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ACAMS CAMS (Certified Anti-Money Laundering Specialists) Certification Exam is a globally recognized certification exam that is designed to test the knowledge and skills of professionals in the field of anti-money laundering (AML). CAMS exam is intended for professionals who work in financial institutions, regulatory bodies, law enforcement agencies, and other organizations that deal with financial crime prevention. The CAMS certification is awarded by the Association of Certified Anti-Money Laundering Specialists (ACAMS), which is a professional organization dedicated to the advancement of the AML profession.
NEW QUESTION # 222
In many jurisdictions, financial institutions are prohibited from hiring a person who has been convicted of what type of offense?
- A. Kidnapping
- B. Protests of government action
- C. Driving while under the influence
- D. Offenses involving dishonesty
Answer: D
NEW QUESTION # 223
When implementing a risk-based approach related to casinos, which risks are related to the customer as an individual? (Choose two.)
- A. Improper use of third parties as customers
- B. Use of casino deposit accounts by the customer
- C. Customer from a high-risk country
- D. Transfer between customers
- E. Casual customers
Answer: C,E
Explanation:
When implementing a risk-based approach related to casinos, the risks related to the customer as an individual are mainly based on the customer's profile, behaviour, source of funds, and geographic location. Among the options given, B and D are the most relevant factors that could indicate a higher risk of money laundering or terrorist financing.
Casual customers are those who do not have a regular or established relationship with the casino, and who may visit the casino only once or occasionally. They may not provide sufficient or reliable identification information, or may use false or stolen identities. They may also engage in suspicious transactions, such as large cash purchases of chips, minimal or no gaming activity, or frequent transfers of chips between customers. Casual customers pose a higher risk of money laundering or terrorist financing because they are harder to verify, monitor, and trace by the casino operators.
Customer from a high-risk country is a customer who resides in, or has links to, a country that is subject to sanctions, embargoes, or similar measures, or that is identified by credible sources as having significant levels of corruption, or as being a source, transit, or destination of illicit funds. Such customers pose a higher risk of money laundering or terrorist financing because they may be involved in, or connected to, criminal or terrorist activities, or may be using funds that are derived from or intended for such activities.
NEW QUESTION # 224
When implementing a risk-based approach related to casinos, which risks are related to the customer as an individual? (Choose two.)
- A. Improper use of third parties as customers
- B. Use of casino deposit accounts by the customer
- C. Customer from a high-risk country
- D. Transfer between customers
- E. Casual customers
Answer: C,E
Explanation:
When implementing a risk-based approach related to casinos, the risks related to the customer as an individual are mainly based on the customer's profile, behaviour, source of funds, and geographic location. Among the options given, B and D are the most relevant factors that could indicate a higher risk of money laundering or terrorist financing.
Casual customers are those who do not have a regular or established relationship with the casino, and who may visit the casino only once or occasionally. They may not provide sufficient or reliable identification information, or may use false or stolen identities. They may also engage in suspicious transactions, such as large cash purchases of chips, minimal or no gaming activity, or frequent transfers of chips between customers. Casual customers pose a higher risk of money laundering or terrorist financing because they are harder to verify, monitor, and trace by the casino operators.
Customer from a high-risk country is a customer who resides in, or has links to, a country that is subject to sanctions, embargoes, or similar measures, or that is identified by credible sources as having significant levels of corruption, or as being a source, transit, or destination of illicit funds. Such customers pose a higher risk of money laundering or terrorist financing because they may be involved in, or connected to, criminal or terrorist activities, or may be using funds that are derived from or intended for such activities.
References: = The main reference for this question is the document titled "FATF Guidance on the Risk-Based Approach for Casinos" published by the FATF in October 2008. You can access it by clicking here. You can also find more information about the risk-based approach and the customer risks for casinos on the Gambling Commission website and the Exam Answer website.
NEW QUESTION # 225
Upon filing a suspicious transaction report, which of the following elements should be the highest anti-money laundering priority in making the decision to keep the account open?
- A. Financial impact on the institution if the account is closed.
- B. Additional Administrative costs of monitoring the account.
- C. Total number of accounts the institution closed in the last month.
- D. Procedures to ascertain the potential risk to the organization.
