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Certified Anti-Money Laundering Specialist (CAMS7 the 7th edition) Question and Answers

Certified Anti-Money Laundering Specialist (CAMS7 the 7th edition)

Last Update Nov 1, 2025
Total Questions : 313

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Questions 1

Which of the following are potential financial crime-related red flags when obtaining client data? (Choose three.)

Options:

A.  

A client frequently submits financial statements much earlier than required appearing overly eager

B.  

A client insists on using a personal bank account for business transactions despite being advised otherwise

C.  

A new client shows a preference for minimal direct interaction and relies primarily on indirect communication methods, citing convenience or time constraints

D.  

The client is a publicly listed company but very diversified

E.  

The ultimate beneficial ownership is unclear

Discussion 0
Questions 2

The owner of a real estate investment company deposits multiple cashier's checks that were bought using cash over a three-month period, from the sale of two apartments. This account also receives several electronic transfers from other financial institutions for US$10,000 each.

What activity is considered suspicious of money laundering?

Options:

A.  

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

B.  

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

C.  

Performing operations with real estate investment companies

D.  

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

Discussion 0
Questions 3

Which control would be most effective as part of a risk-based approach (RBA) to managing AML/CFT risk for a bank established in the EU that also has a branch in a high-risk third country outside of the EU?

Options:

A.  

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

B.  

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

C.  

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

D.  

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

Discussion 0
Questions 4

What key element contributes to the effectiveness of AML training programs'?

Options:

A.  

In-person training sessions

B.  

Comprehensive curriculum delivered by senior management

C.  

Comprehensive content with engaging delivery methods

D.  

Generalized content designed to apply to a broad audience

Discussion 0
Questions 5

The compliance officer at a casino in Taiwan discovers that the casino received multiple cash deposits from a customer just below the Large-Amount Transaction Report (LTR) limit on consecutive days. The customer used three different betting accounts.

What is the appropriate next step?

Options:

A.  

Make a note in the customer's account that the customer's gambling activities are frequently conducted below the reporting limit

B.  

Follow internal reporting procedures to escalate the activity as suspicious and report to appropriate authorities

C.  

Inform the customer their activity Is suspicious and request an explanation

D.  

Contact law enforcement to launch an Investigation into the customer's financial activities

Discussion 0
Questions 6

The supply of goods and services can be vulnerable to corruption within a company, particularly the solicitation and receipt of bribes and kickbacks, because: (Choose two.)

Options:

A.  

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

B.  

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

C.  

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

D.  

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

Discussion 0
Questions 7

What should a financial institution (FI) do in response to a formal law enforcement request to produce documents?

Options:

A.  

Keep senior management informed at all times to strategically organize a defense to terminate the law enforcement request

B.  

Verify the officer's identification and ask for the law enforcement request to be served when the Chief Executive Officer is available to sign for it

C.  

Ask for an extension to review the FI's privacy policy and confidentiality policy before providing any information under the law enforcement request

D.  

Designate a person responsible for the internal investigation in preparation of documents for the request

Discussion 0
Questions 8

Assessing the money laundering risk related to a product within the financial sector includes assessing the: (Select Two.)

Options:

A.  

governance arrangements

B.  

complexity of the products

C.  

results of the last audit

D.  

financial status of the business

Discussion 0
Questions 9

An adequate organizational policy is: (Choose two.)

Options:

A.  

up to date and reflects all relevant regulatory developments

B.  

signed off by the board of directors and regulators

C.  

approved by the clients and third parties

D.  

clearly communicated and understood by staff

Discussion 0
Questions 10

At a high level, the risk assessment process involves identifying and rating the inherent risks associated with customers, products, countries, and delivery channels, and then:

Options:

A.  

comparing these risks with industry benchmarks to determine the residual risk.

B.  

implementing new controls to eliminate all risks

C.  

rating the effectiveness of the related controls in order to calculate the residual risk.

D.  

documenting the historical risk incidents for future reference.

Discussion 0
Questions 11

The goal of the Egmont Group of Financial Intelligence Units (FIUs) is to provide a forum for FIUs to: (Select Three.)

Options:

A.  

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

B.  

Establish an environment to foster trust amongst countries

C.  

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

D.  

Improve global cooperation between FIUs

E.  

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

Discussion 0
Questions 12

A financial institution's (FI's) policy is to apply enhanced due diligence (EDD) for every new client to ensure the effectiveness of the program.

How should a consultant advise the FI's management team?

Options:

A.  

Suggest the FI needs to implement a risk-based approach for EDD.

B.  

Suggest the management team select the clients that are chosen for EDD.

C.  

Suggest the management team ask the regulator for advice on EDD measures.

D.  

Suggest EDD for 50% of the clients is appropriate.

Discussion 0
Questions 13

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.)

Options:

A.  

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

B.  

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

C.  

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

D.  

