...11 Study Guide for the Certification Examination Organization of The Guide Purpose Audience Conclusion...13 v

7 Study Guide for the CAMS Certification Examination Chapter 2: Risks and Methods of Money Laundering and Terrorist Financing What is Money Laundering?...15 Three Stages in the Money Laundering Cycle...17 The Economic and Social Consequences of Money Laundering...20 Methods of Money Laundering Banks and Other Depository Institutions...28 q.electronic Transfers of Funds...29 q.correspondent Banking...30 q.payable-through Accounts...34 q.concentration Accounts...35 q.private Banking...37 q.smurfing/structuring...40 q.bank Complicity...46 q.credit Unions or Building Societies Non-Bank Financial Institutions...49 q.credit Card Industry...49 q.money Remitters and Money Exchange Houses...50 q.insurance Companies...53 q.securities Broker-Dealers Non-Financial Businesses and Professions...62 q.casinos and Other Businesses Associated with Gambling...62 q.dealers in High-Value Items (Precious Metals, Jewelry, Art, etc.) q.travel Agencies...70 q.vehicle Sellers...71 q.gatekeepers: Notaries, Accountants, Auditors, Lawyers...73 vi

8 Table of Contents q.investment and Commodity Advisors...76 q.trust and Company Service Providers...79 q.real Estate Industry...81 q.manipulation of Prices in Import and Export Transactions...84 q.black Market Peso Exchange...86 Money Laundering Risks Associated with New Technologies Online or Internet Banking Internet Casinos Prepaid Cards and E-Cash...95 Money Laundering Risks of Structures Designed to Hide Beneficial Ownership Shell Companies Trusts Bearer Bonds and Securities Terrorist Financing Differences and Similarities Between Terrorist Financing and Money Laundering Detecting Terrorist Financing Hawala and Other Informal Value Transfer Systems Charities or Non-Profit Organizations Summary Review Questions Chapter 3: Compliance Standards for Anti-Money Laundering and Combating the Financing of Terrorism vii

9 Study Guide for the CAMS Certification Examination Financial Action Task Force Members and Observers Objectives Financial Action Task Force 40 Recommendations FATF Guidance on Dismantling Terrorist Financing and Special Recommendations Non-Cooperative Countries The Basel Committee on Banking Supervision European Union Directives on Money Laundering Regional and Other International Initiatives Regional FATF-Style Bodies q.asia/pacific Group on Money Laundering q.caribbean Financial Action Task Force q.south American Financial Action Task Force (GAFISUD) q.middle East and North Africa Financial Action Task Force q.eurasian Group on Combating Money Laundering and Terrorist Financing q.eastern and South African Anti-Money Laundering Group Other Anti-Money Laundering Initiatives q.organization of American States Inter-American Drug Abuse Control Commission (CICAD) q.egmont Group of Financial Intelligence Units q.wolfsberg Group q.world Bank and International Monetary Fund Other International Organizations Key U.S. Legislative and Regulatory Initiatives Applied to Transactions Internationally USA Patriot Act The Reach of the U.S. Criminal Money Laundering and Civil Forfeiture Laws viii

10 Table of Contents. Office of Foreign Assets Control Summary Review Questions Chapter 4: Anti-Money Laundering Compliance Program Introduction Assessing Risk and Developing a Risk Scoring Model Introduction q.factors to Determine Risk What Risks Do Your Customers Pose? q.geographical Location q.type of Business q.legal and Transaction Structures What Risks Do Your Products or Services Pose? q.high- Risk Products, Services and Countries The Elements of an AML Program Internal Policies, Procedures and Controls Compliance Officer Training q.whom to Train q.what to Train In q.how to Train q.when to Train q.where to Train ix

11 Study Guide for the CAMS Certification Examination. Audit Compliance Culture and Senior Management s Role Know Your Customer Main Elements of a KYC Program Account Opening, Customer Identification and Verification q.name Checking Lists q.consolidated KYC Know Your Employee Suspicious or Unusual Activity Monitoring and Reporting Red Flags or Indicators of Money Laundering Suspicious Customer Behavior Suspicious Customer Identification Circumstances Suspicious Cash Transactions Suspicious Non-Cash Deposits Suspicious Wire Transfer Transactions Suspicious Safe Deposit Box Activity Suspicious Activity in Credit Transactions Suspicious Commercial Account Activity Suspicious Trade Financing Transactions Suspicious Investment Activity Suspicious Employee Activity Suspicious Activity in a Money Remitter/Currency Exchange House Setting Suspicious Activity in an Insurance Company Setting Suspicious Activity in a Broker-Dealer Setting x

12 Table of Contents. Suspicious Activity Indicators of Black Market Peso Exchange Money Laundering Method Electronic Anti-Money Laundering Solutions Summary Review Questions Chapter 5: Conducting or Supporting the Investigation Process Introduction When to Conduct an Internal Investigation Type of Investigation Choice of Counsel for the Investigation Media Relations Control of Documents and Computer Files Notices to Employees Plan In Advance Investigative Inquiries Search Warrants Orders to Restrain or Freeze Accounts or Assets Summonses and Subpoenas If Asked to Hand Over Documents Which Ones Do You Provide? Criminal Liability for the Institution Conducting the Investigation Interviewing Employees q.preparing for Employee Interviews xi

13 Study Guide for the CAMS Certification Examination q.attorney-client Privilege, Applied to Entities and Individuals q.conducting the Interviews Documents q.the Importance of Gathering and Producing Documents q.finding and Reviewing the Documents q.organization of Documents Report of the Investigation q.dissemination of a Written Report q.oral Report q.protecting the Company from Suits Arising from the Report q.protecting Investigative Materials from Disclosure Dealing with the Prosecutor Prosecution Government Investigations Exploiting the Internet for Money Laundering Investigations Too Much Money Unknown Business Weird Wires The Final Word AML Cooperation Between Countries IMoLIN Mutual Legal Assistance Treaties Financial Intelligence Units/Financial Investigative Units (FIUs) The Supervisory Channel FATF Recommendations on Cooperation Between Countries Summary xii

14 Table of Contents Review Questions Chapter 6: Practice Questions for Certification Examination Chapter 7: Glossary of Anti-Money Laundering Terms Chapter 8: Study and Test-Taking Tips and Techniques How Do You Learn? Learning How to Learn Avoiding the Traps of Studying Good Study Habits Taking the Examination Top 10 Tips for Succeeding in Multiple-Choice Tests Coping with Test Anxiety Chapter 9: Guidance Documents and Reference Materials Guidance Documents and Reference Materials Other Websites with Helpful AML Material AML-Related Periodicals xiii

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