[Mar-2026] CAMS Questions - Truly Beneficial For Your ACAMS Exam [Q308-Q330]

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[Mar-2026] CAMS Questions - Truly Beneficial For Your ACAMS Exam

Download ACAMS CAMS Sample Questions


The ACAMS CAMS exam consists of multiple-choice questions and covers a broad range of topics, including AML regulations, customer due diligence, sanctions screening, and suspicious activity reporting. CAMS exam is available in multiple languages and can be taken online or at a physical test center.

 

NEW QUESTION # 308
the Financing of Terrorism (CFT)]
Why is the Mutual Legal Assistance Treaty (MLAT) a gateway for international cooperation?

  • A. They provide a legal basis for transmitting evidence that can be used for prosecution and judicial proceedings
  • B. They obtain intelligence that might lead to evidence
  • C. They issue the Prmc4es of Information Exchange Between Financial intelligence Units (FIUs)
  • D. They receive reports of suspicious transactions from financial institutions to disseminate to local Law enforcement and foreign FIUs

Answer: A

Explanation:
A Mutual Legal Assistance Treaty (MLAT) is an agreement between two or more countries for the purpose of gathering andexchanging information in an effort to enforce public or criminal laws1. MLATs provide a legal basis for transmitting evidence that can be used for prosecution and judicial proceedings, such as witness statements, bank records, search and seizure orders, and asset forfeiture2. MLATs also facilitate the cooperation and coordination between law enforcement authorities of different jurisdictions in investigating and prosecuting transnational crimes, such as money laundering, terrorist financing, corruption, and cybercrime3. The other options are incorrect because:
* B. MLATs do not receive reports of suspicious transactions from financial institutions, but rather request specific information or evidence from foreign authorities. Financial institutions report suspicious transactions to their domestic Financial Intelligence Units (FIUs), which may then share the information with foreign FIUs through other mechanisms, such as the Egmont Group or bilateral agreements4.
* C. MLATs do not obtain intelligence that might lead to evidence, but rather request evidence that is already available or can be obtained by foreign authorities. Intelligence is a broader term that refers to any information that is relevant to the security or interests of a country, and may not be admissible as evidence in a court of law5. Intelligence may be obtained through other means, such as covert operations, surveillance, or informants6.
* D. MLATs do not issue the Principles of Information Exchange Between Financial Intelligence Units (FIUs), but rather follow them. The Principles of Information Exchange are a set of guidelines that were adopted by the Egmont Group of FIUs in 2001, and aim to enhance the cooperation and communication among FIUs in exchanging financial information and intelligence7. The Principles of Information Exchange are not legally binding, but rather reflect the best practices and standards of the FIU community.
:
1: Mutual legal assistance treaty - Wikipedia
2: FREQUENTLY ASKED QUESTIONS REGARDING LEGAL ASSISTANCE IN CRIMINAL
MATTERS, page 1
3: The Mutual Legal Assistance Problem explained | wilmap
4: ACAMS, CAMS Certification Package - 6th Edition, Chapter 4, page 125
5: Intelligence - Wikipedia
6: Intelligence cycle - Wikipedia
7: Egmont Group of Financial Intelligence Units - Wikipedia
8: Principles for Information Exchange Between Financial Intelligence Units for Money Laundering and Terrorism Financing Cases


NEW QUESTION # 309
A director of a financial institution was convicted of laundering money as part of a Ponzi scheme and terminated. As a result of an internal investigation evidence proved that an employee assisted in the illegal activity.
Which action should the institution take?

  • A. Discipline the employee and inform local authorities
  • B. Since the employee was not charged, no further action is required
  • C. Discipline the employee with no further action
  • D. Require all employees to complete additional anti-money laundering training

Answer: A

Explanation:
If an employee of a financial institution is found to have assisted in money laundering or any other criminal activity, the institution should take appropriate disciplinary action and report the employee to the relevant authorities. This is not only a legal obligation, but also a sound compliance practice to protect the institution's reputation and integrity. Disciplining the employee without informing the authorities would be insufficient and potentially expose the institution to further legal risks. Ignoring the employee's involvement or requiring additional training for all employees would be ineffective and inappropriate responses.
References:
* ACAMS CAMS Certification Package - 6th Edition, Chapter 5: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), pp. 121-1221
* ACAMS CAMS Certification Package - 6th Edition, Chapter 6: AML Compliance Program, pp. 143-1441
* ACAMS CAMS Certification Video Training Course, Module 5: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), Lesson 5.2: International Standards and Best Practices2
* ACAMS CAMS Certification Video Training Course, Module 6: AML Compliance Program, Lesson
6.4: Internal Controls2


NEW QUESTION # 310
In its paper. Customer Due Diligence for Banks, the Basel Committee on Banking Supervision identified which risks on banking institutions as a result of an inadequate KYC program?