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

Discussion 0
Questions 14

Which techniques are most commonly used in a rules-based approach to transaction monitoring for detecting suspicious activities? (Choose two.)

Options:

A.  

Using predefined rules to flag specific transaction patterns

B.  

Randomly flagging transactions for further investigation

C.  

Statistical tuning of monitoring scenarios to improve accuracy

D.  

Using advanced machine learning models to detect outliers

E.  

Setting transaction thresholds for automated alerts

Discussion 0
Questions 15

Reference data screening includes the screening of which types of datasets? (Select Two.)

Options:

A.  

Types of payment messages

B.  

Customers

C.  

Third-party service providers

D.  

Customer spouses

Discussion 0
Questions 16

Which of the following AML/CFT arrangements should a bank have in place at minimum before opening for business? (Choose three.)

Options:

A.  

Independent compliance testing

B.  

Qualified and knowledgeable staff

C.  

Third-party screening software

D.  

An automated monitoring system

E.  

Written policy and procedures

Discussion 0
Questions 17

How should risk-related issues be addressed to ensure the effectiveness of the three lines of defense model?

Options:

A.  

Ensure that the second line reviews, monitors, and escalates risk-related issues as needed to senior management while maintaining independent oversight from the third line

B.  

Have senior management handle risk-related issues directly when possible because they are ultimately responsible for the organisation's overall risk management strategy

C.  

Delegate some risk-related issues to the first line to avoid overwhelming the second line and to ensure operational efficiency

D.  

Assign risk-related oversight duties to the third line to provide an independent review and address issues more effectively by avoiding conflicts of interest in the first and second lines

Discussion 0
Questions 18

Which suspicious activity may be the strongest indicator of money laundering through a casino?

Options:

A.  

A privately held company originates funds transfers through the casino into the betting accounts of multiple patrons

B.  

A patron requests the casino to transfer their winnings to another gambling operator

C.  

A patron purchases a large amount of chips at a blackjack table using cash

D.  

A patron routinely places multiple bets on the same sporting events

Discussion 0
Questions 19

Using artificial intelligence (Al) and machine learning-based techniques tn adverse media screening can: (Choose three.)

Options:

A.  

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

B.  

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

C.  

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

D.  

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

E.  

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

Discussion 0
Questions 20

Which of the following are key financial crime risks associated with real estate companies? (Choose four.)

Options:

A.  

Buying property allows for the movement of large amounts of funds in a single transaction

B.  

Criminal networks could purchase real estate for use as supply houses or locations to grow, manufacture, or distribute illicit narcotics

C.  

Markets can be volatile, and buyers may not achieve a strong return on their investment

D.  

Beneficial ownership information might be opaque, and criminals may abuse arrangements like shell companies and trusts

E.  

Real estate transactions often involve financial institutions and other professional gatekeepers

F.  

The high value of properties may require multiple types of financing, which can make it more difficult to identify the source of funds

Discussion 0
Questions 21

In the context of terrorist financing, which of the following are potential indicators of the abuse of non-profit organizations (NPOs)? (Choose two.)

Options:

A.  

Involvement in community development and humanitarian aid projects

B.  

Large and unaccounted cash donations from anonymous sources

C.  

Operating in high-risk jurisdictions with limited oversight

D.  

Frequent changes in leadership and mission statements

E.  

Extensive transparency in financial reporting and governance practices

Discussion 0
Questions 22

According to PinCEN. when a financial institution (PI) identities a suspicious activity that necessitates suspicious activity report (SAR) filing, the SAR supporting documentation should (Select Two.)

Options:

A.  

include all documents or records that assisted the Fl in making the determination that the activity required a filing.

B.  

always be limited to account name, account details, and transaction records.

C.  

have written policies and procedures to maintain supporting documentation.

D.  

be saved in a single separate file with hard copies stored in a fireproof cabinet.

Discussion 0
Questions 23

A bank received a subpoena regarding one of its clients. The financial intelligence unit of the bank should review the subpoena and:

Options:

A.  

Close the client's account by informing the client of the subpoena.

B.  

Perform a transaction review and respond fully to the subpoena.

C.  

File a suspicious activity report (SAR), including the receipt of the subpoena in the SAR narrative.

D.  

Adjust the client's risk score and close the case.

Discussion 0
Questions 24

A large international bank is conducting a comprehensive review of its risk management framework to ensure it effectively addresses various financial crime risks, including AML, CFT,

sanctions, fraud, anti-bribery and corruption (ABC), and tax evasion.

The bank’s compliance team is responsible for evaluating the current risk assessment processes, identifying potential gaps, and recommending enhancements to better mitigate these risks. During this review, the team needs to consider the different types of risk assessments and how to integrate findings into the overall risk management strategy.

Which approach should the compliance team prioritize to enhance the bank’s ability to identify, assess, and mitigate the identified risks?

Options:

A.  

Use a static risk assessment model that remains unchanged until a significant regulatory update occurs to ensure consistency in the evaluation process over time

B.  