Answer: D
Explanation:
According to the CAMS Certification Package - 6th Edition1, the decision to keep or close an account after filing a suspicious transaction report (STR) should be based on a risk-based approach that considers the nature and severity of the suspicious activity, the customer profile and relationship, the regulatory and legal obligations, and the reputational and operational risks for the institution. The financial impact, the administrativecosts, and the number of accounts closed are not the primary factors in determining the appropriate course of action. Therefore, the correct answer is B. Procedures to ascertain the potential risk to the organization.
CAMS Certification Package - 6th Edition1, Chapter 5: Risk Management, Section: Account Closure, pp. 211-
212.
NEW QUESTION # 226
Which statements regarding the USA PATRIOT ACT best describe key aspects that have extraterritorial reach? (Choose three.)
- A. It allows federal banking supervisors to require records of the identity of the owners of a foreign bank from a Fl operating in the US.
- B. It allows foreign banks to voluntarily designate a registered agent in the US to accept service of subpoenas.
- C. It excludes as foreign FIs businesses that would be considered broker-dealers, money transmitters, and currency exchangers.
- D. It allows for the US Attorney General to subpoena records from a foreign bank with US correspondent accounts, including those that are located outside the US.
- E. It obliges the government to trace the origin of the funds when a seizure of assets occurs in a correspondent account that has been opened and maintained for a foreign bank in the US.
- F. It allows the Secretary of the Treasury to order a US financial institution (FI) to close a correspondent account when a subpoena has not been responded by a foreign bank in a timely manner.
Answer: B,D,F
Explanation:
The USA PATRIOT Act is a comprehensive legislation that was enacted in response to the terrorist attacks of September 11, 2001, and aimed to strengthen the US government's ability to prevent, detect, and prosecute money laundering and terrorist financing. Among its many provisions, the USA PATRIOT Act contains several sections that have extraterritorial reach, meaning that they apply to foreign entities or activities that have a nexus with the US. Three of these sections are:
* Section 319(b), which allows for the US Attorney General or the Secretary of the Treasury to issue a subpoena or other legal order to any foreign bank that maintains a correspondent account in the US, requiring the production of records relating to such account or any account at the foreign bank, including records maintained outside the US12. This section also allows foreign banks to voluntarily designate a registered agent in the US to accept service of such subpoenas or orders12.
* Section 313, which prohibits US financial institutions from establishing, maintaining, administering, or managing correspondent accounts for foreign shell banks, which are banks that have no physical
* presence in any country and are not affiliated with a regulated financial group34. This section also requires US financial institutions to take reasonable steps to ensure that their correspondent accounts with foreign banks are not being used to provide banking services indirectly to foreign shell banks34.
* Section 311, which authorizes the Secretary of the Treasury to designate foreign jurisdictions, financial institutions, classes of transactions, or types of accounts as being of "primary money laundering concern" and to impose special measures to address such concerns . These special measures may include requiring US financial institutions to obtain and retain information on the beneficial owners of foreign accounts, prohibiting or imposing conditions on the opening or maintaining of correspondent or payable-through accounts for foreign financial institutions, or requiring US financial institutions to identify the customers of their foreign correspondent account holders . The Secretary of the Treasury may also order a US financial institution to terminate a correspondent account within 10 days if the foreign bank fails to comply with a subpoena or other request for information under Section 319(b) .
References:
* 1: USA PATRIOT Act, Section 319(b)
* 2: ACAMS, CAMS Certification Package - 6th Edition, Chapter 4, page 121
* 3: USA PATRIOT Act, Section 313
* 4: ACAMS, CAMS Certification Package - 6th Edition, Chapter 4, page 120
* : USA PATRIOT Act, Section 311
* : ACAMS, CAMS Certification Package - 6th Edition, Chapter 4, page 119 Reference:
https://www.jonesday.com/-/media/files/publications/2007/10/extraterritorial-application-of-the-usa-patriot-ac/fi
https://www.lawfareblog.com/long-arm-us-law-patriot-act-anti-money-laundering-act-2020-and-foreign-banks
NEW QUESTION # 227
the Financing of Terrorism (CFT)]
The Office of Foreign Assets Control requirements have an extraterritorial reach because compliance is required by:
- A. US persons in the US.