  • A. Outsourcing, legal, concentration, reputational
  • B. Security, information, local, operational
  • C. Credit, operational, market, concentration
  • D. Legal, reputational, operational, concentration

Answer: D

Explanation:
The Basel Committee on Banking Supervision identified four risks to banking institutions as a result of an inadequate KYC program: legal, reputational, operational, and concentration. Legal risks include the potential for fines or sanctions for non-compliance with applicable laws and regulations. Reputational risks include the loss of customer confidence due to the institution's involvement in illicit activities. Operational risks include the potential for fraudulent or suspicious activity to go undetected. Finally, concentration risks involve the potential for a single customer or group of related customers to dominate the institution's operations.


NEW QUESTION # 311
An anti-money laundering consultant audits a bank's current anti-money laundering policies, procedures and controls. The bank serves high-income, high net-worth clients who include non-residents and offshore businesses. During a review of the custom list, the anti-money laundering consultant determines that he and the bank have mutual clients. The bank's written anti-money laundering program includes a process for the bank to establish the identity of the person with whom they conduct business, but does not address monitoring of customer account activity.
The consultant should recommend the bank:

  • A. Revise the procedures to better assess ongoing customer activity.
  • B. Reduce the risk rating on the mutual customers.
  • C. Continue to follow the current written anti-money laundering program.
  • D. Focus on high-risk customer acceptance procedures.

Answer: A

Explanation:
According to the ACAMS Study Guide, an effective AML program should include four key elements: internal controls, independent testing, designated compliance officer, and training1. Internal controls are policies, procedures, and processes that help prevent, detect, and report money laundering and terrorist financing activities. One of the essential components of internal controls is customer due diligence (CDD), which involves identifying and verifying the customer, understanding the nature and purpose of the customer relationship, and conducting ongoing monitoring of customer transactions and risk profiles2. Ongoing monitoring is crucial for detecting and reporting suspicious activities, updating customer information, and reassessing customer risk ratings3.
In this case, the bank's written AML program does not address monitoring of customer account activity, which is a significant gap in its internal controls. The bank serves high-income, high net-worth clients who include non-residents and offshore businesses, which are considered high-risk customers for AML purposes4. The bank should have enhanced due diligence (EDD) measures for these customers, such as obtaining additional information, conducting more frequent reviews, and applying stricter transaction limits5. The fact that the consultant and the bank have mutual clients does not affect the risk rating or the due diligence requirements of those customers. Therefore, the consultant should recommend the bank to revise its procedures to better assess ongoing customer activity and comply with the AML standards.
Reference:
1: ACAMS Study Guide, Chapter 2: Developing an Effective Anti-Money Laundering Program
2: ACAMS Study Guide, Chapter 3: Conducting Customer Due Diligence
3: ACAMS Study Guide, Chapter 4: Ongoing Monitoring and Suspicious Activity Reporting
4: ACAMS Study Guide, Chapter 5: Identifying High-Risk Customers
5: ACAMS Study Guide, Chapter 6: Applying Enhanced Due Diligence Measures


NEW QUESTION # 312
A bank compliance officer discovers cash deposit activity inconsistent with the expected and historical cash activity within the personal accounts of the chairman of the board. The cash activity appears structured to avoid the local legal filing requirements for large cash transactions, and a suspicious transaction report (STR) was filed.
How should the compliance officer report the filing of the STR to the board of directors without revealing the existence of the filing to the subject?

  • A. Inform the legal counsel of the bank
  • B. The compliance officer and the chief executive officer should jointly interview the chairman
  • C. Notify the financial institution's regulator to disclose the activity
  • D. Follow the financial institution's established STR reporting policy

Answer: A


NEW QUESTION # 313
What core objective does the Egmont Group suggest would lead to an effective national Financial Intelligence Unit (FIU)?

  • A. The FIU must have absolute trust amongst national and international stakeholders before sensitive information will be exchanged with confidence.
  • B. The FIU must operate from physically separated premises from other law enforcement agencies and government offices.
  • C. The FIU meets the Egmont Group assessment criteria.
  • D. The FIU must be able to promote the value of the government's commitment to embed a corruption free society within the country.

