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

As part of a risk-based approach, the bank should apply tailored due diligence measures based on the assessed risk level of each customer. This ensures resources are focused where they are most needed, rather than applying uniform enhanced measures to all customers, which can be inefficient and unnecessary.

A: FIs should ensure they have a general understanding of virtual assets and VASP operations to assess risks accurately.

C: Enhanced KYC measures are recommended for VASPs due to their higher ML/TF risk profile.

“FIs must understand the business model and risk of VASPs and apply enhanced due diligence as required by FATF and regulatory guidance.”(CAMS 6th Edition, Virtual Assets and VASPs; FATF Guidance)

Incorrect:

B: While monitoring transactions is important, it’s not a primary initial consideration for onboarding.

D: The FI’s own holdings are not relevant to due diligence on VASPs.

Money laundering corrodes financial-system integrity, eroding investor confidence and impeding sustainable economic growth.

Illicit funds entering legitimate economies can finance terrorism and organized crime, skew resource allocation, and stifle development.

An adequate organizational policy must be up to date with all relevant regulatory developments to remain compliant, and it must be clearly communicated and understood by staff to ensure proper implementation and adherence.

A: The first step in any suspicious activity investigation is to review the transaction history and other relevant account information to establish context, identify patterns, and determine if the behavior is consistent with known typologies of money laundering.

“The initial phase of an AML investigation is to review relevant account information and transaction activity to assess whether a SAR filing is warranted.”

This approach ensures that any subsequent decisions, such as escalation, SAR filing, or customer outreach, are based on a comprehensive understanding of the facts.

To maximize the benefits of PPPs while addressing data privacy and regulatory concerns, the bank should establish a clear framework within the partnership that defines privacy protections and ensures all information sharing complies with applicable legal and regulatory requirements across jurisdictions. This approach fosters trust, enables effective collaboration, and mitigates potential legal risks.

Terrorist financing can be facilitated on gaming platforms particularly through the trading of in-game items for fiat currency. This mechanism allows for the movement of value outside the formal financial system, potentially evading detection and reporting requirements.

“One of the key ML/TF risks in online gaming is the ability to convert virtual assets or in-game items into real-world (fiat) currency, thereby providing a channel for laundering money or funding terrorist activities.”

(CAMS 6th Edition, Chapter: Risks and Methods of Money Laundering and Terrorist Financing; FATF, Virtual Assets Guidance 2019)

Incorrect Options:

A: Buying in-game items with in-game currency does not in itself facilitate terrorist financing.

B: Exchanging items between players may be a step in layering but is not direct TF unless items are traded for fiat.

D: Obtaining items by in-game activity is standard gameplay and not a TF method.

Governance arrangements (A):“Sound governance and risk management arrangements are fundamental to assessing and managing ML/TF risk in products and services.”(CAMS 6th Edition, Risk-Based Approach for Products and Services)

Complexity of the products (B):“Complexity increases risk—products that are highly complex, opaque, or allow for multiple layers or jurisdictions are more vulnerable to misuse for ML/TF.”(CAMS 6th Edition, Product Risk Assessment)

Incorrect Options:

C: Last audit results inform program effectiveness, not inherent product risk.

D: Business financial status is considered in customer risk assessment, not product risk.

The Basel Committee on Banking Supervision (BCBS) requires that the board of directors establish and oversee the compliance function and approve the bank's AML/CTF compliance policies and procedures, including processes for identifying, assessing, monitoring, and reporting compliance risks.

“The board of directors should establish a compliance function and approve compliance policies and processes for identifying, assessing, monitoring, and reporting compliance risks throughout the organization.”

(CAMS 6th Edition, Corporate Governance and Oversight; BCBS, Corporate Governance Principles for Banks, Principle 6)

Many jurisdictions lack robust sanctions frameworks, requiring international cooperation and education to improve compliance.

Option B (Correct):Educational initiatives such as AML/sanctions training and workshops help raise awareness and build capacity.

Option D (Correct):Bilateral cooperation allows knowledge-sharing and technical assistance between regulatory authorities.

Why Other Options Are Incorrect:

Option A (Incorrect):Trade restrictions may pressure non-compliant nations, but they do not directly improve sanctions awareness.

