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

Virtual Asset Service Providers (VASPs) are considered higher-risk customers under FATF guidance due to their exposure to anonymity, speed of transactions, and cross-border activity. When onboarding a VASP, a financial institution must conduct a thorough risk assessment to determine whether the relationship aligns with its financial crime risk appetite.

Understanding the percentage of higher-risk clients served by the VASP is critical, as it indicates the level of exposure to illicit activity and the robustness of the VASP’s own risk management practices. A high concentration of higher-risk customers may significantly increase money laundering and terrorist financing risk.

Identifying which registered institutions act on behalf of the VASP, such as wallet providers or exchange operators, is also essential. Reliance on third parties introduces additional risk and requires assessment of those entities’ regulatory status and AML controls.

Finally, knowing who the VASP’s clients are, including the proportion of foreign versus domestic customers, is a core component of geographic and customer risk analysis. Cross-border exposure often elevates risk due to differing regulatory standards.

Data privacy practices and the use of central bank digital currencies, while relevant operational considerations, are not primary determinants of AML risk appetite decisions.

The first step in designing an effective controls framework using a risk-based approach is conducting a risk assessment. This identifies and evaluates inherent risks, providing the basis for determining which controls are necessary and how they should be prioritized.

Virtual Asset Service Providers (VASPs) are considered higher-risk customers due to their exposure to anonymity, speed, and cross-border transactions. FATF guidance highlights several red flags indicative of potential money laundering activity.

The use of shell companies to move funds into and out of a VASP is a strong indicator of attempts to conceal beneficial ownership and obscure transaction flows. Similarly, frequent use of mixers and tumblers is a well-recognized technique used to break transaction trails and hinder blockchain tracing.

Receiving funds from jurisdictions with weak AML frameworks significantly increases geographic risk, particularly when combined with other red flags.

By contrast, peer-to-peer infrastructure use and market volatility are inherent features of the virtual asset ecosystem and do not, on their own, indicate money laundering.

The most effective way to reduce irrelevant results in AI/ML-driven adverse media screening is to fine-tune the models to prioritize high-risk keywords and reliable sources. This improves precision by filtering out noise and directing focus toward content that is more likely to indicate financial crime risk.

Trust and company service providers (TCSPs) are recognized by FATF as higher-risk gatekeepers due to the nature of services they provide, which can be misused to facilitate money laundering.

The use of nominee directors can obscure beneficial ownership, allowing criminals to hide their involvement behind third parties. This lack of transparency is a significant AML risk.

The sale of ready-made or shelf companies, particularly through offshore intermediaries, enables rapid creation of legal entities with no operating history, which are frequently used in layering schemes.

Additionally, minimal face-to-face interaction—especially in offshore service models—reduces the ability to verify customer identity and intent, increasing impersonation and misuse risks.

TCSPs do not market themselves to criminals and are subject to AML obligations in most jurisdictions, making those options incorrect.

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.

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.

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.

High-risk customers present elevated money laundering and terrorist financing risks, requiring careful consideration before onboarding. FATF guidance emphasizes that higher-risk relationships demand stronger controls due to their increased vulnerability to misuse.

One key risk is the greater potential for laundering illicit proceeds. High-risk customers may operate in sectors, jurisdictions, or business models that are frequently abused for financial crime, increasing the likelihood that illicit funds could pass through the institution.

Another significant risk is the increased likelihood of involvement in financial crimes, either directly or indirectly. This may include exposure to corruption, fraud, sanctions evasion, or organized crime networks.

Enhanced due diligence is not a risk but rather a risk-mitigating control imposed by regulators. Reduced regulatory scrutiny is incorrect, as high-risk customers are subject to greater—not lesser—oversight.

The primary compliance concern is balancing compliance with the US Bank Secrecy Act (BSA) and OFAC sanctions while also ensuring adherence to EU AML directives and GDPR requirements. GDPR’s strict data protection rules can complicate cross-border information sharing, making it challenging to align compliance across multiple jurisdictions.

After identifying and rating inherent risks, the next key step in the risk assessment process is to evaluate the effectiveness of existing controls. This allows the organization to calculate the residual risk - i.e., the level of risk remaining after controls are applied.

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.

Risk assessment is the foundation of an effective AML compliance program. It enables an organization to identify, understand, and prioritize its exposure to money laundering and terrorist financing risks, which in turn informs the development of appropriate controls, including policies, procedures, and customer due diligence measures.