- B. intermediaries of a transaction with a US nexus.
- C. foreign financial intelligence units.
- D. entities registered in the US.
Answer: B
Explanation:
The Office of Foreign Assets Control (OFAC) is the U.S. Treasury Department's agency that administers and enforces economic sanctions programs against countries, groups, and individuals that pose a threat to the national security, foreign policy, or economy of the U.S. OFAC's requirements have an extraterritorial reach because they apply not only to U.S. persons (citizens, permanent residents, entities, and those physically present in the U.S.), but also to any person or entity that engages in a transaction that has a connection to the
U.S., such as using the U.S. financial system, U.S. goods, or U.S. persons. This means that intermediaries of a transaction with a U.S. nexus, such as foreign banks, brokers, or agents, are required to comply with OFAC's regulations and may face penalties for violating them. OFAC's jurisdiction does not depend on the registration or incorporation of an entity in the U.S., nor does it extend to foreign financial intelligence units, unless they are involved in a transaction with a U.S. nexus.
References:
The Aggressive Extraterritorial Reach of U.S. Economic Sanctions: Foreign Company Exposure to OFAC Enforcement OFAC Consolidated Frequently Asked Questions The global reach of OFAC sanctions Which three circumstances are U.S. banks required to block transactions?
NEW QUESTION # 228
A large cash deposit most likely reflects money laundering when it is
1. from a customer who has never conducted a transaction in cash before.
2. transacted in segments smaller than the reporting thresholds at various times during the day.
3. followed by an immediate wire transfer to an offshore secrecy haven.
4. by a customer who operates a cash-based business.
- A. 1, 3, and 4 only
- B. 2, 3, and 4 only
- C. 1, 2, and 3 only
- D. l, 2, and 4 only
Answer: C
Explanation:
A large cash deposit is a red flag for money laundering when it is inconsistent with the customer's profile, behavior, or business activity. A customer who has never conducted a transaction in cash before may be trying to avoid detection or conceal the source of the funds. A customer who transacts in segments smaller than the reporting thresholds at various times during the day may be engaging in structuring or smurfing, which are techniques to evade currency transaction reporting requirements. A customer who follows a large cash deposit with an immediate wire transfer to an offshore secrecy haven may be attempting to layer or move the funds to a jurisdiction with weak anti-money laundering controls or high confidentiality. These scenarios indicate a high risk of money laundering and warrant further investigation and reporting.
A customer who operates a cash-based business may have a legitimate reason to make a large cash deposit, depending on the nature and scale of the business. However, this does not mean that the customer is exempt from scrutiny or monitoring, as cash-based businesses are also vulnerable to money laundering abuse. The bank should verify the source and purpose of the funds, and compare the deposit with the customer's expected activity and turnover.
References:
CAMS Certification Package - 6th Edition, Chapter 4: Conducting and Supporting the Investigation Process, pp. 97-98.
Warning signs of money laundering | The Law Society, Section: Cash deposits and withdrawals.
NEW QUESTION # 229
A foreign bank maintains a correspondent account in the US. According to an investigation carried out by US authorities, the specific correspondent account seems to have facilitated a transaction involving tainted funds.
Which allows the US authorities to seize the funds of the foreign bank held with the US bank?
- A. The FinCEN CDD Final Rule
- B. Regulations of the OFAC, US Department of Treasury
- C. The USA PATRIOT Act
- D. The 6th EU AML Directive
Answer: C
NEW QUESTION # 230
A division anti-money laundering officer for a financial institution has been conducting a monthly self-assessment.
The officer reviews the accounts opened for compliance with a long standing Know Your Customer policy.
The self-assessment for the latest month shows a significant increase in compliance deficiencies for the first time in more than a year.
Which of the following is the next course of action for the anti-money laundering officer to take?
- A. Revise the policy to simplify Know Your Customer compliance before the report is issued.
- B. Determine if there is a readily identifiable cause for the deficiencies.
- C. Inform the Board promptly of the Know Your Customer policy trend over the last 6 months.
- D. Implement a revision to the account-opening training program.
Answer: B
Explanation:
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.
