ACAMS CAMS Certified Anti-Money Laundering Specialist (CAMS7 the 7th edition) Exam Practice Test

has a general understanding of virtual assets.

consistently reviews transactions between fiat and virtual currencies.

implements enhanced KYC measures.

owns virtual currencies itself.

Conduct AML audits no less often than every 12 months for consistency in annual reporting.

Remain independent from expressing opinions on the sufficiency of remediation or action plans to address findings and recommendations.

Be involved in the day-to-day operations of the AML program to immediately prevent control failures.

Report to the audit committee of the board of directors to maintain independence.

The board of directors should be responsible for overseeing the management of the bank's compliance risk but not involved in establishing a compliance policy that explains the processes by which compliance risks are to be identified and managed throughout the organization.

The board of directors should establish a compliance function and approve the bank's policies for identifying, assessing, monitoring, reporting, and advising on compliance risk.

The compliance function must have sufficient authority, stature, independence, and resources to be effective on its own and should not have access to the board of directors.

The compliance function should report directly to the CEO concerning the bank's compliance with applicable laws, rules, and standards and only update the board of directors on the bank's efforts in managing compliance risk when required.

ML undermines the integrity and stability of financial systems and makes them vulnerable to illegal activity. This can erode investor confidence and hinder economic growth.

When a financial institution (FI) is found to be promoting ML or violating AFC regulations, this can lead to a loss of confidence in the institution and a loss of customers. Interestingly, this scenario might sidestep any legal consequences for the Fl.

When laundered funds flow into legitimate economies, they can be used for illegal purposes, such as funding terrorist activities or organized crime. This distorts resource allocation and undermines development.

Jurisdictions perceived as having insufficient ML measures might be identified as uncooperative or high-risk, potentially facing restricted access to international markets, though economic sanctions by other countries are an unlikely outcome.

integrates seamlessly with existing systems and processes.

meets budget and cost requirements.

automates all regulatory reporting requirements.

replaces manual compliance training for employees.

Money services business (MSB)

Multinational corporations

Individual foreign customers

Non-profit organizations with international operations

Investment advisor

Relationship manager

Operations manager

Compliance officer

Only commit to action plans that require no new investment to maximize shareholder value

Draft action plans in consultation with the jurisdiction's FIU to remain aligned with other similar companies

Only commit to action plans that can be implemented and closed within the three-month management reporting cycle

Draft action plans to address the root cause of the deficiencies, regardless of how long they will take to fully implement

A customer receives funds from a popular decentralized mixer

A customer uses funds from their monthly income to purchase virtual currency

A customer makes a transaction on the blockchain that their traditional financial institution is unaware of

A customer receives multiple wires from different sources and uses those funds to purchase virtual currency

ensure that all adverse media sources are comprehensively analyzed without the need for human review.

significantly reduce human errors arising from repetitive tasks by delivering consistent and highly accurate analysis.

instantly identify intent behind media articles, allowing for more effective risk scoring.

automate the process of identifying new information and distinguishing it from previously encountered data.

cover multiple languages and scripts, surpassing the limitations of human linguistics.

evidence that the increased residual risk arising from the change is within the bank's risk appetite.

approval by money-laundering reporting officer for the proposal.

how many resources are spent on the less productive lower threshold and the associated costs.

the number of cases that will not be filed and the resources that can be freed up for other tasks.

minutes of meeting held with the regulator where agreement was obtained that the higher threshold was justified.

historical analysis proving that the current scenario generates a disproportionate number of false positives.