Delegate the risk assessment process to individual business units to conduct independently and allow for specialized assessments tailored to each unit's specific activities

C.  

Conduct a periodic enterprise-wide risk assessment that includes identifying inherent risks, evaluating the effectiveness of existing controls, and determining residual risks

D.  

Focus primarily on AML risk assessments, as these are typically the most scrutinized by regulators, while addressing other financial crime risks only when issues are identified

Discussion 0
Questions 25

How can public-private partnerships (PPPs) foster collaboration in the fight against financial crime? (Choose two.)

Options:

A.  

Developing a culture of compliance

B.  

Improving governance in the public sector by requesting feedback from financial institutions

C.  

Reducing transaction monitoring false positives for all financial institutions

D.  

Improving the quality and quantity of data available for analysis by sharing information

Discussion 0
Questions 26

Which services provided by an accounting firm could be considered as higher risk from a financial crime perspective? (Choose three.)

Options:

A.  

Forming a trust on behalf of a customer with a complex setup and acting as a nominee director

B.  

Auditing a firm that provides payroll software to large corporate customers

C.  

Preparing financial statements for a listed or a privately owned firm

D.  

Providing tax advice to an international customer hoping to move their assets out of their home country

E.  

Assisting an offshore corporation from a jurisdiction with no available beneficial owner information to buy property in the UK

Discussion 0
Questions 27

Which statements regarding using network analysis tools to determine links to criminality are true? (Choose three.)

Options:

A.  

When using network analysis data to fight money laundering and financial crime, data protection and privacy can be disregarded because fighting crime takes precedent

B.  

Network analysis tools are an efficient means of generating relevant results because they only need a limited amount of data and computation power and artificial intelligence (Al) allows less-skilled people to quickly learn to use these systems

C.  

When using artificial intelligence (Al) with network analysis tools, it must be ensured that the algorithms used are not biased towards social criteria, such as race, gender, or religion

D.  

Network analysis allows for the identification of individuals or entities in a network by analyzing connections or links between them and can be used to study a wide range of systems, such as social or transportation networks

E.  

Analyzing relationships between individuals in a social network allows for the identification of hierarchies, the detection of behaviors and geographical movements, or an understanding of how groups are organized

Discussion 0
Questions 28

The Office of Foreign Assets Control (OFAC) is responsible for:

Options:

A.  

Ensuring an effective export control and treaty compliance system

B.  

Administering and enforcing economic and trade sanctions

C.  

Designating jurisdictions as primary money laundering concerns

D.  

Managing trade agreements between the US and foreign countries

Discussion 0
Questions 29

Which of the following measures can help maintain the independence of BSA/AML compliance staff to ensure effective compliance controls?

Options:

A.  

Establishing BSA/AML compliance staff reporting to the management of the business line in the first line of defense

B.  

Ensuring BSA/AML compliance staff is primarily outsourced

C.  

Providing BSA/AML compliance staff a reporting line to compliance or other second line of defense internal control function

D.  

Providing BSA/AML compliance staff with a reporting line to the chief financial officer

Discussion 0
Questions 30

A law enforcement agency submits several requests to a financial institution.

Which request is legitimate and requires the bank to respond?

Options:

A.  

Keep an account open upon verbal request

B.  

Produce documents and testimony without a subpoena

C.  

Seize privileged documents upon written request

D.  

Freeze an account in terms of a court order

Discussion 0
Questions 31

A multinational corporation is considering expanding into a new market with a history of political instability and corruption.

Which strategy would be most effective in mitigating reputational risk from a financial crime perspective associated with such an expansion?

Options:

A.  

Ensure the jurisdiction risks and other relevant factors have been taken into consideration in the EWRA and the residual risks are within the corporation's risk appetite

B.  

Partnering with established local businesses to leverage their knowledge and connections while sharing risks

C.  

Ensuring the company has strong ties with local government officials to influence policy and avoid negative scrutiny

D.  

Committing to open communication, ethical practices, and community engagement to build trust with stakeholders

E.  

Minimizing the company's direct presence in the country to reduce exposure to potential risks

Discussion 0
Questions 32

Which of the following is a broader risk specific to casinos and gambling?

Options:

A.  

Low thresholds for transactions

B.  

Frequent use of cash

C.  

Cross-border transactions

D.  

Weak KYC policies and procedures

Discussion 0
Questions 33

Unusual wire transfer transactions can include: (Choose two.)

Options:

A.  

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

B.  

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

C.  

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

D.  

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

Discussion 0
Questions 34

Which ML/TF risks are associated with cryptoassets? (Select Three.)

Options:

A.  

Devaluation

B.  

Smart contract vulnerabilities

C.  

Potential for anonymity

D.  

Global reach

E.  

High transaction fees

F.  