References:
CAMS Study Guide - 6th Edition, Chapter 6, pages 171-172
CAMS Certification Exam Outline, Domain 3, Task 3.1, Skill 3.1.2
Anti-Money Laundering & Know Your Customer eBook, Chapter 5, pages 63-64 Summary of the Global Anti-Money Laundering Know Your Customer Policy, page 3
NEW QUESTION # 231
According to the Financial Action Task Force (FATF) report on terrorism financing, charities and nonprofit organizations are often vulnerable to terrorist financing because they: (Select Two.)
- A. Collect donations from various sources, and their primary objective is philanthropy and social well- being.
- B. Have a global presence that provides a framework for national and international operations and financial transactions that are often in or near areas most exposed to terrorist activity.
- C. Enjoy the public trust and have access to considerable sources of funds, and their activities are often cash-intensive.
- D. Are usually legitimate establishments and will not use the funds collected through donations for the profit of individuals or entities.
Answer: B,C
Explanation:
Nonprofit organizations (NPOs) and charities are at risk of being exploited for terrorist financing due to their access to large sums of money and their operational reach into high-risk areas. FATF'sRecommendation 8 specifically recognizes that terrorist organizations may misuse NPOs to raise and move funds, provide logistical support, or conceal the diversion of funds for illicit purposes.
* Option A (Correct):Many charities operate internationally, especially in areas with humanitarian crises. These regions often overlap with locations where terrorist organizations are active, making them vulnerable to abuse.
* Option D (Correct):Charities handle large volumes of cash and enjoy public trust, which makes it easier for illicit actors to integrate illicit funds without raising immediate suspicion.
* Option B (Incorrect):While charities are generally legitimate, the concern is that they can be exploited, not that they necessarily intend to misuse funds.
* Option C (Incorrect):Although collecting donations is a legitimate practice, it does not directly contribute to their vulnerability to terrorist financing.
Reference:FATF Recommendation 8 (R8) on Nonprofit Organizations; FATF Reports on Terrorist Financing Risks in NPOs (2014, 2019).
NEW QUESTION # 232
Which of the following strategies is most effective for a global organization to manage risks related to anti-money laundering (AML) and sanctions compliance?
- A. Ensuring group policies and procedures prioritize adherence to US regulations because they are the most influential worldwide.
- B. Ensuring sanctions compliance by relying solely on international bodies like the UN because there is no requirement to adhere to local laws.
- C. Ensuring group policies cater to compliance with each country's specific AML and sanctions regulations.
- D. Applying global AFC and sanctions policies to ensure consistency without the need to adapt to local regulations.
Answer: C
Explanation:
A global organization must ensure its group policies accommodate compliance with each country's specific AML and sanctions regulations to effectively manage risks across multiple jurisdictions.
NEW QUESTION # 233
A customer has held an account at a local credit institution for 10 years. The account has received deposits twice weekly for the same amount and has never shown signs of suspect behavior. Monitoring software indicated that in the past few months the account has received several large deposits that were not in line with the account history.
When asked, the customer states she recently sold a piece of property, which is supported with a proof of sale.
Which of the following should the compliance officer do next?
- A. File a suspicious transaction report with the competent authorities.
- B. Contact the local Financial Intelligence Unit for advice.
- C. Investigate these unusual transactions further.
- D. Document reasons for not filing a suspicious transaction report.
Answer: D
Explanation:
Explanation
The decision of whether or not to file a suspicious transaction report (also known as a suspicious activity report or SAR in the United States) often involves weighing the aggravating and mitigating factors arising from the research conducted during the investigative process. The final decision should be documented and supported by the reasoning that was used to make the determination. The transaction has already been investigated which led to the requesting of the document. The document checked out and the question did not specify the document was suspicious, therefore we can conclude an STR does not need to be completed and thus should move to document the reason why an STR wasn't completed.
NEW QUESTION # 234
A law enforcement agency is reviewing a suspicious transaction report (STR) filed by a financial institution for suspicious activity on a client's account. Subsequently, the agency requests further information.
Which supporting documentation might the law enforcement agency request from the institution to facilitate its investigation?