Information security, data privacy, and cybersecurity

Foreign exchange control, and precious gemstone and metal dealing

Ombudsman and anti-competition authority

Electronic contract and biological signature acceptance

Consumer protection, financial inclusion, and environmental, social and governance

Reduction in the number of false positives in long term

Complete automation of compliance processes

Elimination of the need for human oversight

Increased flexibility in adapting to changing financial crime risks

Enhanced ability to detect emerging patterns and anomalies

Collect donations from various sources, and their primary objective is philanthropy and social wellbeing

Are usually legitimate establishments and will not use the funds collected through donation for the profit of individuals or entities

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

Enjoy the public trust and have access to considerable sources of funds, and their activities are often cash intensive

The Financial Action Task Force (FATF)

The AUSTRAC Fintel Alliance

The Egmont Group

The Wolfsberg Group

Keep an account open upon verbal request

Produce documents and testimony without a subpoena

Seize privileged documents upon written request

Freeze an account in terms of a court order

It produces outputs that include a range of intermediate possibilities between "Yes" and "No"

It is an advanced analytics tool widely used to implement AFC controls

It allows for a greater number of exact matches, reducing the need for manual review

It is a new technique for enhancing the quality of alerts for review

Address control of payments in EU countries to reduce money laundering.

Build a network of financial institutions that work together to prevent money laundering across the EU.

Establish a consistent regulatory environment across the EU to prevent money laundering.

Allow member states to discuss the draft legislation with the cooperation of the EU financial intelligence units.

A customer changes multiple high-denomination notes to low-denomination notes.

A customer conducts cash transactions using multiple branches of the MSB on the same day.

A customer has a family link to the destination of a money transfer

A customer sends and receives money transfers in equal amounts at or about the same time.

A customer only wants to deal with a particular employee in the MSB.

cross-border purchases.

purchases in the name of a natural person.

paying true market price for a property.

non-financed purchases.

Information provided by a prospective customer

Photocopy of a copy of a government-issued identity document

Information obtained from an open-source database

Information obtained directly from a government-managed registry

Appointing individuals to serve in official capacities of the company

Annual maintenance services

Provision of a local business address

Company incorporation services

create a common database of key information and share analysis of suspicious activities with FATF

exchange strategic information between FlUs and obliged entities

exchange strategic information between financial institutions

exchange operational information between public authorities and obliged entities

Drafting detailed action plans for the audit team to execute to close the findings

Reperforming the testing for the controls mentioned in the findings to confirm the results of the audit

Defining remedial actions based on the findings' root cause analysis

Assigning responsibility for reviewing the action plan to the board of directors

Allowing clients lo transact anonymity-enhanced tokens

Onboardlng of clients who are residents abroad. Including those with politically exposed person (PEP) status

Enabling transfer of tokens from one blockchain to another

Offering services to VASPs established in jurisdictions that are not FATF compliant

Operating a network of crypto ATMs charging high fees

Lack of adequate IP address tracking capabilities

Consumer protection laws may intersect will) AML/CFT requirements when handling customer complaints or disputes, potentially affecting how FIs implement their compliance programs.

AML/CFT laws are the primary focus for FIs, and other regulations like data privacy and consumer protection may only indirectly influence their compliance obligations

Environmental, social, and governance (ESG) frameworks can influence a Fl's risk management strategies but are generally considered separate from core AML/CFT compliance requirements

Data privacy laws can restrict the sharing of customer information, while financial inclusion initiatives require FIs to avoid excessive de-risking that could exclude vulnerable populations.

Ensuring sanctions coy on international bodies like the UN because there is no requirement to adhere to local laws.

Ensuring group policies and procedures prioritize adherence to US regulations because they are the most influential worldwide.

Applying global AFC and sanctions policies to ensure consistency without the need to adapt to local regulations.

Ensuring group policies cater to compliance with each country's specific AML and sanctions regulations.

allows Financial Intelligence Units (FlUs) to enact sanctions against perpetrators of financial crime

promotes financial transparency and protects the integrity of the financial systems

needs to be approved by the Financial Intelligence Unit (FIU) before sharing between financial institutions

helps financial institutions to be more effective in fighting crime with data analysis

Using gaming accounts to transfer illicit funds between players undetected

Structuring transactions to avoid reporting thresholds by keeping them under certain limits

Providing false personal information to evade regulatory oversight

Ensuring identity verification is completed prior to the onboarding of new customers

Investing all gaming winnings into high-risk stocks to conceal funds

Receiving electronic transfers for US$10,000 amounts from other financial institutions