Use to layer illicit funds

Discussion 0
Questions 35

Which techniques would be most efficient for a complex investigation of unusual patterns of activity involving multiple businesses, triggered by an automated monitoring system alert? (Select Two.)

Options:

A.  

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

B.  

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

C.  

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

D.  

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

E.  

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

Discussion 0
Questions 36

Which of the following are best practices to raise awareness and train staff regarding the risks related to financial crime? (Select Three.)

Options:

A.  

Tailor training and offer regular training to all employees

B.  

Train outside of daily operations and promote awareness of Compliance

C.  

Train core AML topics once per year, at a minimum, to relevant employees

D.  

Use a variety of training methods and provide necessary resources to employees

E.  

Communicate regularly and measure effectiveness of training

Discussion 0
Questions 37

Which of the following statements is true regarding the 2012 Financial Action Task Force (FATF) 40 Recommendations and'or 11 Immediate Outcomes?

Options:

A.  

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

B.  

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

C.  

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

D.  

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

Discussion 0
Questions 38

According to Basel Committee guidelines, which level of the organization should determine whether or not to enter business relationships with higher risk customers?

Options:

A.  

Account opening staff

B.  

Middle management

C.  

Senior management

D.  

First-level management

Discussion 0
Questions 39

When a multinational organization develops its anti-financial crime (AFC) program, what is the most important consideration for ensuring compliance across different jurisdictions?

Options:

A.  

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

B.  

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

C.  

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

D.  

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

Discussion 0
Questions 40

A law enforcement action alleged that on several trading days over the course of two months, defendants engaged in a series of copper gold, crude oil. and natural gas futures transactions on an electronic trading platform One defendant repeatedly bought future contracts at low prices from the other, and then immediately sold them back at higher prices. As a result, one defendant effectively pocketed the same amount as the other lost even though there were no changes in the open positions held by either defendant.

What is a name for this typology?

Options:

A.  

Short position

B.  

Reverse flip

C.  

Bid-ask spread

D.  

Wash trading

Discussion 0
Questions 41

An agent of a wealthy individual residing in Country A, which is on the EU list of high-risk third jurisdictions, approaches a notary in Country B, which is in the EU. The agent wants to complete a disposal of assets recently acquired at auction by the wealthy individual through an offshore company. The agent also has a power of attorney to act on behalf of the offshore company issued by a respectable law firm from Country C, which is also in the EU. The agent asks the notary to proceed with the disposal as quickly as possible without paying any specific attention to related costs or taxes to be paid as a result of this transaction. The notary notices the intended transfer price is significantly lower than the one recorded at auction, but the agent does not want to discuss this matter and claims that it is not covered by the power of attorney.

Which red flags should the notary consider? (Select Two)

Options:

A.  

The agent requested a disposal of assets at a lower price than recently acquired.

B.  

The assets acquired through an auction were put in the name of an offshore company

C.  

The agent acted on behalf of an individual residing in a country which is on the EU's list of high-risk jurisdictions

D.  

The power of attorney was issued by a law firm in a different EU country from where the transaction took place.

Discussion 0
Questions 42

Which of the following best describes the use of fuzzy logic in customer screening systems?

Options:

A.  

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

B.  

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

C.  

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

D.  

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

Discussion 0
Questions 43

A compliance analyst has recently investigated an account where money was deposited in amounts below the reporting limit and almost entirely withdrawn in a foreign country.

Which type of money laundering is the compliance analyst potentially identifying?

Options:

A.  

Trade-based

B.  

Check Kiting

C.  

Microstructuring

D.  

Structuring

Discussion 0
Questions 44

Interactions between the compliance department and other functions or departments within an organization contribute to making the anti-financial crime (AFC) compliance program more robust by addressing specific risk areas.

Which departments play a crucial role in enhancing the AFC compliance program of an organization? (Select Two.)

Options:

A.  

Information security office (ISO)

B.  

Marketing and sales

C.  

Human resources (HR)

D.  

Data privacy office (DPO)

Discussion 0
Questions 45

Arecruitment manager in the human resources departmentof a bank hasshortlisted a candidate for the position of relationship manager in its private banking division.

Thebank’s compliance policyrequiresproper background checksto protect againstfraud and money laundering risks.

Whichresourceswould bemost usefulfor identifying potential negative information regarding the shortlisted candidate? (Select Three.)

Options:

A.  

Past employment records.

B.  

Personal references from close associates.

C.  

Personal resume.

D.  

Internet and public media searches.

E.  

Criminal history searches.

Discussion 0
Questions 46

Which of the following are part of a risk-based approach? (Select Three.)

Options:

A.  

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

B.  

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

C.  

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

D.  

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

E.  

Allocating resources equally across all customer segments to ensure fairness

Discussion 0
Questions 47

Perpetual KYC includes: (Choose two.)

Options:

A.  

triggers identifying static data changes and data based on client's behaviors in real time.

B.  

periodic refreshing at one-, three- and five-year cycles.

