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

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.

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.

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)

Customer loyalty program tracking and product usage analysis can uncover unusual patterns or behaviors that deviate from expected norms. These insights may help detect suspicious activity or hidden risks, making them valuable tools for supporting AML compliance even if not directly linked to traditional monitoring systems.

A: “Hawala and similar informal value transfer systems are difficult to monitor, making it challenging to identify the originator, recipient, and source of funds.”

D: “Hawala operates through informal networks for cross-border transfers, often outside the formal banking system, increasing AML/CFT risk.”(CAMS 6th Edition, Alternative Remittance Systems; FATF, Guidance on Money Transfer Services)

According to the Egmont Group and CAMS 6th Edition, PPPs benefit FIUs by:

A: “PPPs help address challenges around data protection and facilitate information sharing between public and private sectors, overcoming common legal barriers.”

B: “PPPs result in higher-quality reports from the private sector and provide valuable additional informational input for FIUs.”

E: “These partnerships give FIUs increased flexibility and agility, allowing them to respond dynamically to evolving ML/TF threats.”(CAMS 6th Edition, Egmont Group Guidance on PPPs; Egmont Group, Public-Private Partnerships for FIUs)

PEPs are recognized by CAMS 6th Edition and FATF as posing elevated risk due to:

A. The family members and close associates of PEPs may be involved in illicit activities:“The risks extend beyond the PEP to family members and close associates, who may be used to conceal the movement of illicit funds.”(CAMS 6th Edition, PEP Risk Factors; FATF Guidance)

C. PEPs may exploit embassy activities to conceal bribery and corruption transactions:“PEPs may use their position or diplomatic privileges, such as embassy operations, to disguise or facilitate the movement of illicit funds.”(CAMS 6th Edition, Corruption and PEP Risks)

Incorrect Options:

B: There is no such legal provision granting PEPs financial immunity or unlimited credit.

D: Banks may (and often must) exit PEP relationships not in line with their risk appetite.

A rules-based approach to transaction monitoring relies on predefined rules that flag specific patterns and on setting thresholds that trigger automated alerts when exceeded. These techniques are fundamental to identifying potentially suspicious activities in a structured, deterministic way.

A (ISO): Ensures information security controls are aligned with AFC efforts, protecting sensitive data and reducing the risk of cyber-enabled financial crime.

D (DPO): Helps ensure compliance with data privacy laws and enables secure, lawful information-sharing for AML purposes.

“Collaboration with the ISO and DPO is critical to maintaining data security and privacy within AFC compliance frameworks.”(CAMS 6th Edition, Governance and Cross-Functional Collaboration)

The AUSTRAC Fintel Alliance is a successful example of a public-private partnership (PPP). It brings together government agencies and private sector organizations to collaborate on detecting, preventing, and disrupting financial crime through shared intelligence, technology, and expertise.

B: If a bank fails to demonstrate sustained improvement or cannot resolve identified deficiencies, it can face civil or even criminal penalties from regulators. Regulators expect not just policy changes, but proof of effectiveness and ongoing compliance improvements.

C: Even after addressing many concerns, if all issues are not resolved—such as outstanding transaction monitoring backlogs—regulators may issue orders to further remediate the AML program until full compliance is achieved.

CAMS 6th Edition and regulatory guidance clarify that “regulators may impose penalties, issue consent orders, or require further remediation where weaknesses persist.”

Incorrect:

A: Secondary sanctions generally apply to sanctions violations, not standard AML program weaknesses.

D: Regulatory actions can be public and do pose reputational risk.

E: While transparency is sometimes required, this is not a universal regulatory response.

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.

When developing and maintaining AML policies, standards, and procedures, banks should rely on the National Risk Assessment, regulatory guidance or publications, and guidance issued by international bodies to ensure their frameworks align with both domestic and global best practices and risk considerations.

The Office of Foreign Assets Control (OFAC), part of the U.S. Department of the Treasury, is responsible for theadministration and enforcement of economic and trade sanctions. These sanctions are based on U.S. foreign policy and national security objectives and target:

Foreign countries and regimes

Terrorist organizations

Narcotics traffickers

Individuals and entities engaged in activities related to the proliferation of weapons of mass destruction

OFAC acts under various authorities, including national emergency powers granted by the President and specific legislation. One of its primary tools is theSpecially Designated Nationals(SDN) List, which identifies individuals and entities whose assets are blocked and with whom U.S. persons are generally prohibited from dealing.

It is important to note that OFAC is not responsible for designating jurisdictions as primary money laundering concerns (a task handled by FinCEN under Section 311 of the USA PATRIOT Act), nor does it manage trade agreements.

Public-Private Partnerships (PPPs)are collaborative initiatives involvinglaw enforcement, FIUs, and financial institutions. Their objective is to improve theefficiency and effectivenessof the fight against money laundering, terrorist financing, and other financial crimes bysharing both operational and strategic intelligence.

Option A – Exchange operational information between public authorities and obliged entities:

PPPs often facilitate real-time or near-real-time information sharing that supportsspecific investigations and the detection of suspicious activity, helping financial institutions respond quickly and accurately to ongoing threats.