Using cash to buy multiple cashier's checks over a period of time

Performing operations with real estate investment companies

Using cashier's checks in the transactions with the real estate investment company's account

Percentage of regulatory reports for high-risk customers not completed within the required regulatory deadlines

Percentage change of transaction monitoring alerts escalated for investigation compared to the previous quarter

Percentage of customers for whom onboarding verification was not completed within KYC policy service-level agreement (SLA) requirements

Number and percentage of senior politically exposed persons (PEPs) who were onboarded in the past quarter compared to all active customers

FATF Evaluation Committee

Series of internal audits followed by reporting to FATF

Basel Committee

Mutual evaluation

Conduct an open-source intelligence investigation using artificial intelligence tools to gain more information on the activities of the suspected employee

Use the FI's whistleblowing channel to report the suspected employee

Question their co-worker to determine if their suspicions are correct before reporting to the FI's Human Resources department

Warn colleagues and customers of the FI that the employee's suspicious financial investment proposals could be a scam

Report the suspected employee to the line manager of the FI to take the required action

Determining detailed risk profiles for customers based on their activities and relationships

Focusing monitoring primarily on previously flagged customers while using standard controls for others

Choosing and applying effective controls that align with the identified risk levels

Performing a comprehensive risk assessment to identify customer, transaction, and geographic risks

Allocating resources equally across all customer segments to ensure fairness

Reporting entities are prohibited from disclosing to clients or third parties that a suspicious activity report (SAR) has been filed or that an investigation is ongoing

Reporting entities can share general information about suspicious activities internally within the organization without compromising confidentiality

Reporting entities must inform their clients if a suspicious activity report (SAR) has been filed, as part of maintaining transparency in customer relations

Reporting entities are allowed to discuss suspicious activities with clients if it helps clarify a situation before submitting a suspicious activity report

Setting tone from the top

Mandatory participation in all regulatory inspections

Mandatory attendance and review of all financial crime trainings

Setting clear criteria for escalations to senior management

A customer being hesitant to provide beneficiary name or address information when sending international wire transfers

Cash-intensive businesses, such as convenience stores or restaurants, making large cash deposits

A customer exchanging foreign currency from a higher-risk jurisdiction for domestic currency under the reporting threshold

A customer using multiple accounts under different names to conduct transactions

A customer completing frequent small-dollar international money transfers to their native country

Criminal history searches

Personal resume

Internet and public media searches

Past employment records

Personal references from close associates

Section 314(a)

Section 314(b)

Section 319(b)

Section 319(a)

Fully rely on central beneficial owner registry records in the high-risk third country to determine the ultimate beneficial owners of all customers

Apply tailored due diligence measures, based on the level of risk posed by each customer following risk assessment

Monitor every cross-border transaction in real time, flagging all for enhanced scrutiny due to the country risk level

Automatically apply enhanced customer due diligence measures to all customers in the high-risk third-country branch regardless of risk level

Periodic and ad hoc cooperation with the legal team to appropriately investigate and monitor the transactions of subjects of subpoenas or government inquiries

Periodic review of client profiles to ensure that the most up-to-date information is on file for high-risk clients in line with the bank's internal policies and procedures

Periodic review of suspicious activity reports (SARs) filed with FinCEN to determine whether any should be withdrawn

Periodic review of the transaction monitoring scenarios and their productivity to ensure that appropriate AML typologies are reflected

the operational burden of dealing with potential matches.

the value of fines for non-compliance.

the experience of the team dealing with potential matches.

whether the data to be screened is reliable and verified.

Permanent US resident aliens regardless of location

Merchants that offer US-origin goods for sale regardless of location

Non-US financial institutions that offer accounts in USD regardless of location

US citizens regardless of location

US incorporated entities and their foreign branches

evaluate and monitor compliance with the FATF standards and provide recommendations for improvement.

assist countries in implementing EU, UN, and regional sanctions regimes.

develop and promote international standards to prevent money laundering and terrorist financing.

conduct investigations on countries legislations and laws to prevent them from being used for money laundering and terrorist financing.

ensure that countries follow its laws to maintain financial stability.