C.  

ability to prioritize better based on client data rather than driven by schedules alone.

D.  

classification of clients into categories of risk.

Discussion 0
Questions 48

An employee at a financial institution (Fl) suspects that one of their co-workers is involved in a financial investment scam syndicate. Which step should be taken next by the employee who has the suspicion?

Options:

A.  

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

B.  

Use the Fl's whistle blowing channel to report the suspected employee

C.  

Warn colleagues and customers of the F1 that the employee's suspicious financial investment proposals could be a scam

D.  

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

E.  

Report the suspected employee to the line manager of the F1 to take the required action

Discussion 0
Questions 49

Which risks are specifically associated with the misuse of gaming accounts in financial crime? (Choose three.)

Options:

A.  

Using gaming accounts to transfer illicit funds between players undetected

B.  

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

C.  

Providing false personal information to evade regulatory oversight

D.  

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

E.  

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

Discussion 0
Questions 50

Which of the following processes or tools contribute to AML compliance despite being seemingly unrelated? (Choose two.)

Options:

A.  

Customer loyalty program tracking

B.  

Product usage analysis

C.  

Customer satisfaction surveys

D.  

Customer support ticket tracking

E.  

Credit risk assessment

Discussion 0
Questions 51

A US bank recently received a regulatory order to remediate its AML programs, which included several violations of law.

What degree of accountability is it possible for the bank's senior management and employees to face?

Options:

A.  

The bank's designated AML compliance officer is likely to face criminal prosecution because the bank received a regulatory order

B.  

The bank's designated AML compliance officer and senior management can face civil prosecution but not criminal prosecution for violation of AML laws

C.  

The bank's designated AML compliance officer and senior management may face personal liability if they failed to take actions while aware of AML violations at the bank

D.  

The bank's designated AML compliance officer is the only individual in the company's senior management team that can face personal liability for violation of AML laws

Discussion 0
Questions 52

The manager of a bank's KYC team discovers that a high-risk customer's activity was not reviewed last quarter as the bank's internal schedule required.

What should the KYC team manager do?

Options:

A.  

Submit a referral to file a suspicious activity report (SAR)

B.  

Evaluate the KYC review process to understand why the review did not occur as required and take corrective action as necessary

C.  

Contact the customer's relationship manager to suspend account access until the periodic KYC review is completed

D.  

Remove the customer from the bank's high-risk list

Discussion 0
Questions 53

Which of the following are important AML controls for a compliance manager of a regulated asset management company in the European Union to implement? (Select Two.)

Options:

A.  

Inviting prospective customers for an onboarding interview

B.  

Rejecting any politically exposed persons (PEPs) as customers

C.  

Understanding the source and origin of assets

D.  

Performing negative news checks of prospective customers

E.  

Producing financial stability reports on interesting customers

Discussion 0
Questions 54

A financial institution's US Branch receives a subpoena from law enforcement requesting detailed records of a customer's account activity. The customer is part of an ongoing investigation into a money laundering operation. At the same time, the institution has received a FinCEN 314(b) information-sharing request from another bank seeking details on transactions linked to the same customer. The compliance team is tasked with responding to both the subpoena and the FinCEN 314(b) request.

What should the compliance officer prioritize in responding to these requests while ensuring that all legal and regulatory obligations are met?

Options:

A.  

Notify the customer of the information-sharing request from the other financial institution and seek their consent before responding

B.  

Consult the institution's legal counsel to validate the subpoena, then respond directly to law enforcement while ensuring all documentation is properly recorded

C.  

Respond to the FinCEN 314(b) request first, as it allows for voluntary information sharing with partner organizations

D.  

Provide the requested records to both law enforcement and the other financial institution immediately to ensure full cooperation and transparency

Discussion 0
Questions 55

The new KYC lead at a bank is particularly focused on enhancing the risk management component of its KYC program and refers to the Basel Committee's customer due diligence (CDD) principles.

Which of the following describe key improvements to a KYC program established in the Basel Committee's CDD principles? (Select Two.)

Options:

A.  

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

B.  

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

C.  

Increased frequency of training provided to front office employees

D.  

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

Discussion 0
Questions 56

According to the Financial Action Task Force's (FATF's) "Guidance for a Risk-Based Approach Life Insurance Sector," which of the following are money laundering red flags relating to the involvement of a third party in a life insurance product? (Select Two.)

Options:

A.  

A customer engages an attorney to consult on the issuance of the policy.

B.  

A customer transfers the policy to another insurance company unaffiliated with the original policy issuer.

C.  

Payments are regularly received from third parties that have no apparent relationship with the policy holder.

D.  

A customer names an apparently unrelated third party as a beneficiary.

Discussion 0
Questions 57

A bank is completing a periodic KYC profile review for a customer that is a small digital marketing company based in New York City.

Which of the following would be a red flag?

Options:

A.  

The account activity includes deposit activity into both savings and checking accounts

B.  