Answer: A

Explanation:
According to the Anti-Money Laundering Specialist (the 6th edition) resources, the Egmont Group is an international network of FIUs that facilitates and prompts the exchange of information, knowledge, and cooperation among its members to combat money laundering, terrorist financing, and associated predicate offences1. The Egmont Group suggests that one of the core objectives that would lead to an effective national FIU is to have absolute trust amongst national and international stakeholders before sensitive information will be exchanged with confidence2. This means that the FIU should establish and maintain a high level of credibility, professionalism, and integrity in its operations, and ensure that the information it receives and disseminates is protected and used appropriately. The FIU should also comply with the Egmont Group's principlesand standards for information exchange, and foster a culture of mutual trust and cooperation with other FIUs and relevant authorities3.
The other three options are incorrect because:
* The FIU must operate from physically separated premises from other law enforcement agencies and government offices is not a core objective that the Egmont Group suggests for an effective national FIU. While the FIU should have operational independence and autonomy, and be free from undue influence or interference, it does not necessarily have to be physically separated from other agencies or offices. The FIU may be located within the judicial, law enforcement, administrative, or hybrid model, depending on the country's legal and institutional framework4.
* The FIU meets the Egmont Group assessment criteria is not a core objective that the Egmont Group suggests for an effective national FIU. While meeting the Egmont Group assessment criteria is a requirement for becoming and remaining a member of the Egmont Group, it is not an objective in itself. The assessment criteria are based on the FATF recommendations and the Egmont Group's own documents, and they serve as a benchmark for evaluating the FIU's compliance and effectiveness5.
* The FIU must be able to promote the value of the government's commitment to embed a corruption free society within the country is not a core objective that the Egmont Group suggests for an effective national FIU. While the FIU may contribute to the prevention and detection of corruption, as well as the recovery of illicit assets, by analyzing and sharing financial intelligence, it is not the sole or primary responsibility of the FIU to promote the value of the government's commitment to embed a corruption free society within the country. This is a broader and more complex goal that involves multiple actors and factors, such as political will, legal framework, institutional capacity, civil society, media, and international cooperation.
1: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 64 2: Egmont Group, Egmont Group of Financial Intelligence Units Principles for Information Exchange Between Financial Intelligence Units, June 2013, 3, p. 2 3: Egmont Group, Egmont Group of Financial Intelligence Units Principles for Information Exchange Between Financial Intelligence Units, June 2013, 3, p. 3-4 4: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3, p. 67 5: Egmont Group, Egmont Group of Financial Intelligence Units Support and Compliance Process, June 2013, [6], p. 3-4 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 4, p. 91-92 Reference: https://www.elibrary.imf.org/view/books/069/02365-9781589063495-en/ap01.xml


NEW QUESTION # 314
Which elements can trigger a review of the existing relationship during the opening of a new account? (Select Two.)

  • A. A false positive result for name screening
  • B. Recent adverse media on the client
  • C. Regular checks on the flow of funds
  • D. Incoming transfers from high-risk jurisdictions
  • E. Estimated total income decrease

Answer: B,D

Explanation:
According to the Certified Anti-Money Laundering Specialist (CAMS) Sixth Edition manual, elements that can trigger a review of the existing relationship during the opening of a new account include recent adverse media on the client (page 60) and incoming transfers from high-risk jurisdictions (page 61). The other elements listed, such as regular checks on the flow of funds, a false positive result for name screening, and an estimated total income decrease, are not triggers for a review.


NEW QUESTION # 315
Which type of sanctions are most likely to be used in order to avoid escalating violent conflicts and/or proliferation of weapons?

  • A. Asset freeze
  • B. Financial prohibitions
  • C. Export and import restrictions
  • D. Arms and related materials embargo

Answer: D

Explanation:
Arms and related materials embargo is a type of sanction that prohibits the supply, sale, transfer, or export of arms and related materials to a targeted country, entity, or individual. This type of sanction is most likely to be used in order to avoid escalating violent conflicts and/or proliferation of weapons, as it aims to reduce the availability and access of weapons and ammunition that could fuel violence and instability. Arms and related materials embargo can also prevent the transfer of weapons of mass destruction and their delivery systems to non-state actors or rogue states. According to the UN, arms and related materials embargo is one of the most common and effective forms of sanctions that the Security Council imposes to address threats to international peace and security12.
Reference:
1: Different types of sanctions - Consilium1
2: UN Sanctions and the Prevention of Conflict - United Nations University2