Advising private financial institutions on how to enhance their profitability through AML efforts

Establishing and enforcing legal frameworks to detect, prevent, and punish money laundering and related financial crimes

Providing funding to private and non-governmental organizations (NGOs) for the development of advanced compliance technologies

Acting as intermediaries between private sector firms and non-governmental organizations (NGOs) to streamline AML compliance programs

Public organizations can belter understand what the private sector experiences and inform policy and the enactment of laws

Data-protection privacy policies provide an opportunity to develop information sharing protocols to prevent unauthorized access to information

Data-protection privacy policies prohibit the evolution of PPPs due to restrictions based on legacy government legislation

Small business owners can choose third-party providers or financial institutions to keep their private data safe which can easily be shared within a PPP

Surrendering a policy early to liquidate funds

Focusing excessively on the investment performance of an insurance product

Using a credit card to purchase an insurance policy

Using cryptocurrencies or other non-fiat currencies to fund an insurance policy

generative copilots.

small language models.

privacy coins.

crypto-mixers.

Accounting

Model risk management

Technology solutions and IT security

Marketing

Fraud risk management

certain contractors may receive preferential treatment, allowing them opportunities to inflate margins during the tender process

unsuccessful bidders are informed of decisions and provided detailed justifications for awarding the contracts

procurement and contracting processes involve the management of the tender process, which may lack sufficient oversight

bids are solicited and disseminated to a wide audience through advertising and other channels.

A check returning a mortgage overpayment made in error

A payment made to a mixer platform

A regular standing order to a high-interest savings account

A bill payment made to a friend after splitting a dinner bill

data privacy.

enhanced due diligence (EDD) policies.

the Travel Rule.

data quality.

complexity.

regulatory.

Inform local LEA and regulator of the request for awareness

Close the client's accounts immediately to avoid any undue risk

Review the client's activity, determine if suspicious activity exists, and report accordingly

Advise the LEA that the government needs to be contacted for extradition

Comply immediately with the foreign jurisdiction and turn over all client information

difficulty in tracking the originator, recipient, and source of transactions.

remote verification of identity by third-party program managers.

heavy usage by senior political figures.

informal networks used for cross-border transactions outside of the formal banking system.

heightened risks of returned transactions.

wire transfers in different currencies between accounts held at different banks for the same client.

an incoming third-party wire transfer followed by the purchase of real estate in the client's name.

an incoming wire transfer followed by the loan payment to a third party that is a business associate of the client.

multiple wire transfers sent to counterparties associated with the client as per KYC documentation.

Securely share sensitive information in the fight against money laundering and the financing of terrorism

Establish an environment to foster trust amongst countries

Sign memoranda of cooperation that recognize and allow room for case-by-case solutions to specific problems

Improve global cooperation between FIUs

Propose legislation to combat financial crime, including money laundering and the financing of terrorism

waste management sector companies based in high-risk jurisdictions with payments or trade invoices tor types of waste aligned with those they are authorized to process.

frequent payments from companies in the logging. milling, or waste trade sectors to individuals or beneficiaries unrelated to the legal parson activity or business.

unexplained wealth and cash transfers involving senior officials or politically exposed persons for their family members) with a position of responsibility related to the management or preservation of natural resources.

small cash transfers from cash-Intensive businesses to beneficiaries in areas known as a source of gold mining, illegal logging, and Illegal land clearing.

identification of the customer's occupation.

identification and verification of the customer's identity.

identification of the customer's work address.

identification of the beneficial owner.

verification of the customer's credit history.

[verification of the customer's income sources.

Perform a control and ownership assessment of the businesses involved, using the information available in the client files

Contact local law enforcement and request that they assist in the analysis and investigation

Review the information presented in the automated monitoring system's alert description and decline any future transactions

Contact the account manager and ask for the reasons behind the patterns of activity highlighted in the AML alerts

Use social media platforms to connect with the businesses and request details about the account activity

Receiving securities into an existing brokerage account following the death of a spouse

Allowing fixed income securities to mature

Using brokerage accounts like deposit accounts

Engaging in transactions involving nominees or third parties

The residual risk would be significantly reduced due to the effectiveness of the controls in place

The residual risk would be moderately reduced, but further controls may be necessary to achieve an acceptable level

The residual risk would remain high due to the inherent nature of the private banking business

The residual risk would be eliminated entirely because the controls are sufficient to mitigate all potential risks

PPPs improve financial crime detection and prevention by sharing intelligence between banks and law enforcement.