The account activity includes incoming funds transfers at irregular intervals from small businesses located in New York

C.  

The account activity includes deposits made in multiple branches around New York City into the same account.

D.  

The account activity includes frequent purchases of tickets to industry conferences and other events.

Discussion 0
Questions 58

Common risks and red flags associated with trade finance clients may include: (Choose four.)

Options:

A.  

account activity that is not consistent with the purpose of the account

B.  

bills of lading matching the description of goods, quantities, and values with transshipment details justified

C.  

transaction structures that appear unnecessarily complex

D.  

trade documents, such as invoices and letters of credit, that are not clearly worded or are in foreign languages

E.  

invoices with prices that are much higher than market price

F.  

fluctuations in the pricing of standard goods and services

Discussion 0
Questions 59

Which is a key goal of the EU's Directives on money laundering?

Options:

A.  

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

B.  

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

C.  

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

D.  

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

Discussion 0
Questions 60

An EU Trust and Company Service Provider analyst notices some unusual activity while looking through a customer's financial statements and detailed general ledger. The customer is in the business of importing and exporting machineries.

Which transaction indicator warrants further escalation to the compliance officer?

Options:

A.  

The payment of company secretarial retainer fees to a foreign company in a tax-efficient jurisdiction

B.  

The payment of virtual offices services overseas

C.  

Inter-company loans from the holding company to the subsidiary company to finance the shipment of machinery

D.  

The payment of consultancy fees to unrelated companies and service providers established in a foreign jurisdiction

Discussion 0
Questions 61

A key advantage of privacy enhancing technologies (PETs) in anti-money laundering is that they offer:

Options:

A.  

simultaneous encryption and decryption for underlying data.

B.  

full access to underlying data with full and uninterrupted calculations made on the data.

C.  

secure processing of data while it remains encrypted.

D.  

transfer, decryption and storage of data by the data processor.

Discussion 0
Questions 62

Which changes at a financial institution (FI) should trigger an enterprise-wide reassessment of its inherent AML risk exposure? (Select Three.)

Options:

A.  

Introduction of new products or services

B.  

Mergers or acquisitions

C.  

Restructuring of the FI's risk and compliance functions

D.  

Use of new technologies for delivering existing products

E.  

Changes in the individuals overseeing the FI's product lines and sales strategies

Discussion 0
Questions 63

There are three types of factors that can be used to authenticate someone ownership, knowledge, and inherent factors.

Which of the following factors falls under inherent factors?

Options:

A.  

Challenge-response

B.  

Fingerprint

C.  

Security token

D.  

Passphrase

Discussion 0
Questions 64

A financial institution is designing an enterprise-wide risk assessment (EWRA).

According to the guidance issued by the Wolfsberg Group regarding a risk-based approach to identifying and managing money laundering risks, an effective approach should:

Options:

A.  

Focus on understanding the risks presented by new clients within the assessment period, and the controls to mitigate associated money laundering risks.

B.  

Include appropriate measures and controls to mitigate money laundering risks stemming from higher-risk customers, products, and geographies.

C.  

Focus on the inherent risk in the FI's product and service offerings and the controls to mitigate potential money laundering risks.

D.  

Use a framework provided by a third-party vendor and used by other FIs in the jurisdiction.

Discussion 0
Questions 65

Which of the following controls is typically implemented at customer onboarding to mitigate the risk of onboarding high-risk customers?

Options:

A.  

Enhanced due diligence (EDD)

B.  

Transaction monitoring

C.  

Customer risk assessment

D.  

Sanctions screening

Discussion 0
Questions 66

Which of the following laws or regulations can impact the application of AML/CFT programs and require financial institutions (r" Is) to balance multiple compliance requirements?

Options:

A.  

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

B.  

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

C.  

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

D.  

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.

Discussion 0
Questions 67

Which of the following are part of a risk-based approach? (Choose three.)

Options:

A.  

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

B.  

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

C.  

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

D.  

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

E.  

Allocating resources equally across all customer segments to ensure fairness

Discussion 0
Questions 68

When assessing and managing money laundering risks while operating in foreign jurisdictions different from that of the head office, an effective AML monitoring program should:

Options:

A.  

Be consistent with the head office audits

B.  

Be tailored to the higher of standards between the jurisdictions.

C.  

Conform to the foreign jurisdiction policies to align with the head office policies.

D.  

Provide all foreign jurisdiction reports to the head office for approval.

Discussion 0
Questions 69

The relationship manager in the corporate banking department at a bank is required to take specialized AML training tailored to the risks the department is most likely to encounter.

Which types of content are most appropriate for this training? (Select Two.)

Options:

A.  

Money laundering typologies applicable to monetary instrument reporting

B.  

Applicable AML laws and regulations

C.  

Regulatory exam best practices

D.  

Money laundering typologies applicable to corporate loans

Discussion 0
Questions 70

Which statement best describes a key money laundering risk associated with virtual asset service providers (VASPs), cryptoassets, and related products?