NEW QUESTION # 316
A bank in an offshore jurisdiction approaches an institution about opening a new correspondent banking relationship. Prior to opening the account, the new account representative obtains copies of the offshore bank's anti-money laundering policies and procedures, and all appropriate legal documentation for the bank; ascertains no third parties will be able to access the accounts; and determines the owners of the bank, the bank's primary business activities, and the business address of the bank. Which of the following steps does the Basel Committee on Banking Supervision's Customer Due Diligence for Banks Paper recommend the banker take prior to opening Oils correspondent account?
1. Conduct a site visit and meet all the principals and beneficial owners in person.
2. Verify the bank has a physical presence in the country where it is incorporated.
3. Confirm the bank is subject to regulatory supervision with adequate anti-money laundering laws.
4. Obtain and maintain a complete listing of the correspondent bank's customers, including politically exposed persons.

  • A. 1 and 4 only
  • B. 1 and 2 only
  • C. 2 and 3 only
  • D. 3 and 4 only

Answer: C


NEW QUESTION # 317
Combating the Financing of Terrorism (CFT)]
Which activity associated with new or developing technologies does the Financial Action Task Force recommend financial institutions pay special attention to?

  • A. Financial intermediaries performing transactions for customers
  • B. High volumes of cash transactions
  • C. Complex or unusually large transactions
  • D. Non-face-to-face business relationships or transactions

Answer: D

Explanation:
The Financial Action Task Force (FATF) recommends that financial institutions pay special attention to non- face-to-face business relationships or transactions when dealing with new or developing technologies. These include digital channels, online platforms, and virtual interactions. The increased use of technology for remote transactions poses unique risks related to customer identification, authentication, and due diligence. Financial institutions must implement robust controls to mitigate these risks and ensure compliance with anti-money laundering (AML) and counter-terrorist financing (CFT) requirements12.
References:
FATF Opportunities and Challenges of New Technologies for AML/CFT
FATF: New Technologies for AML/CFT
FATF Recommendation 15: New technologies


NEW QUESTION # 318
Which principles of the Egmont Group of Financial Intelligence Units (Fills) are aimed at maximizing cooperation between FlUs to more effectively combat money laundering? (Select Two.)

  • A. Eliminating spontaneous information sharing between FlUs to reduce the burden of excess investigative work.
  • B. Information exchange should take place informally, without too many formal prerequisites.
  • C. FIU cooperation should always be channeled through designated intermediaries.
  • D. Formal Egmont Group membership requirements ensure a high commitment of the eligible FlUs.
  • E. It is within an FlU's authority to sign Memorandums of Understanding independently.

Answer: B,E

Explanation:
The principles of the Egmont Group of Financial Intelligence Units (FILLs) aimed at maximizing cooperation between FILLs to more effectively combat money laundering are [1]:
B . Information exchange should take place informally, without too many formal prerequisites. (CAMS Manual, 6th Edition, Page 55)


NEW QUESTION # 319
Which key aspect of the Office of Foreign Assets Control's extraterritorial reach specifically relates to prohibited transactions?

  • A. Prohibit or reject licensed trade and financial transactions with specified countries, entities and U.S.
    individuals
  • B. Prohibit or reject licensed trade and financial transactions with specified countries, entities and non-U.
  • C. individuals
  • D. Prohibit or reject unlicensed trade and financial transactions with specified countries, entities, and individuals
  • E. Prohibit or reject unlicensed foreign trade and financial transactions with specified countries, entities, and individuals.