PPPs help banks reduce compliance costs by automating information sharing.

PPPs allow banks to manage their own suspicious activity report (SAR) filing process without the need to involve the Financial Intelligence Unit (FIU).

PPPs maximize the efficiency of the bank's compliance program by providing real-time intelligence from law enforcement.

imposes economic sanctions on jurisdictions with lax AML controls to force them to strengthen their controls.

conducts on-site inspections of financial institutions in jurisdictions with lax AML controls to identify deficiencies and recommend improvements.

publishes annual reports ranking all member jurisdictions based on their self-assessment of AML controls.

conducts a peer review process whereby member countries assess the AML controls of other jurisdictions and provide recommendations for improvement.

increased reputation risk.

inclusion on the UN Consolidated List.

civil and criminal penalties

delisting of public filing status.

A court order requests the bank to disclose the SAR subject to obtaining agreement from the legal team

A customer asks about potential reporting to the local Financial Intelligence Unit (Fill)

An external consultant inquires about the details of the SAR

A third-country police directly inquires about the customer.

executing cross-border transactions for their own business which is not commensurate to the PEP's wealth.

in a position to provide more information regarding the PEP's whereabouts and hidden properties.

travelling to offshore jurisdictions often on holiday which exposes them to higher risks for AML.

used as intermediaries to facilitate bribery or corruption or to conceal the illicit wealth of the PEP.

Cash-intensive businesses risks

Unknown third-party risks

Geographic risks

Anonymous transactions risks

product risk.

credit risk.

geographic risk.

customer risk.

liquidity risk.

The residual risk would be eliminated entirely because the controls are sufficient to mitigate all potential risks

The residual risk would be significantly reduced due to the effectiveness of the controls in place

The residual risk would remain high due to the inherent nature of the private banking business

The residual risk would be moderately reduced, but further controls may be necessary to achieve an acceptable level

The Bank Secrecy Act (BSA) extraterritorial reach requires that the Travel Rule be applied to all financial institutions globally, including all USD transactions

The Anti-Money Laundering Act of 2020 (AML Act) extraterritorial reach covers all USD transactions throughout the global economy

The Office of Foreign Assets Control's (OFAC's) economic and trade sanctions may pose extraterritorial risks for financial institutions and businesses outside of the US

Section 319(b) of the USA PATRIOT Act extraterritorial reach permits the seizure of funds from a correspondent bank account in the US that have been opened and maintained for the foreign bank

helping to identify high-risk sectors that require enhanced due diligence (EDO),

eliminating the need for sectoral risk assessments within the organization

guiding the allocation of resources for mitigating financial crime risks

requiring all organizations to apply standardized measures

automatically reducing the organization's responsibility for conducting its own risk assessment

Paying premium several years in advance and terminating early for a refund

Natural persons having more than one insurance policy

High-premium life insurances that provide high payouts

Regularly switching policies and accepting penalties

Beneficiary payouts to elderly people

Gathering sufficient information to establish the source of funds and source of wealth

Assessing the level of money laundering risk posed by prospective and existing high-risk customers

Assessing and reviewing the minutes of the relevant committee responsible for onboarding customers

Ensuring an employee is responsible for liaison with the authorities on matters related to countering the finance of terrorism

Ensuring that resources in its compliance and AML areas kept pace with the bank's growth

Reputational risk

Operational risk

Sanctions risk

Compliance risk

Lending risk

Politically exposed persons (PEPs)

Capital flight risk

Anti-bribery and corruption risk

Tax evasion

The EU AMLD and local AML regulations are separate and unrelated legal frameworks.