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).

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)

A key advantage of privacy enhancing technologies (PETs) in anti-money laundering is their ability to securely process data while it remains encrypted. This enables data analysis and collaboration without exposing sensitive information, helping to maintain privacy while still supporting financial crime detection.

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.

A robust transaction monitoring system is a core component of an effective Anti-Money Laundering (AML) and Counter-Financial Crime (AFC) program. Regulatory guidance from FATF and national supervisors emphasizes that the primary purpose of transaction monitoring systems is to detect unusual or suspicious activity by analyzing customer transactions and identifying anomalies or patterns that may indicate money laundering, terrorist financing, or other financial crimes.

These systems use predefined rules, thresholds, and increasingly advanced analytics to monitor transactions in real time or retrospectively. Alerts generated by the system are reviewed by compliance professionals, who determine whether further investigation or reporting is required.

While transaction monitoring systems may support the preparation of regulatory reports, such as SARs or CTRs, the actual filing of these reports typically requires human review and approval and is not the defining capability of the monitoring system itself. Features such as automatic document translation or integration of social media profiles are not considered core or necessary functions under AML regulatory expectations.

Therefore, the essential capability of a robust transaction monitoring system is its ability to monitor transactions and detect anomalies indicative of suspicious activity.

This scenario presents multiple classic money laundering red flags, particularly within the life insurance sector, which is recognized by FATF as vulnerable to misuse due to its investment and payout features.

The use of an offshore trust in a jurisdiction with no clear link to the customer raises concerns about concealment of beneficial ownership and layering. Criminals frequently use trusts and offshore structures to obscure the origin and destination of illicit funds.

The client’s request to split premium payments into multiple transactions to avoid bank charges is indicative of structuring, a known money laundering technique used to evade monitoring and reporting thresholds.

Furthermore, the lack of a legitimate source of wealth or income consistent with the high-value policy is a significant red flag. Purchasing high-value insurance products with no apparent financial means is a common placement method for laundering illicit proceeds.

While fraud or sanctions evasion could be relevant in other contexts, the combination of structuring, unexplained wealth, offshore structures, and non-residency most strongly indicates money laundering risk.

Policies outline the guiding principles and objectives of an organization’s AML framework, setting the tone for compliance. Procedures translate these policies into detailed, actionable steps that staff must follow. Both are essential for effective AML compliance.

Effective sanctions screening depends heavily on strong list management governance, as emphasized in sanctions compliance guidance from regulators such as OFAC and FATF.

First, restricting list modification to authorized individuals is critical. This ensures proper governance, auditability, and control over updates, reducing the risk of errors, unauthorized changes, or manipulation of screening outcomes.

Second, sanctions and watchlists may be sourced internally or from reputable third-party vendors. Many financial institutions supplement regulatory lists with internal watchlists, law enforcement requests, or commercially curated databases to enhance detection capabilities. This flexibility supports a risk-based approach.

Using only regulatory lists may be insufficient for identifying broader sanctions evasion risks, while applying all lists in all jurisdictions may lead to legal conflicts and over-screening. Institutions must tailor list usage based on jurisdictional applicability and legal requirements.

Together, controlled access and flexible list sourcing form the foundation of effective sanctions list management.

Using multiple sanctions lists ensures that financial institutions meet international regulatory obligations and can identify sanctions-related risks across different jurisdictions. This comprehensive approach strengthens compliance and reduces the likelihood of exposure to sanctioned individuals or entities.

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.

Real estate ML/TF risk is highest where transparency is low or the origin of funds is obscured:

Use of cash to purchase property (A):“All-cash transactions in real estate present a high ML risk, as they bypass traditional financial scrutiny and facilitate the placement of illicit funds.”(CAMS 6th Edition, Real Estate Money Laundering Risks)

Use of a company for the purchase of property (D):“Purchasing property through companies, especially shell companies, can conceal the beneficial owner and the true source of funds.”(CAMS 6th Edition, Real Estate ML/TF Risks; FATF, Real Estate Sector)

Incorrect Options:

B: Unlicensed agents may be risky, but the core risks are A and D.

C: Trusts may add complexity but are less common/high-risk than company structures.

E: Value manipulation is risky but less so than the above.