Option B – Exchange strategic information between FIUs and obliged entities:

Strategic-level intelligence sharing helps financial institutionsunderstand typologies, risk trends, and evolving criminal methods, thereby strengthening their risk assessments and transaction monitoring frameworks.

Option Cis incorrect: Strategic information exchange between private institutions is limited and heavily regulated.

Option Dis incorrect: FATF does not collect or manage databases of suspicious activity reports; it sets standards and reviews national frameworks.

The CAMS 6th Edition specifically lists environmental crime as a predicate offense for money laundering. Environmental crimes include activities such as illegal logging, illegal mining, and illegal trade in wildlife.

“Environmental crime, including illegal logging and mining, is recognized as a predicate offense to money laundering. Such crimes often involve complex corporate structures to hide the illicit origin of the proceeds.”

(CAMS 6th Edition, Chapter: Risks and Methods of Money Laundering and Terrorist Financing; FATF Recommendations, Predicate Offenses)

Incorrect Options:

A: Trade-based ML refers to manipulating trade transactions, not the underlying crime.

B: Corruption may be involved, but the primary crime is environmental.

C: Illicit resource trade describes the act, but the official predicate crime category is environmental crime.

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.

C: Privacy coins (like Monero, Zcash) are designed to obscure transaction details, making tracing difficult.

D: Crypto-mixers (or tumblers) mix potentially identifiable cryptocurrency funds with others, obscuring the source.

“Privacy coins and mixing services are specifically cited as high ML/TF risk tools, enabling greater anonymity.”(CAMS 6th Edition, Cryptoassets ML/TF Risks; FATF, Virtual Assets Guidance)

A low number of sanctions screening alerts relative to the size and scope of operations may indicate overly restrictive or inappropriate monitoring parameters. Revisiting and adjusting the post-transaction monitoring system parameters and thresholds ensures that the system is calibrated to detect potential sanctions breaches effectively.

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.

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 review should prioritize politically exposed persons (PEPs) risk, as state ownership increases the likelihood of political connections, and anti-bribery and corruption risk, since such environments may have higher exposure to corrupt practices and misuse of influence.

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)

The compliance team should request further clarification to assess the AML risk appropriately. This includes understanding which cryptoassets were sold and whether the exchange used applies adequate due diligence. These details help determine the legitimacy of the source of funds and ensure compliance with AML requirements.

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.

Red flags include using personal accounts for business transactions (which can obscure fund tracing), preferring minimal direct interaction (potentially avoiding scrutiny), and unclear ultimate beneficial ownership (which can conceal the true controllers of the entity and facilitate illicit activity).

D: “Family members and close associates of PEPs are often used as intermediaries to launder the proceeds of corruption or conceal illicit assets.”(CAMS 6th Edition, Enhanced Due Diligence for PEPs; FATF Guidance on PEPs)

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.

An effective supervision regime includes both onsite and offsite reviews, cooperation on international and domestic levels, and access to a range of sanctions and outreach programs. This combination allows regulators to detect and address risks comprehensively while promoting compliance through engagement and enforcement.

Policies, controls, and procedures must be proportionate to the size and nature of the firm, approved by senior management, and regularly reviewed to ensure they remain effective in preventing and mitigating financial crime risk while aligning with regulatory expectations.

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.

Receiving funds from a decentralized mixer and using multiple incoming wires from different sources to purchase virtual currency are red flags, as they can indicate attempts to obscure the origin of funds and facilitate money laundering through virtual asset transactions.

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.

Scenario-based systems use algorithms to detect suspicious behaviors, such as transactions occurring at unusual times, those exceeding specified thresholds, or those taking place in locations inconsistent with a customer's typical activity. These anomalies help identify potential financial crime risks.

The United Nations Security Council (UNSC) is authorized under the UN Charter to imposebinding sanctions measureson member states. These sanctions may target countries, entities, or individuals and can include arms embargoes, travel bans, asset freezes, and restrictions on trade or financial services.

Statement Ais correct:

Circumventing or evading UNSC sanctionsmay constitute a criminal offenseif the jurisdiction has incorporated UN obligations into domestic law. While the UNSC does not directly impose criminal penalties,member states must implement these measures locally, andmany jurisdictions have lawsthat make such violations criminal acts.

Statement Bis incorrect:

The UNSC is empowered toimpose broad restrictions, includingtrade bans beyond arms, such as on luxury goods, fuel, or specific commodities. Therefore, the idea that it cannot prohibit exports beyond arms is inaccurate.

Statement Cis correct:

Member countries of the United Nations are expected to implement and enforce UNSC sanctions, in accordance with their obligations under the UN Charter (specifically Chapter VII). Countries are responsible for transposing these sanctions into their national legal frameworks.

Statement Dis incorrect:

Although member countries are required to enforce sanctions,not all countries automatically consider breaches a criminal offense. Whether a violation is criminal depends on how each country enacts UN sanctions domestically.