The EU AMLD and local AML regulations must have identical requirements.

Local AML regulations may impose additional or more stringent requirements than the EU AMLD.

The EU AMLD take precedence over local AML regulations.

Local AML laws and regulations override the requirements of the EU AMLD.

The EU AMLD provide a framework that member countries must implement through local AML regulations.

The ratio of true positives to false positives generated by the automated monitoring system

The number of money laundering alerts generated by the watchlist screening system

The number of high-risk customers onboarded each month

The number of clients exited for commercial reasons

private banks agree that transparency of client beneficial ownership Is necessary and appropriate.

due diligence requirements tor private banking customers are necessary to prevent predicate offenses.

risk based approaches are insufficient to address the heightened risk presented through private banking

private banks need to better coordinate and align their global AML control environment strategies.

A customer wants to purchase gold bars with a combination of cash and cryptocurrency

A customer specifically requests to purchase a Kimberly Process-certified cut diamond

A customer pays an antique dealer with a credit card for a high-value antique item

A customer wants a hand-written receipt for a cash purchase of a high-end, limited-edition luxury watch

Inquiring about the source of wealth and source of funds

Asking to provide a list of immediate family members

Verifying the financial crime awareness of the client

Collecting necessary documents to verify the veracity of information

The foreign bank will not allow indirect use of the correspondent bank accounts by Politically Exposed Persons (PEPs)

The jurisdictions in which the foreign bank maintains a physical presence

The foreign bank's operations will be limited to the country of incorporation

The ownership details of the foreign bank

The foreign bank will not allow indirect use of the correspondent bank accounts by shell banks

Accountants can prepare ledgers and spreadsheets, draft annual returns and make payments to government offices

Accountants can advise on the structuring of companies as well as ensure compliance with local tax regulations

Accountants are knowledgeable about financial management, including what to record over the course of the accounting year

Accountants are able to create and structure companies, falsify accounts and manipulate financial statements

impose sanctions lo maintain of restore international peace and security

impose sanctions on countries that lack AML/CFT controls.

conduct research on and analyze the impacts of sanctions to improve the effectiveness of sanctions regimes.

impose sanctions on economic targets to maintain or restore financial stability within a country.

The first line

The second line

Senior management

The third line

Narrow the media sources to avoid unrelated articles

Rely on manual filtering by investigators

Increase the frequency of updates to media sources

Adjust AI/ML models to focus on high-risk keywords/phrases from reputable media sources

Implementation of a blacklist of correspondent customers with previously detected and investigated suspicious activity

Enhancement of a customer acceptance policy to more clearly identify high-risk customers

Increased frequency of training provided to front office employees

Enhancement of customer identification procedures to appropriately identify trust, nominee, and fiduciary accounts

The 40 Recommendations have not been updated to reflect the impact of new technology

Each jurisdiction can reach out to the FATF for private access to the interpretive notes to the 40 Recommendations

The 11 Immediate Outcomes are recommendations specific to high-risk jurisdictions requiring enhanced monitoring.

The cornerstone of the 40 Recommendations is the adoption of a risk-based approach by each jurisdiction

KYC analyst

Senior management

Relationship manager

Enhanced due diligence compliance officer

Account opening staff

Middle management

Senior management

First-level management

red notice

white list

yellow notice

grey list

using shell companies or trusts for privacy, lax planning, or asset protection.

in the names of unrelated thud patties.

using the proceeds from selling a prior property or liquidating investments to make an all-cash purchase

using legal entities and intermediaries to protect the privacy of the purchasers.

using loans backed by cash or certificates of deposit.

List-based

Secondary

Country-based

Sectoral

The buyer is using high-value real estate transactions to obscure the origin of the funds.

The buyer is quickly diversifying their investment portfolio through structuring payments in order to take advantage of the liquidity of cash transactions in real estate.

The buyer is capitalizing on favorable market conditions and using cash purchases to outbid competitors in a competitive real estate market using insider information.

The buyer is a real estate developer acquiring multiple properties for a potential redevelopment project with a business partner located in a high-risk jurisdiction.