United Nations Security Council (UNSC) sanctions are a key international tool established under Chapter VII of the UN Charter. Their primary purpose is to maintain or restore international peace and security, not to punish states or provide economic advantage.

Sanctions may include asset freezes, travel bans, arms embargoes, or targeted measures against individuals and entities. These measures are designed to influence behavior, prevent escalation of conflict, and support diplomatic solutions.

The use of force is separate from sanctions and requires explicit authorization. Sanctions are not intended to be indefinite and are regularly reviewed and adjusted based on effectiveness and humanitarian considerations.

While sanctions may exert pressure on governments or actors, they are not intended as punitive measures but as preventive and corrective tools aligned with international law.

Key performance indicators (KPIs) are essential for evaluating the effectiveness and efficiency of transaction monitoring systems within an AML/CFT program. Regulators expect institutions to monitor how well their systems identify, prioritize, and resolve suspicious activity.

The number of alerts raised provides insight into system sensitivity and potential over- or under-alerting. Tracking alerts by region helps institutions identify geographic risk concentrations and emerging threats. The average time to review an alert measures operational efficiency and whether investigations are conducted promptly, as required by regulatory expectations.

Hiring timelines and transaction volumes by top customers are operational or business metrics and do not directly assess transaction monitoring effectiveness.

Before opening for business, a bank must have independent compliance testing to ensure controls are functioning, qualified staff who understand AML/CFT requirements, and documented policies and procedures to guide day-to-day compliance. These are foundational elements of an effective AML/CFT framework.

Trust and Company Service Providers (TCSPs) pose the greatest financial crime risks when they use trusts to obscure beneficial ownership, promote complex corporate structures that make tracing ownership difficult, and establish shell companies that can be used to hold and move illicit funds. These activities can facilitate money laundering, tax evasion, and other financial crimes by concealing the true origin and control of assets.

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.

Technology plays a critical role in strengthening AML/CFT programs by improving efficiency, consistency, and scalability. Regulators encourage the responsible use of technology while maintaining governance and oversight.

One major benefit is processing large volumes of data efficiently, helping institutions eliminate investigative backlogs and manage increasing transaction volumes. Technology also automates repetitive tasks, reducing human error and improving data accuracy, allowing compliance professionals to focus on higher-value investigative work.

Technology does not eliminate privacy concerns, and front-end search tools alone are not sufficient to drive effectiveness. Human oversight remains essential for decision-making, investigations, and regulatory reporting.

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.

While regulatory compliance, cost efficiency, and operational considerations are important, the primary objective of AML/CFT measures is to reduce and manage the risks and threats of financial crime. FATF emphasizes that effectiveness should be measured by outcomes, not merely by technical compliance.

An AML/CFT framework may fully comply with laws and still be ineffective if it fails to detect, deter, or disrupt money laundering and terrorist financing. Regulators increasingly focus on whether systems and controls actually identify suspicious activity, prevent misuse of the financial system, and support law enforcement efforts.

Minimizing operational burden and controlling costs are secondary considerations and must not compromise risk mitigation. A cost-effective system that fails to detect financial crime would not meet regulatory expectations.

Therefore, the true measure of effectiveness lies in how well systems and controls mitigate financial crime risks and threats in practice.

Financial Intelligence Units (FIUs) play a central role in national and international AML/CFT frameworks. According to FATF standards, FIUs are responsible for the receipt, analysis, and dissemination of financial intelligence related to suspected money laundering, terrorist financing, and predicate offenses.

One core function of an FIU is receiving and analyzing SARs submitted by financial institutions and other obliged entities. Through analysis of reported information, FIUs identify suspicious patterns, trends, and networks that may indicate financial crime.

Another key function is disseminating intelligence and typologies to competent authorities and, where appropriate, to the private sector. This includes sharing insights on emerging risks, new money laundering methods, and evolving threat trends, which enhances system-wide financial integrity.

FIUs do not design financial products for institutions, nor do they supervise AML programs—that responsibility lies with AML supervisory authorities. Their role is intelligence-focused rather than regulatory or commercial.

The UN Security Council has the authority to impose sanctions specifically to maintain or restore international peace and security.

Artificial intelligence can significantly enhance efficiency when reviewing large volumes of privacy and data protection regulations across jurisdictions. However, regulators consistently emphasize that AI outputs must be subject to human oversight and validation.