Answer: D

Explanation:
the Office of Foreign Assets Control (OFAC) has the authority to prohibit or reject any trade or financial transactions involving specified countries, entities, and individuals that are subject to U.S. economic sanctions, unless such transactions are authorized by a general or specific license issued by OFAC. This applies to transactions that occur within the U.S. territory, as well as transactions that involve U.S. persons, U.
S. goods, or the U.S. financial system, regardless of where they take place. This is one of the key aspects of OFAC's extraterritorial reach, which means that OFAC can enforce its sanctions programs beyond the U.S.
borders.
References:
* Home | Office of Foreign Assets Control, section "Mission": "The Office of Foreign Assets Control ("OFAC") of the US Department of the Treasury administers and enforces economic and trade sanctions based on US foreign policy and national security goals against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the United States."
* The Aggressive Extraterritorial Reach of U.S. Economic Sanctions: Foreign Company Exposure to OFAC Enforcement, section "A. Bases for OFAC jurisdiction over foreign parties", paragraph 1: "One key aspect of the Office of Foreign Assets Control's extraterritorial reach includes the blocking of certain non-United States initiated transactions for or through the United States (U.S.) for benefit of a restricted person or entity."
* The global reach of OFAC sanctions, section "The global reach of OFAC sanctions", paragraph 1:
"OFAC sanctions are trade and economic sanctions administered by The U.S. Treasury Department's Office of Foreign Asset Control (OFAC). They are often intended to have extra-territorial effect, meaning that they apply outside the U.S. territory. In some instances a connection with the U.S.
territory is required."
"Prohibit or reject unlicensed trade and financial transactions with specified countries, entities, and individuals. "


NEW QUESTION # 320
Which of the following arekey metricsthat providevaluable data to senior managementabout the effectiveness of an FI'sAML controls?

  • A. Thenumber of high-risk customers onboardedeach month.
  • B. Thenumber of money laundering alertsgenerated by the watchlist screening system.
  • C. Theratio of true positives to false positivesgenerated by the automated monitoring system.
  • D. Thenumber of clients exitedfor commercial reasons.

Answer: C

Explanation:
AML controls should bemeasured for effectivenessusingquantifiable metrics.
* Option D (Correct):Thetrue positive/false positive ratioassesses theefficiencyof AML detection.
* Option A (Incorrect):Thenumber of alerts alonedoes not measureeffectiveness, as many could befalse positives.
* Option B (Incorrect):Client exitsdo not indicate whether an AML program isworking properly.
* Option C (Incorrect):High-risk customer onboardingmust bemonitored, but it does not indicate AML effectiveness.
Reference:FATF Guidance on AML Risk Management, Wolfsberg Group AML Effectiveness Indicators, FinCEN SAR Filing Effectiveness Reports.


NEW QUESTION # 321
Combating the Financing of Terrorism (CFT)]
According to the Financial Action Task Force 40 Recommendations, to fulfill identification requirements concerning legal entities, financial institutions should take measures to verify

  • A. funds or trusts maintained by terrorists.
  • B. the financial status of the legal entity through documented proof of the entity's other banking relations.
  • C. a person purporting to act on behalf of the legal entity who is a resident in a country with strict secrecy laws.
  • D. the legal existence and ownership structure of the legal entity.

Answer: D

Explanation:
According to the Financial Action Task Force (FATF) 40 Recommendations, Recommendation 10 requires financial institutions to identify and verify the identity of their customers, including legal persons and arrangements, using reliable and independent sources. This includes verifying the legal existence and structure of the legal entity, such as by obtaining a certificate of incorporation, a partnership agreement, or a trust deed. Additionally, financial institutions should identify and verify the identity of the beneficial owners of the legal entity, such as by obtaining information on the natural persons who ultimately own or control the entity, or who exercise effective control over the entity.
The other options are not consistent with the FATF 40 Recommendations. Verifying the financial status of the legal entity, or the entity's other banking relations, is not a requirement for identification purposes, although it may be relevant for risk assessment or due diligence purposes. Verifying a person purporting to act on behalf of the legal entity is also not sufficient, as the person may not be authorized or may not disclose the true identity or beneficial ownership of the entity. Verifying funds or trusts maintained by terrorists is not a specific identification requirement, but rather a general obligation to comply with targeted financial sanctions and freeze the assets of designated persons or entities.
:
FATF 40 Recommendations, Recommendation 10, Interpretive Note to Recommendation 10, pages 14-18.
ACAMS CAMS Certification Study Guide, 6th Edition, Chapter 3, Section 3.2.1, page 77.


NEW QUESTION # 322
In addition to monitoring for suspicious activity, what are electronic monitoring systems also valuable for?

  • A. Proving to the Board of Directors that the FIU is doing its job
  • B. Identifying how customers are using products
  • C. Meeting mandatory regulatory requirements for system implementation
  • D. Highlighting the skills of the system analysts

Answer: C


NEW QUESTION # 323
Which of the below would be relevant money laundering red flags for life insurance companies? (Select Two.)