Option C (Incorrect):Enforcing fines without prior education or assistance is ineffective and may create diplomatic tensions.

Best Practices for Sanctions Awareness & Compliance:

Develop international AML/sanctions training programs for emerging markets.

Encourage diplomatic engagement to strengthen legal frameworks.

Leverage FATF’s Mutual Evaluation process to assess progress.

Financial institutions must conduct thorough background checks on employees in sensitive roles (e.g., private banking) to mitigate fraud, insider trading, and money laundering risks.

Option A (Correct):Past employment records help verify work history and identify any red flags related to prior financial misconduct.

Option D (Correct):Internet and media searches reveal any negative press, regulatory issues, or connections to illicit activity.

Option E (Correct):Criminal history searches help screen for prior convictions related to financial crimes.

Why Other Options Are Incorrect:

Option B (Incorrect):Personal references are less reliable and may not uncover objective risk factors.

Option C (Incorrect):A resume is self-reported and should be verified using independent sources.

Best Practices for Employee Background Screening:

Conduct enhanced due diligence for high-risk roles (e.g., private bankers, compliance officers).

Use reliable background screening tools and legal databases.

Verify employment history and check against regulatory blacklists.

E-commerce platforms face KYC challenges due to a global and diverse customer base, making due diligence complex, while criminals may exploit identity fraud to pass KYC checks and facilitate layering in money laundering schemes. These factors increase the financial crime risks for such businesses.

Trade-based money laundering red flags include third-party involvement in transactions, amended letters of credit without clear justification, and non-standard settlement arrangements, all of which can indicate attempts to disguise illicit fund movements or the true nature of the trade.

Business entities in offshore financial centers often pose money laundering risks due to limited organizational disclosure and recordkeeping requirements, which can obscure beneficial ownership and make it easier to conceal illicit financial activities.

C: “The system must be adequate and proportionate to the bank’s size, activities, complexity, and risk profile. A one-size-fits-all solution is not appropriate.”

D: “Effective monitoring systems should support the detection of unusual trends and business relationships, facilitating meaningful analysis and alerts.”(CAMS 6th Edition, Transaction Monitoring System Requirements)

Incorrect:

A: Vendor internal controls are important, but not a top selection criterion for AML system effectiveness.

B: Permissions should be appropriate for the bank’s structure, not just compared to other banks.

The documentation should include evidence that the residual risk remains within the bank’s risk appetite, analysis of resources spent and costs associated with the current lower threshold, and historical data showing the high false positive rate to justify altering the threshold while maintaining effective risk management.

Key challenges in adopting new AML/CFT technologies are:

A: Data privacy—new tech often requires processing more personal data, raising privacy/regulatory concerns.

C: The Travel Rule—meeting global standards for information sharing in payments is a technology challenge.

D: Data quality—effective systems rely on accurate, comprehensive, timely data.

E: Complexity—integrating and managing new technology can increase operational complexity.(CAMS 6th Edition, Technology in AML/CFT; FATF Guidance on Digital ID and Fintech)

In the context ofgambling and gaming sectors, a well-known money laundering typology is the use of platforms tointroduce illicit funds and withdraw them as "winnings". When a customerdeposits large cash amounts and quickly withdraws themwithout engaging in actual gambling, it indicates"placement and layering"techniques.

This behavior is indicative of attempts todisguise the origin of illicit funds, converting them into legitimate-looking financial flows. It is considered a classic red flag in AML programs related to casinos and online gaming.

Fuzzy logic in customer screening systems is used to handle uncertainty and variability in data by producing outputs that include a range of intermediate possibilities between "Yes" and "No." This enables the system to identify potential matches that are not exact but still relevant, improving the detection of name variations and misspellings.

When using network analysis tools, it’s important to avoid algorithmic bias toward social criteria to ensure fairness, analyze connections between individuals or entities to identify links and structures, and study relationships within networks to uncover hierarchies, behaviors, movements, and group organization relevant to detecting criminal activity.

Establishing a surveillance program with periodic risk assessments, access controls, and regular compliance reviews for employees, vendors, and third parties is the most effective way to mitigate insider threats and ensure ongoing adherence to AML regulations. This proactive approach continuously monitors risk rather than relying solely on initial checks or self-certifications.