AI-based systems may identify relevant laws, regulations, and obligations, but generated results still require expert assessment to confirm completeness, applicability, and relevance to a specific institution’s business model, jurisdictions, and data processing activities. Legal interpretation remains a human responsibility.

Training AI solely on rule content without understanding how models function undermines governance expectations. Additionally, analyzing a large volume of rules does not guarantee accuracy or applicability. AI systems can be trained to identify jurisdiction-specific rules, but they cannot independently determine legal applicability without contextual judgment.

Therefore, human review remains essential, making option A the correct answer.

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)

Global organizations must ensure their policies and procedures comply with local laws and regulations in each country where they operate, even when maintaining group-wide consistency. Relying solely on international or U.S. standards does not ensure compliance with all local requirements, which may be more stringent or specific.

“A global group-wide program should ensure adherence to local AML and sanctions laws and regulations in every jurisdiction in which it operates. Local adaptation of policies is essential to address jurisdiction-specific risks and legal requirements.”

(CAMS 6th Edition, International AML/CFT Standards; FATF Recommendations 18, 35; EU & US Sanctions Regulations)

Customer onboarding is a critical AML/CFT process that must balance regulatory compliance with customer experience. Excessive friction can lead to customer dissatisfaction and abandonment.

Implementing internal or external tools—such as digital onboarding platforms, document collection tools, and workflow automation—can significantly streamline information gathering and reduce delays while maintaining compliance standards.

Additionally, consistent training of all employees involved in onboarding ensures that information requests are clear, consistent, and proportionate. Well-trained staff reduce rework, confusion, and unnecessary follow-ups, improving customer trust and efficiency.

Restricting decision-making to managers can slow processes, and delaying updates to processes reduces adaptability to evolving risks and regulatory expectations.

A Financial Intelligence Unit (FIU) functions as the central hub for receiving and analyzing suspicious activity reports and can obtain additional information from reporting entities to support law enforcement in investigating and combating financial crimes.

A national risk assessment can identify high-risk sectors requiring enhanced due diligence and guide resource allocation to mitigate financial crime risks effectively, helping organizations align their risk-based approach with national priorities and threats.

FIUs rely on formal cooperation mechanisms to exchange information lawfully and efficiently across borders. One of the most widely used mechanisms is a Memorandum of Understanding (MOU) between FIUs in different jurisdictions.

MOUs establish the terms, scope, confidentiality protections, and procedures for sharing financial intelligence. They enable FIUs to exchange information directly, quickly, and securely while respecting data protection and domestic legal requirements. This structure significantly reduces bureaucratic delays and supports effective cross-border investigations.

FATF and regional bodies are standard-setters and evaluators, not operational information-sharing hubs. The Wolfsberg Group is a private-sector association and does not facilitate FIU-to-FIU communication. MLATs are used primarily by law enforcement and judicial authorities for criminal proceedings and arrests—not for FIU intelligence exchange.

Therefore, MOUs are the correct and most appropriate mechanism for FIU cooperation.

Appointing individuals to serve in official capacities poses a higher money laundering risk because it can be used to obscure the true beneficial ownership and control of the company, making it easier to conceal illicit activities or the identity of those directing the business.

Casinos are recognized as high-risk entities under AML/CFT frameworks due to their exposure to large cash volumes and convertible instruments such as chips. Regulators and FATF guidance highlight minimal or no gaming activity combined with rapid cash-out as a major red flag.

In this scenario, the player purchases a large amount of chips using multiple funding methods, including an international wire transfer, does not engage in any gambling, and then immediately cashes out. This behavior is consistent with placement and layering techniques, where a casino is used as a pass-through to legitimize illicit funds.

The absence of gaming activity strongly suggests that the intent was not entertainment but financial manipulation. Casinos are frequently misused for this exact purpose due to their ability to convert cash into “winnings.”

The other scenarios describe activity that may be higher risk but are consistent with legitimate casino behavior when properly documented.

A: Selling assets at a significant loss, especially shortly after purchase, is a classic red flag for asset laundering and value manipulation, which can be used to disguise the true nature of proceeds.

C: Transactions involving individuals from high-risk jurisdictions, as identified by the EU and FATF, warrant heightened scrutiny due to increased ML/TF risk.(CAMS 6th Edition, Red Flags for Complex Asset Transactions; EU List of High-Risk Third Countries)

B and D may contribute to complexity but are not the primary red flags in this scenario.

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.