  • A. High-premium life insurances that provide high payouts
  • B. Regularly switching policies and accepting penalties
  • C. Natural persons having more than one insurance policy
  • D. Beneficiary payouts to elderly people
  • E. Paying premium several years in advance and terminating early for a refund

Answer: B,E

Explanation:
* 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.
References:
CAMS 6th Edition, Life Insurance Red Flags
FATF Guidance for a Risk-Based Approach for the Life Insurance Sector


NEW QUESTION # 324
A comprehensive set of risk-based guidelines for maintaining business relationships is being developed.
Which situation indicates that the institution should terminate the relationship with a client?

  • A. The client conducts international financial transactions exceeding U.S. $500 million.
  • B. The client exceeds the criteria of an acceptable risk model created by another institution that is not similar in size and complexity.
  • C. The client exceeds the criteria of an acceptable risk model created by the institution and does not perform acceptable remedial actions.
  • D. The client does business in countries with active terrorist organizations.

Answer: C

Explanation:
According to the risk-based approach, financial institutions should apply enhanced due diligence and ongoing monitoring to higher-risk clients, and take appropriate measures to mitigate the risks of money laundering and terrorist financing. If the client exceeds the criteria of an acceptable risk model created by the institution, the institution should communicate the issues to the client and request remedial actions, such as providing additional information, documentation, or evidence of compliance. If the client does not cooperate or comply with the institution's requirements, the institution should consider terminating the relationship with the client, as the risk may outweigh the benefits of continuing the business relationship.
References:
ACAMS CAMS Certification Package - 6th Edition, Chapter 2: Risk Assessments, pp. 51-521 ACAMS CAMS Certification Package - 6th Edition, Chapter 4: Customer Due Diligence, pp. 97-981 ACAMS CAMS Certification Video Training Course, Module 2: Risk Assessments, Lesson 2.3:
Risk-Based Approach2
ACAMS CAMS Certification Video Training Course, Module 4: Customer Due Diligence, Lesson 4.3:
Enhanced Due Diligence
Reference:
http://www.fatf-gafi.org/media/fatf/documents/reports/Risk-Based-Approach-Banking-Sector.pdf


NEW QUESTION # 325
A compliance officer at a large financial institution has been tasked by senior management to lead a team in an internal review and potential revision of the institution's customer onboarding program following a regulatory enforcement action of another institution.
Which step should the compliance officer perform first?

  • A. Conducting enhanced due diligence on high risk customers
  • B. Reviewing the institution's risk assessment
  • C. Revising training materials for frontline staff
  • D. Resolving substantive discrepancies in customer verification

Answer: B

Explanation:
Explanation
Review of any AML/CFT program begins with the Risk Based Approached. It should first check the internal system to identify risk factors and design program accordingly.


NEW QUESTION # 326
Combating the Financing of Terrorism (CFT)]
At a minimum, who should receive role-specific AML training? (Select Three.)

  • A. Human resources staff
  • B. Customer facing staff
  • C. Information technology staff
  • D. Board of Directors
  • E. Consultants
  • F. AML/Compliance staff

Answer: B,C,F

Explanation:
1. Information Technology Staff: These employees handle systems, databases, and software used for transaction monitoring, customer due diligence (CDD), and other AML processes. They need to understand how to configure and maintain AML systems, recognize suspicious patterns, and ensure data security.
2. Customer Facing Staff: Frontline employees, such as tellers, relationship managers, and customer service representatives, interact directly with customers. They play a crucial role in identifying red flags, conducting enhanced due diligence (EDD), and reporting suspicious activities. Training helps them recognize unusual behavior and follow proper procedures.
3. AML/Compliance Staff: These professionals are directly responsible for AML program management, policy development, and regulatory compliance. They need in-depth knowledge of AML laws, regulations, and best practices. Training ensures they stay updated and can effectively implement AML controls.
References:
1. Financial Crime Academy: Ensuring Compliance - Building an Effective AML Training Program
2. ACAMS: AML Training - Preparing Auditors to Adequately Assess AML Programs
3. Financial Crime Academy: AML Training for High-Level Executives
4. Financial Crime Academy: Senior Management AML Training Workshops


NEW QUESTION # 327
the Financing of Terrorism (CFT)]
Which online gambling scheme involves placing bets with deposited funds and colluding with other players to obscure the money's origin?