The FATF’s core role is to enhance international cooperation against money laundering and terrorist financing through setting global standards (“Recommendations”) and issuing guidance.

“The FATF is an intergovernmental body whose purpose is the development and promotion of national and international policies to combat money laundering and terrorist financing.”

The FATF does not have authority to oversee FIUs, nor does it regulate financial markets directly.

Information obtained directly from a government-managed registry is considered a reliable, independent source because it is authoritative, verified, and maintained by an official source, reducing the risk of inaccuracies or manipulation.

AI-powered dashboards summarizing flagged transactions are the most effective feature for improving investigator efficiency, as they consolidate and present relevant data from multiple sources in a structured, actionable format - reducing time spent on manual data gathering and enabling quicker decision-making.

AMutual Legal Assistance Treaty (MLAT)is aformal agreement between two or more countriesthat facilitatescooperation in legal and law enforcement matters, includingAML investigations.

Option D (Correct):MLATs allow governments to share financial intelligence, request legal assistance, and conduct joint investigations.

Option A (Incorrect):A Memorandum of Agreement (MOA) is typically a non-binding contract used for general business or governmental cooperation.

Option B (Incorrect):A Declaration of Understanding is an informal agreement and does not provide a legal framework for law enforcement cooperation.

Option C (Incorrect):A Memorandum of Understanding (MOU) is often used for informal cooperation but lacks the legal enforceability of an MLAT.

Option E (Incorrect):A Request for Urgent Information is not a recognized international legal instrument.

Best Practices for Cross-Border AML Cooperation:

Use MLATs to request access to financial records in foreign jurisdictions.

Collaborate with Financial Intelligence Units (FIUs) via the Egmont Group.

Leverage FATF’s International Cooperation Review Group (ICRG) for guidance.

Potential indicators of terrorist financing abuse in non-profit organizations include large, unaccounted cash donations from anonymous sources, which can disguise illicit funding, and operations in high-risk jurisdictions with limited oversight, where regulatory and monitoring frameworks may be weak.

D: NGOs play an important role in raising awareness about money laundering, lobbying for strong AML/CFT laws, and educating the public and stakeholders about the risks and consequences.

“NGOs help combat money laundering primarily through advocacy, education, and raising public and industry awareness.”(CAMS 6th Edition, Role of NGOs in AML/CFT)

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.

A risk appetite statement clearly defines the level and type of financial crime risk a financial institution is willing to accept in pursuit of its objectives. It guides decision-making and ensures consistency in risk-taking across the organization.

Modern KYC solutions help reduce identity theft, provide reliable customer authentication to build trust, and shorten authentication times, enhancing both security and efficiency in customer onboarding and ongoing due diligence processes.

B: When a subpoena is received, the institution should first consult with legal counsel to ensure the validity and scope of the subpoena. Compliance with law enforcement requests is mandatory and subject to strict legal obligations. All documentation and responses should be properly recorded.

“A subpoena requires a legal response; consult legal counsel to validate the request and respond as required by law.”

FinCEN 314(b) information-sharing requests are voluntary and can proceed only after fulfilling required legal steps, such as verifying membership in the program and ensuring information-sharing agreements are in place.

CAMS 6th Edition clarifies that “under no circumstances should a customer be notified of a law enforcement inquiry or subpoena.”

One of the core components of a strong AFC (Anti-Financial Crimes) compliance program is establishingclear roles, responsibilities, and lines of accountability, especially forescalating and addressing AFC risks and compliance issues. This governance clarity ensures effective implementation, transparency in decision-making, and timely resolution of compliance concerns.

While external audits (option A) and internal controls (option B) are important,defining governance structure and escalation responsibilities (option D)is a foundational element. Additionally, the board of directors (option C) provides oversight—not day-to-day compliance monitoring.

Using brokerage accounts like deposit accounts (e.g., frequent cash deposits or withdrawals) and conducting transactions through nominees or third parties are common red flags in the securities industry. These behaviors can obscure the origin or ownership of funds and are often used to facilitate money laundering.

Cryptocurrency and convertible virtual currencies present common financial crime risks such as obscuring the origin of illicit funds, being used to layer transactions for money laundering, and facilitating payments for illegal goods and services due to their pseudo-anonymous and borderless nature.