Public-private partnerships help develop a culture of compliance across sectors and improve the quality and quantity of data through information sharing, enhancing the collective ability to detect and prevent financial crime.

Money services businesses (MSBs) are considered higher-risk customers under AML/CFT frameworks due to their role in facilitating payment flows and fund transfers. FATF guidance highlights specific characteristics that elevate financial crime risk.

One significant risk arises when MSBs process the activity of their customers’ customers. This indirect exposure reduces transparency and makes it more difficult for the financial institution to identify the true originators and beneficiaries of transactions, increasing vulnerability to money laundering and terrorist financing.

Another major risk is frequent cross-border transfers. International transactions introduce geographic risk, particularly when funds move through or to jurisdictions with weaker AML controls or higher financial crime prevalence.

While high volumes of low-value transactions can present monitoring challenges, this characteristic alone does not necessarily represent the greatest risk without additional factors. Registration requirements are a regulatory control, not a risk indicator.

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.

Artificial intelligence (AI) enhances transaction monitoring by complementing or improving upon traditional rules-based systems. Regulators recognize that AI can strengthen AML programs when deployed with appropriate governance and oversight.

One key benefit is the ability to identify changes in customer behavior over time. AI models analyze historical and real-time data to detect deviations from expected patterns, allowing institutions to reassess customer risk more dynamically and accurately.

AI can also generate predictive customer risk scores, helping institutions prioritize alerts and focus investigative resources on higher-risk customers and activities. This improves efficiency and effectiveness while supporting a risk-based approach.

AI is designed to reduce false positives, not increase them, and bias must be carefully managed during training through governance and data controls.

Open-source intelligence (OSINT) is widely used in AML/CFT investigations to support customer due diligence, adverse media screening, and financial crime analysis. However, because OSINT sources vary widely in quality and reliability, regulators and investigative best practices emphasize verification and corroboration.

The most effective way to ensure the reliability of open-source information is cross-checking information across multiple independent sources. Corroboration helps confirm accuracy, reduce the risk of misinformation, and identify inconsistencies or bias. This approach is especially important when using online media, public records, blogs, or social media content.

Excluding entire categories of sources—such as the dark web or social media—may result in missed intelligence and does not ensure reliability. Similarly, relying only on international news agencies limits coverage and may overlook relevant local or niche reporting.

Therefore, triangulation through multiple sources is the most effective and regulator-aligned method for validating OSINT.

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.

Correspondent banking relationships are recognized as higher risk under FATF guidance primarily because transactions are cross-border and conducted on behalf of third-party customers.

In correspondent banking, a respondent bank may process transactions for customers that the correspondent bank does not have a direct relationship with. This reduces transparency and limits the correspondent’s ability to fully assess customer identity, beneficial ownership, and transaction purpose.

While correspondent transactions may involve high-risk jurisdictions, this is not always the case. They are not anonymous by design, and payment messaging standards often require significant information. However, the indirect customer relationship and cross-border nature introduce complexity, jurisdictional risk, and reliance on the respondent bank’s controls.

Therefore, third-party and cross-border exposure is the key driver of heightened risk.

Adverse media screening seeks to identify reputational or financial crime risk by:

B: Identifying links to criminal activity or sanctions.

C: Monitoring regulatory actions and updates for risk associations.

D: Regularly scanning news and public records for negative information.

“Adverse media screening involves collecting and reviewing publicly available information, news, and regulatory actions to detect links to criminal activity or reputational risks.”

(CAMS 6th Edition, Adverse Media Screening; FATF Guidance)

Incorrect:

A and E: Customer sentiment and credit scores are not core to adverse media screening.

Predicate offenses are crimes that generate proceeds which may subsequently be laundered. FATF standards and national AML laws define a wide range of serious crimes as predicate offenses.

Bribery and corruption are among the most common predicate offenses, often involving large illicit payments that require laundering to disguise their origin. Fraud, including financial, consumer, and corporate fraud, is another primary source of illicit proceeds and is universally recognized as a predicate offense.

Organized crime and racketeering encompass coordinated criminal activities designed to generate ongoing illegal income, making them central predicate offenses under AML frameworks.

While arson may be considered a serious crime in some jurisdictions, and assault is generally not associated with financial gain, AML regimes focus primarily on crimes that generate substantial proceeds. Therefore, bribery, fraud, and organized crime are the most consistently recognized predicate offenses across jurisdictions.