  • A. Concealment
  • B. Chip dumping
  • C. Coordinated betting
  • D. Player-to-player transfers

Answer: B

Explanation:
Chip dumpingis a commonmoney laundering techniquein online gambling.
* Option D (Correct):Chip dumpingoccurs whenplayers colludetotransfer fundsvia staged betting, making illicit funds appear as gambling winnings.
* Option A (Incorrect):Concealmentis a broad term, not a specific technique.
* Option B (Incorrect):Coordinated bettingrefers tomatch-fixing, not money laundering.
* Option C (Incorrect):Player-to-player transfersare used in money laundering but arenot specific to online gambling.
Reference:FATF Report on Virtual Assets and Online Gambling (2021), Wolfsberg Group Gaming AML Guidelines.


NEW QUESTION # 328
Suspicious activity triggered a suspicious transaction report filing on a company that holds an account at a large commercial bank. Investigations revealed that a member of the bank's Board of Directors is the major shareholder of the company. Further review revealed the bank had no reasonable explanation for the activity, but could not confirm if criminal activity occurred. Which of the following is the next best course of action for the compliance officer?

  • A. Ask the Board member to explain the transaction.
  • B. Prevent the suspicious transaction report from government filing.
  • C. Maintain standard summary statistical reporting to the Board.
  • D. Include a detailed presentation of this case in the Board report.

Answer: D

Explanation:
The compliance officer should report the suspicious activity to the Board of Directors, as they are ultimately responsible for the bank's compliance program and oversight. The Board should be informed of the potential conflict of interest and reputational risk involved in the case, as well as the steps taken by the compliance officer to investigate and file the suspicious transaction report. The compliance officer should not prevent the filing of the report, as this would violate the legal obligations of the bank and expose it to regulatory sanctions and penalties. The compliance officer should not ask the Board member to explain the transaction, as this could compromise the integrity and independence of the investigation and the reporting process. The compliance officer should not maintain standard summary statistical reporting to the Board, as this would not adequately address the seriousness and complexity of the case.
References:
* ACAMS CAMS Certification Study Guide, 6th Edition, Chapter 5, page 1271
* ACAMS CAMS Certification Video Training Course, Module 5, Lesson 22
* ACAMS CAMS Certification Exam Outline, Domain 5, Task 13


NEW QUESTION # 329
The compliance officer for a private bank has been tasked with reviewing the procedure for authorized signatories on customer accounts to ensure it is in line with relevant Wolfsberg Anti-Money Laundering Principles for Private Banking.
Which three statements from the procedure are in line with Wolfsberg? (Choose three.)

  • A. Where due diligence has been satisfactorily completed on all authorized signers, the responsible private banker may reduce the due diligence performed on the account holder and/or beneficial owner.
  • B. The responsible private banker must establish the identity of a holder of general powers over an account (e.g. a signatory for the account) and, as appropriate, verify that identity.
  • C. If an individual has signing authority over an account but does not act on a professional basis as a manager of funds, the responsible private banker must understand and document the relationship between that authorized signer, the account holder, and, if different, the beneficial owner of the account.
  • D. Where the Authorized Signatory is not a lawyer or accountant, due diligence as to the source of funds and wealth of the Authorized Signatory should be undertaken.
  • E. The responsible private banker must obtain the necessary documentation establishing the authorized signer's authority to act on behalf of the account holder or beneficial owner (e.g. a Power of Attorney).

Answer: B,C,E

Explanation:
The three statements from the procedure that are in line with Wolfsberg are:
B: The responsible private banker must establish the identity of a holder of general powers over an account (e.g. a signatory for the account) and, as appropriate, verify that identity. This is consistent with the Wolfsberg Principle 1.2.1, which states that the bank will establish the identity of its clients and beneficial owners prior to establishing business relationships with such persons1.
D: The responsible private banker must obtain the necessary documentation establishing the authorized signer's authority to act on behalf of the account holder or beneficial owner (e.g. a Power of Attorney). This is consistent with the Wolfsberg Principle 1.2.3, which states that the bank will obtain the necessary documentation establishing the authority of the authorized signatory to act on behalf of the client or beneficial owner1.
E: If an individual has signing authority over an account but does not act on a professional basis as a manager of funds, the responsible private banker must understand and document the relationship between that authorized signer, the account holder, and, if different, the beneficial owner of the account. This is consistent with the Wolfsberg Principle 1.2.4, which states that the bank will understand and document the relationship between the authorized signatory, the client and, if different, the beneficial owner of the account1.
References:
1: Wolfsberg Anti-Money Laundering Principles for Private Banking (2012)


NEW QUESTION # 330
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