Effective oversight of transaction monitoring includes:

Periodic review of client profiles to ensure up-to-date information for high-risk clients (B):“Reviewing and updating customer profiles is essential to ensure that monitoring scenarios are based on current risk data.”(CAMS 6th Edition, Transaction Monitoring and Customer Due Diligence)

Periodic review of transaction monitoring scenarios and productivity to ensure appropriate AML typologies are reflected (D):“Firms should periodically review the parameters and output of transaction monitoring systems to ensure they continue to identify relevant ML/TF risks and typologies.”(CAMS 6th Edition, Monitoring and Surveillance)

Incorrect Options:

A: Cooperation with the legal team is important, but not a core strategy for monitoring governance.

C: SARs filed with FinCEN should not be withdrawn unless new evidence requires it; review should focus on process, not withdrawal.

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 combination of frequent address changes and a recent change in the ultimate beneficial owner raises potential red flags that warrant immediate investigation. To mitigate risk, the insurance company should investigate these changes and temporarily decline any payment or withdrawal instructions until the review is complete and appropriate steps are agreed upon. This ensures both regulatory compliance and protection against potential misuse of the policy.

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.

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.

Weak KYC policies and procedures represent a broader and more systemic risk specific to casinos and gambling. Without strong KYC, it becomes easier for individuals to engage in money laundering by exploiting anonymity and lack of oversight, regardless of transaction size or method.

Risks tied to the misuse of gaming accounts include transferring illicit funds between players undetected, structuring transactions to avoid reporting thresholds, and providing false personal information to evade KYC and regulatory oversight, all of which can facilitate money laundering and other financial crimes.

Unusual wire transfer transactions may include transfers in different currencies between accounts at different banks for the same client, which can be used to obscure fund flows, and incoming third-party transfers followed by real estate purchases, which may indicate layering and integration stages of money laundering. These patterns deviate from typical financial behavior and warrant closer scrutiny.

The CAMS 6th Edition clearly identifies a risk-based approach as the cornerstone of effective AML/CFT programs. Risk assessments should consider various risk factors that directly influence exposure to ML/TF.

Product risk (A): Certain products or services may present higher ML/TF risks, such as private banking, correspondent banking, or cash-intensive products.“Products and services offered, and their inherent risk levels, must be assessed as part of the risk-based approach.”(CAMS 6th Edition, AML Compliance Program, Risk Assessment)

Geographic risk (C): Jurisdictions where the customer operates or where transactions are conducted may present higher or lower risks due to factors such as weak AML regulations or high corruption.“Geographic risk considers where a customer is located and/or where transactions occur, referencing countries with increased risk, such as those identified by the FATF.”(CAMS 6th Edition, Risk Assessment Factors)

Customer risk (D): The type of customer, such as PEPs, non-residents, or companies with complex structures, may present higher ML/TF risks.“Customer risk assessment is based on the customer’s profile, activity, and ownership structure, and is a critical component in risk-based monitoring.”(CAMS 6th Edition, CDD/EDD)

Incorrect Options:

B (Credit risk): Related to creditworthiness, not ML/TF.

E (Liquidity risk): Refers to a firm’s ability to meet financial obligations; not an AML risk factor.

BSA/AML compliance staff should report to the compliance function or another second line of defense internal control function to maintain independence from business line management, ensuring objective oversight and effective compliance controls.

Large individual cash transactions pose the highest money laundering risk for money services businesses. Cash is difficult to trace and, when handled in significant amounts, can be used to introduce illicit funds into the financial system with minimal transparency.

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.

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.

A: “Effective training includes practical examples and use cases tailored to the business.”

B: “Firms must keep accurate records of all AML/CFT training, including completion logs.”

D: “Staff should be aware of the consequences of non-compliance with AML/CFT obligations.”(CAMS 6th Edition, AML/CFT Training and Awareness)

Incorrect:

C: Training should be tailored and role-specific.

E: Third-party trainers are not required for effective training.

Proliferation financingrefers to the act of providing financial services or funds for thedevelopment, acquisition, or delivery of nuclear, chemical, or biological weapons. The core threat involvesnetworks of individuals and entities using the financial systemto obtain sensitive technologies, materials, or knowledge forweapons of mass destruction (WMDs).

TheFinancial Action Task Force (FATF)identifies this as a major international security threat and requires institutions to assess and mitigate such risks.

AI and machine learning in adverse media screening can reduce human error through consistent analysis, automate the detection of new versus previously reviewed information, and process multiple languages and scripts, enabling broader and more accurate coverage than human review alone.

Verifying a customer’s identity is a fundamental CDD requirement under the FATF Recommendations, ensuring you know who your customer is.

Identifying the beneficial owner is required to uncover the natural persons ultimately controlling or benefiting from an account, closing the gap that would allow misuse of corporate vehicles.

The most effective strategy is to ensure that jurisdictional and other relevant risks are assessed through the Enterprise-Wide Risk Assessment (EWRA), and that any residual risks fall within the corporation’s defined risk appetite. This structured, risk-based approach supports informed decision-making and protects against reputational damage related to financial crime.