Accounting can help detect irregular financial patterns, technology solutions and IT security provide systems for monitoring and data protection, and fraud risk management identifies and mitigates suspicious activities - all of which are essential to supporting AML and sanctions compliance programs.

A proposed EU import ban on refined oil products would be of greatest concern to the bank’s trade finance services, as it directly targets a core revenue-generating sector (oil production) of the company’s country. This could lead to significant disruptions in trade flows, regulatory risk exposure, and potential sanctions violations.

A, B, C, D are all identified by CAMS 6th Edition and FATF as primary financial crime risks for e-commerce platforms:

A: Platforms can be exploited to launder money by processing the movement of criminal proceeds under the guise of legitimate sales.

B: Use of stolen credit/debit cards for online purchases is a common fraud and ML technique.

C: Fraud schemes (such as chargebacks or fake listings) are widespread on e-commerce platforms.

D: E-commerce platforms can serve as fronts for illicit goods or services, masking the true nature of transactions.

E and F are not commonly cited as principal inherent risks in AML/CTF guidance.

Conducting a periodic enterprise-wide risk assessment (EWRA) is the most effective approach to identifying, assessing, and mitigating financial crime risks. It ensures all inherent risks across areas like AML, CFT, sanctions, fraud, ABC, and tax evasion are evaluated, existing controls are assessed, and residual risks are identified. This comprehensive view enables a cohesive and proactive risk management strategy aligned with regulatory expectations.

A primary objective of public sector groups in combating money laundering is to establish and enforce legal and regulatory frameworks that enable the detection, prevention, and punishment of money laundering and related financial crimes, ensuring the integrity of the financial system.

A risk-based approach is central to AML/CFT programs and includes:

A: Creating detailed risk profiles for customers based on their behaviors and connections.

C: Applying controls that are tailored to the actual risk (not a one-size-fits-all approach).

D: Performing a thorough risk assessment, considering customer, transaction, and geographic factors.

“A risk-based approach involves risk profiling, tailored controls, and comprehensive risk assessment across key risk factors.”

(CAMS 6th Edition, Risk-Based Approach and Risk Assessment)

Incorrect:

B: Monitoring only flagged customers is not sufficient.

E: Equal allocation of resources ignores differing risk levels.

A, C, D:

“Trust and asset management services can facilitate the concealment of the source of funds (A), provide a layer of anonymity to transactions (C), and obscure the true legal and beneficial owners (D). These are well-established ML/TF risks in the private wealth sector.”(CAMS 6th Edition, ML/TF Risks in Trust and Asset Management)

B and E are normal aspects of asset management and are not in themselves ML/TF risks unless combined with other suspicious behaviors.

The United Nations Security Council (UNSC) is the only body with the legal authority under international law to impose binding sanctions on countries, entities, or individuals.

“The Security Council’s primary function in imposing sanctions is to maintain or restore international peace and security. These sanctions are legally binding on all UN member states.”

(CAMS 6th Edition, Chapter: International Sanctions and Proliferation Financing; United Nations Charter, Article 41)

Incorrect Options:

B: Sanctions may address AML/CFT failings, but the core mandate is international peace/security.

C: The UNSC does not primarily conduct research or impact analysis.

D: The purpose is international peace/security, not only domestic financial stability.

The United Nations develops sanctions regimes primarily to support the peaceful resolution of conflicts, deter unconstitutional or non-democratic changes in governments, and promote the protection of human rights. These objectives aim to maintain international peace, security, and uphold global norms.

The most important factor when selecting an anti-financial crime tool is its ability to integrate seamlessly with existing systems and processes. Effective integration ensures data consistency, operational efficiency, and improved detection and response to financial crime risks.

FATF Recommendation 29 states that an FIU should serve as a national center for the receipt and analysis of suspicious transaction reports and other information relevant to money laundering and terrorist financing.

“The FIU should serve as a national center for the receipt and analysis of suspicious transaction reports (STRs) and other information relevant to ML/TF, and for the dissemination of the results of that analysis.”