Options:

A.  

Cryptoassets can be transferred across borders quickly, but the volatility of their value still makes them less attractive for money laundering compared to traditional assets

B.  

Mandatory reporting requirements have been implemented for certain types of crypto transactions, but gaps in regulation and enforcement still leave room for money laundering activities.

C.  

The transparency of blockchain technology helps law enforcement trace transactions, but it can also provide criminals with ways to obscure their financial activities through complex layering techniques.

D.  

The pseudonymous nature of transactions allows criminals to hide their identities while transferring large sums of money globally, making it difficult to trace the ultimate beneficial owner.

Discussion 0
Questions 71

Country A's anti-corruption authority has been investigating the movement of potential proceeds of bribery and corruption to Country B and is now preparing to take the case to a local court.

Which method of obtaining the required evidence to prosecute the case would be most effective?

Options:

A.  

Make an official request directly from the head of Country A's anti-corruption authority to Country B's corresponding law enforcement authority

B.  

Make a request for the required evidence using Country A's mutual legal assistance treaty with Country B

C.  

Use the International Criminal Police Organization (INTERPOL) network to obtain the required evidence from Country B

D.  

Use the Egmont Secure Web to obtain the required evidence from Country B's financial intelligence unit

Discussion 0
Questions 72

Which of the following are considered best practices for effective AML/CFT training programs? (Select Three.)

Options:

A.  

Training should cover practical examples, use case studies, and provide information on how to comply with policies.

B.  

Up-to-date records including logs of training and completion dates should be maintained.

C.  

Training should be broad, high level, and not role-specific in order to reach the largest audience.

D.  

Training should cover the consequences of not complying with policies and procedures.

E.  

Training should always be provided by an independent third party.

Discussion 0
Questions 73

Which money laundering risks are posed by the misuse of trust and asset management services? (Select Three.)

Options:

A.  

Concealing sources of funds

B.  

Allowing for third-party custody safekeeping of funds

C.  

Adding a layer of anonymity to transactions

D.  

Concealing true legal and beneficial owners

E.  

Establishing escrow accounts for real estate transactions

Discussion 0
Questions 74

An institution is looking to alter an existing threshold-based monitoring scenario because it is generating too many alerts that do not yield suspicious activity reports.

Documentation submitted to the relevant committee for supporting this proposal should include details on: (Choose three.)

Options:

A.  

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

B.  

approval by money-laundering reporting officer for the proposal.

C.  

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

D.  

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

E.  

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

F.  

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

Discussion 0
Questions 75

Which of the following is a critical consideration for private sector firms when sharing data and intelligence to combat financial crime?

Options:

A.  

The preference of upper management regarding which teams should participate in the data-sharing initiative

B.  

The cost of the data-sharing system and whether it its within the existing IT budget

C.  

The potential return on investment (ROI) from the data shared versus the financial crime prevention effort

D.  

Ensuring that the shared data complies with applicable data protection regulations while maintaining the integrity and accuracy of the information

Discussion 0
Questions 76

The transaction monitoring system of a bank generated an alert for a car wash client. After making large cash deposits, the client orders international wire transfers.

Which additional circumstances would make the case more suspicious?

Options:

A.  

The beneficiary of the wire transfers is a foreign company whose shareholders and director are other companies

B.  

The wire transfers are for different amounts but with the same beneficiary

C.  

The beneficiary of the wire transfer is a resident of a grey-list country

D.  

The beneficiary of the wire transfers is a resident of a foreign country bearing the same family name as the business owner

Discussion 0
Questions 77

In a large US bank, an individual leads a team in charge of overseeing the governance and effectiveness of the bank's transaction monitoring approach.

Which strategies should the team implement? (Select Two.)

Options:

A.  

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

B.  

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

C.  

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

D.  

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

Discussion 0
Questions 78

Which benefits are most commonly associated with transitioning from a rules-based approach to artificial intelligence (AI) and machine learning-based tools in transaction monitoring? (Choose three.)

Options:

A.  

Reduction in the number of false positives in long term

B.  

Complete automation of compliance processes

C.  

Elimination of the need for human oversight

D.  

Increased flexibility in adapting to changing financial crime risks

E.  

Enhanced ability to detect emerging patterns and anomalies

Discussion 0
Questions 79

A key factor in the independence of an AML audit is that the auditor should.

Options:

A.  

have never worked in previous assignments within the AMUCFT departments.

B.  

have no involvement with the organization's AML/CP T compliance staff.

C.  

have been screened by the board of directors before the audit starts

D.  

be sufficiently trained in AML to be able to provide an independent review.

Discussion 0
Questions 80

Common risks associated with cryptocurrency and convertible virtual currencies include: (Choose three.)

Options:

A.  

funds being stolen from other users.

B.  

obscuring the source of illicit funds.