- A. A copy of the institution's STR policy and procedures
- B. Previously filed STRs on the same customer
- C. Account opening documents and account statements
- D. Copies of promotional materials sent to the customer
Answer: C
Explanation:
A law enforcement agency may request account opening documents and account statements from the institution to facilitate its investigation of a suspicious transaction report (STR). These documents can provide valuable information about the identity, background, source of funds, and transaction patterns of the customer, as well as any red flags or anomalies that may indicate money laundering or other criminal activities. Account opening documents may include identification documents, verification documents, customer due diligence forms, risk assessment forms, etc. Account statements may include transaction details, balances, fees, charges, etc.
:
ACAMS, CAMS Examination Study Guide, 6th Edition, Chapter 4, pp. 115-116 FATF Guidance: The Role of Hawala and Other Similar Service Providers in Money Laundering and Terrorist Financing, October 20131, p. 20 Basel Committee on Banking Supervision, Sound management of risks related to money laundering and financing of terrorism, June 20172, p. 11
NEW QUESTION # 235
A customer has held an account at a bank and has lived locally for over 25 years. Historically he has come into the bank monthly to deposit a $1,500 retirement check from the company where he worked. He is well known at the bank and often brings the staff cookies. Over the past four months, he has come into the bank every Monday, Wednesday, and Thursday to make $3,000 cash deposits into his account. A review of his account shows that an $8,500 check made out to cash clears his account each week. The bank has decided to file a suspicious transaction report (STR).
What is the important fact to include in the STR?
- A. The fact that the account holder is well known to the bank staff
- B. The customer's work history and the amount of his monthly retirement check
- C. The recent change in the timing of deposits and withdrawals in the account
- D. The fact that the customer has lived in the area and has banked at this bank for 25 years
Answer: C
Explanation:
The important fact to include in the STR is the recent change in the timing of deposits and withdrawals in the account, as this indicates a possible change in the customer's source and use of funds, and may suggest money laundering or other illicit activity. The customer's work history, the amount of his monthly retirement check, the fact that he is well known to the bank staff, and the fact that he has lived in the area and banked at this bank for 25 years are not relevant for the STR, as they do not explain the unusual pattern of transactions in his account.
:
CAMS Certification Package - 6th Edition | ACAMS, Chapter 4: Conducting and Supporting the Investigation Process, page 131 CAMS Certifications: How to Get CAMS Certified | ACAMS, CAMS Examination Preparation, page 8 ACAMS CAMS Certification Video Training Course - Exam-Labs, Video 4.2: Suspicious Transaction Reporting Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition), Question 97
NEW QUESTION # 236
Which three should real estate agents include in the criteria to assess their company's potential money laundering and terrorist financing risks when implementing a reasonable risk-based approach?
- A. Geographic Risk
- B. Transaction Risk
- C. Customer Risk
- D. Credit Risk
Answer: A,B,C
Explanation:
Reference:http://www.fatfgafi.org/media/fatf/documents/reports/RBA%20Guidance%20for%20Real%20Estate%20Agents.p df(page 20, second paragraph)
NEW QUESTION # 237
Which action indicates possible Penza scheme activity?
- A. A licensed seller offers higher profit on investments in a high risk country
- B. A licensed investment advisor lures aging/retired professionals to invest in securities
- C. An unlicensed investment advisor offers profits other investments cannot guarantee
- D. A unlicensed investment advisor offers returns that are competitive with industry benchmarks
Answer: C
NEW QUESTION # 238
A client is a wholesale auto business that operates as a used car lot. The client regularly ships vehicles internationally. In a four-month period, the client received wires totaling $1,250,000 from a dealer in Benin in West Africa. All wires originated from Benin and were in increments of $50,000.
Account debits made to the account were payable to various transport companies. All incoming checks reference various vehicles purchased. Dock shipping receipts produced by the client to support account activity identify the vehicles but cannot easily be tied to the wires received.
What is the suspicious behavior?
- A. Wires received are in large, even dollar amounts
- B. Account debits are payable to transport companies
- C. Vehicles are regularly shipped internationally
- D. The dock shipping receipts match the vehicles
Answer: A
NEW QUESTION # 239
A compliance officer at a large financial institution has been tasked by senior management to lead a team in an internal review and potential revision of the institution's customer onboarding program following a regulatory enforcement action of another institution.