(CAMS 6th Edition, Role of the FIU; FATF Recommendation 29)

Public-private partnerships facilitate strategic information exchange between FIUs and obliged entities and operational information sharing between public authorities and obliged entities, improving collaboration and effectiveness in detecting and preventing financial crime.

Strong CDD, EDD, and advanced transaction monitoring can significantly reduce residual risk in high-risk areas like private banking. While no control fully eliminates risk, effective implementation and ongoing oversight can bring the residual risk down to an acceptable level from its initially high inherent risk.

A: The absence of professional oversight or accounting/auditing standards creates a high-risk environment for financial statement manipulation. Without external checks or mandated standards, criminals can more easily falsify statements to hide illicit assets.

“The lack of regulatory oversight and professional standards in accounting and auditing significantly increases the risk of manipulation and fraud in financial reporting.”(CAMS 6th Edition, Professional Service Providers; FATF Guidance on the Risk-Based Approach for Accountants)

USA PATRIOT Act Section 314(b)allows financial institutions tovoluntarily share information with one another, after notifying the U.S. Treasury, toidentify and report possible money laundering or terrorist financing activities.

Key elements include:

Voluntary participation

Prior notice to FinCEN (part of the U.S. Treasury)

Protection from liability when acting in good faith

Enhanced collaborative detection across institutions

Section 314(a)refers toinformation sharing between law enforcement and financial institutions, not peer-to-peer sharing.

COSMICis an initiative in certain jurisdictions like Singapore, not U.S. regulation.

Regulation (EU) 2024/1624is part of the EU AML framework, not relevant to U.S. institutions.

A risk-based approach involves conducting a comprehensive risk assessment, applying controls that match the identified risk levels, and creating detailed customer risk profiles to focus monitoring and resources where they are most needed to mitigate financial crime risks effectively.

The First Line of Defense (1LoD) consists of customer-facing business units (e.g., relationship managers, front-office staff, and operational teams). Their primary responsibility in financial crime risk management is to implement AML/CFT controls as part of daily operations. This includes Collecting complete customer information.

The First Line of Defense is responsible for conducting Know Your Customer (KYC) and Customer Due Diligence (CDD) during onboarding and throughout the customer relationship. Ensuring that all relevant customer details (e.g., identity, business purpose, ownership structure) are accurately collected and documented is crucial for mitigating financial crime risks.

D: “Cooperation and coordination between regulatory authorities, law enforcement agencies, and FIUs are essential for effective AML investigations, especially in cross-border cases. This is often accomplished through formal agreements, MOUs, and information-sharing mechanisms.”(CAMS 6th Edition, International Cooperation in AML/CFT; FATF Recommendations 36-40)

Real estate transactions are vulnerable to ML/TF risks, particularly when there is limited transparency or unusual payment methods:

Cross-border purchases (A):“Purchases by foreign buyers, especially from high-risk jurisdictions, are a red flag for money laundering in the real estate sector.”(CAMS 6th Edition, Real Estate Money Laundering Risks; FATF, Money Laundering and Terrorist Financing through the Real Estate Sector, 2007)

Non-financed purchases (D):“Non-financed (all-cash) purchases can indicate the introduction of illicit funds into the financial system, bypassing the controls of mortgage lenders.”(CAMS 6th Edition, Real Estate ML/TF Risks)

Incorrect Options:

B: Purchasing in the name of a natural person is standard and not inherently risky.

C: Paying the true market price does not raise ML/TF risk.

Paying premium several years in advance and terminating early for a refund (A):“A typical red flag is when a policyholder pays large premiums up front and then seeks early termination to receive a refund. This can be used to launder illicit funds by integrating them into the financial system and then retrieving ‘clean’ money.”(CAMS 6th Edition, Life Insurance ML/TF Risks; FATF Guidance for a Risk-Based Approach for the Life Insurance Sector)

Regularly switching policies and accepting penalties (D):“Frequent changes in insurance policies or products, even at a financial loss, are considered suspicious. This may indicate an attempt to obscure the money trail or integrate illicit proceeds.”(CAMS 6th Edition, ML/TF Red Flags in Life Insurance)

Incorrect Options:

B: Having multiple policies is common and not itself a red flag.

C: High premiums/payouts are not inherently suspicious.

E: Beneficiary payouts to elderly people are not ML/TF red flags.