C.  

layering transactions to hide the origin of funds derived from illicit activity.

D.  

difficulty converting into physical currency.

E.  

facilitating payment for other illicit activities and goods.

Discussion 0
Questions 81

Which ancillary departments or operational areas can play an essential role in supporting a larger organization's Anti-Money Laundering and Economic Sanctions compliance program? (Choose three.)

Options:

A.  

Accounting

B.  

Model risk management

C.  

Technology solutions and IT security

D.  

Marketing

E.  

Fraud risk management

Discussion 0
Questions 82

An AML analyst at a financial institution is examining an alert generated by the automated transaction monitoring system to determine whether the alert should be escalated to the AML unit for further investigation or whether it can be archived as a false positive.

Which action might be reasonable for the AML analyst to take?

Options:

A.  

Restrict the client's access to the account

B.  

Request information from the relationship manager assigned to the account that caused the alert

C.  

Perform below-the-line testing to ensure the automated monitoring system is operating effectively

D.  

Send a request for information to the counterparty bank involved in the transaction that caused the alert

Discussion 0
Questions 83

The degree of attraction that a company holds to criminal organizations is influenced by the (Select Two.)

Options:

A.  

amount of annual fees associated with the jurisdiction.

B.  

permissibility of bearer shares.

C.  

rules governing the disclosure of beneficial ownership by the jurisdiction.

D.  

ease of travel to the jurisdiction.

Discussion 0
Questions 84

A financial crimes risk appetite statement describes:

Options:

A.  

how an organization defines Its risk-based approach.

B.  

how an organization determines its key risk and performance indicators.

C.  

the level and type of risk the organization is willing to take to meet its objectives

D.  

the purpose of an organization's financial crimes compliance program.

Discussion 0
Questions 85

Which of the below would be relevant money laundering red flags for life insurance companies? (Select Two.)

Options:

A.  

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

B.  

Natural persons having more than one insurance policy

C.  

High-premium life insurances that provide high payouts

D.  

Regularly switching policies and accepting penalties

E.  

Beneficiary payouts to elderly people

Discussion 0
Questions 86

Which key metric would provide the most valuable data to the senior management of a financial institution about the effectiveness of its AML controls?

Options:

A.  

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

B.  

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

C.  

The number of high-risk customers onboarded each month

D.  

The number of clients exited for commercial reasons

Discussion 0
Questions 87

An AML compliance officer receives an independent audit report with a number of findings.

An appropriate response to the report would include:

Options:

A.  

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

B.  

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

C.  

Defining remedial actions based on the findings' root cause analysis

D.  

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

Discussion 0
Questions 88

A high volume of incoming wire transfers generates an alert about a client. The funds are immediately debited by cash withdrawals and outgoing wire transfers.

Which information should be reviewed first to investigate this alert/case?

Options:

A.  

Open source information

B.  

Customer profile

C.  

Adverse media search

D.  

Account activity

Discussion 0
Questions 89

Risks associated with real estate transactions include (Select Two.)

Options:

A.  

cross-border purchases.

B.  

purchases in the name of a natural person.

C.  

paying true market price for a property.

D.  

non-financed purchases.

Discussion 0
Questions 90

What are the primary advantages of using open-source tools in financial crime investigations? (Choose two.)

Options:

A.  

Partial automation of data collection and analysis

B.  

Cost-effective access to a wide range of data

C.  

Real-time monitoring of selected transactions and data sources

D.  

Ability to conduct investigations with minimal human oversight

E.  

Enhanced ability to identity connections across various data sets

Discussion 0
Questions 91

When the Financial Action Task Force (FATF) places a jurisdiction on the list of "jurisdictions under increased monitoring," also known as the "grey list," the jurisdiction:

Options:

A.  

Accepts to participate in an off-cycle FATF mutual evaluation to be held within the next 12 months.

B.  

Must pay a fine to be removed from the list before the next FATF plenary.

C.  

Has committed to swiftly resolving the deficiencies identified in a FATF mutual evaluation.

D.  

Poses a high money laundering, terrorist financing and proliferation financing risk and must be restricted from accessing the international financial system.

Discussion 0
Questions 92

A financial institution is conducting an enterprise-wide risk assessment (EWRA) and has identified a high inherent risk of money laundering associated with its private banking division due to the clientele's high net worth and complex financial structures. However, the institution has implemented robust customer due diligence (CDD) and enhanced due diligence (EDD) procedures, along with sophisticated transaction monitoring systems.

How would these controls impact the assessment of residual risk?

Options:

A.  

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

B.  

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

C.  

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

D.  

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

Discussion 0
Questions 93

Which risk factors are associated with acquiring and servicing the banking activities of customers considered higher risk for financial crime activities? (Select Three.)

Options:

A.  

Reputational risk

B.  

Operational risk

C.  

Sanctions risk

D.  

Compliance risk

E.  

Lending risk

Discussion 0