Which step should the compliance officer perform first?
- A. Reviewing the institution's risk assessment
- B. Resolving substantive discrepancies in customer verification
- C. Revising training materials for frontline staff
- D. Conducting enhanced due diligence on high risk customers
Answer: A
Explanation:
The compliance officer should perform the first step of reviewing the institution's risk assessment before implementing any changes to the customer onboarding program. The risk assessment is a key component of the AML compliance program, as it identifies and measures the institution's exposure to money laundering and terrorist financingrisks. The risk assessment should be updated regularly and reflect the institution's products, services, customers, geographic locations, and delivery channels. By reviewing the risk assessment, the compliance officer can determine the adequacy and effectiveness of the current customer onboarding program and identify any gaps or weaknesses that need to be addressed. The compliance officer can also benchmark the institution's risk assessment against the regulatory expectations and best practices in the industry.
The other steps are also important, but they should be performed after the risk assessment review. Revising training materials for frontline staff, conducting enhanced due diligence on high risk customers, and resolving substantive discrepancies in customer verification are all part of the customer onboarding program, but they depend on the risk assessment to provide the appropriate level of controls and procedures. For example, the training materials should reflect the risk assessment results and the revised customer onboarding policies. The enhanced due diligence should be applied to customers who pose a higher risk according to the risk assessment criteria. The customer verification should be consistent with the risk assessment and the customer identification program.
AML KYC Onboarding Lifecycle Process Flow | Guide - AdvisoryHQ
New EBA AML Guidelines on the use of Remote Customer Onboarding Solutions - Bird & Bird KYC Onboarding Process 2023 - AML requirements - Sumsub Review of any AML/CFT program begins with the Risk Based Approached. It should first check the internal system to identify risk factors and design program accordingly.
NEW QUESTION # 240
What are the European Union Directives on Money Laundering?
- A. They are written by the Wolfsberg Group
- B. They require members to implement certain laws of prevent money laundering
- C. They require financial institutions to report suspicious activity to the Egmont Group in Brussels
- D. They are voluntary codes of best practice for the financial sector
Answer: B
Explanation:
"The first European Union Directive, "Prevention of the Use of the Financial System for the Purpose of Money Laundering (Directive 91/308/EEC)," was adopted by the Council of the European Communities in June 1991. Like all directives adopted by the Council, it required member states to achieve (by amending national law, if necessary) the specified results. This First Directive required the members to enact legislation to prevent their domestic financial systems from being used for money laundering"
NEW QUESTION # 241
A compliance officer is looking to modify procedures covering correspondent banking relationships. Which three would be recommended under the Wolfsburg Principles on Correspondent Banking? Choose 3 answers
- A. Periodic risk-based reviews of cents
- B. Risk-based rating of central banks and regional development banks
- C. Assessing the regulatory status and history of the client
- D. Prohibition on offering products or services to shell banks
Answer: A,C,D
NEW QUESTION # 242
A client has retained a lawyer to create a financial holding company. The lawyer resides in Europe. The client provides all requested documentation to the lawyer. However, the lawyer becomes suspicious that the customer is engaged in criminal activity and intends to use the financial holding company for money laundering purposes. Which of the following should an anti-money laundering specialist recommend according to the European Union Money Laundering Directives?
- A. There is no need to file a suspicious transaction report, as this activity is covered by attorney-client privilege.
- B. Consult with the competent authority to receive advice on how to handle the transaction.
- C. Freeze the client's assets so that all records can be turned over to the competent authorities.
- D. Report the activity as suspicious to the competent authority because the lawyer is covered by these directives.
Answer: D
NEW QUESTION # 243
......
The CAMS exam covers a wide range of topics related to AML, including risk assessment, customer due diligence, transaction monitoring, and reporting. CAMS exam is divided into six sections, each of which focuses on a different area of AML. The sections include: (1) Risk Assessment; (2) Customer Due Diligence; (3) Customer Risk Profiling; (4) Transactions and Monitoring; (5) AML Compliance Programs; and (6) Conducting and Responding to Investigations. CAMS exam is computer-based and consists of 120 multiple-choice questions, which must be completed within a four-hour time limit.
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