The Wolfsberg Group and Transparency International are non-governmental organizations that provide information and guidance on AML/CFT matters, helping institutions and policymakers strengthen financial crime prevention practices.

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.

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.

In situations involving significant AML concerns, especially with high-risk clients, thecompliance officer must follow proper escalation procedureswithin the institution. The appropriate course of action is toescalate the matter to a senior governance body, such as ahigh-risk client committee, which is typically tasked with balancing AML risk against business considerations.

Unilateral offboarding (Option B)may violate internal protocols.

Persuading the relationship manager (Option C)bypasses formal governance.

Delaying action (Option D)risks further exposure to regulatory or reputational damage.

This escalation ensuresdocumented risk-based decision-makingand demonstrates to regulators that the institution appliesstructured and objective AML governance.

Public-private partnerships (PPPs) are a key component of modern AML/CFT frameworks and are strongly encouraged by FATF and national regulators. Their primary benefit lies in enhancing timely and effective information sharing between financial institutions, regulators, law enforcement, and financial intelligence units (FIUs).

Through PPPs, authorities can share typologies, red flags, and emerging threat intelligence, while private institutions contribute operational insights derived from real transaction data. This rapid exchange of information on risks, high-risk activities, and suspicious actors significantly improves the detection and prevention of money laundering and terrorist financing.

PPPs do not exist to source staffing resources, provide salaries, or ensure basic understanding of regulatory concepts such as PEPs, which are already addressed through standard AML requirements. Their true value is the speed, quality, and relevance of shared intelligence, allowing participants to respond more effectively to evolving financial crime threats.

Case notes should document who made the decision and the rationale for not filing the SAR to ensure transparency, support auditability, and demonstrate compliance with regulatory expectations.

UN sanctions regimes are not punitive but aim to:

B: “Support peaceful resolution of conflicts.”

D: “Deter non-democratic and unconstitutional changes of government.”

E: “Promote respect for human rights and humanitarian law.”(CAMS 6th Edition, United Nations Sanctions; UN Security Council Mandates)

Incorrect:

A: The UN does not impose sanctions to force regime type.

C: Sanctions are not for punishing weak AML controls.

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)

The risk-based approach (RBA) is a foundational principle of FATF standards. It requires countries, regulators, and financial institutions to identify, assess, and understand their money laundering and terrorist financing risks.

Once risks are understood, entities must apply proportionate mitigation measures. Higher risks require stronger controls, while lower risks may justify simplified measures. However, no risk is ignored or exempted from mitigation.

Regulators do not expect all residual risks to be reduced to low; rather, risks must be managed within an acceptable risk appetite. Resource allocation under an RBA prioritizes AML/CFT activities, not unrelated tasks.

Therefore, the correct definition of an RBA focuses on understanding and managing risk proportionately.

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.

For multinational financial institutions, regulatory expectations are clear: institutions must comply with all applicable laws and regulations in each jurisdiction where they operate or where a transaction has regulatory touchpoints.

In this case, the transaction is subject to both U.S. and EU AML/CFT frameworks, including BSA reporting obligations, OFAC sanctions screening, 6AMLD requirements, and EBA supervisory expectations. Selecting only one regulatory regime would expose the institution to compliance failures and enforcement risk.

A dual-compliance approach ensures that reporting, sanctions screening, customer due diligence, and record-keeping obligations are met in both jurisdictions. This approach aligns with FATF principles on cross-border compliance and consolidated supervision.

Deferring to the “most stringent” regime is not sufficient, as different rules may apply to different aspects of the transaction. Therefore, simultaneous compliance is required.

Fuzzy matching is a critical technique used in name screening systems to identify potential matches where names are not spelled identically. Regulators recognize that sanctions, PEP, and watchlist screening must account for variations in spelling, transliteration, abbreviations, and phonetic differences.

Fuzzy matching algorithms compare names based on similar spelling patterns, phonetics, or character arrangements, allowing institutions to detect matches that exact matching would miss. This is especially important for names originating from different languages or alphabets.

Exact matching alone is insufficient for effective sanctions screening, as it would fail to capture common variations. While machine learning may enhance screening systems, fuzzy matching itself does not rely on predictive modeling.

Therefore, fuzzy matching improves detection effectiveness while supporting regulatory expectations for robust screening controls.

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.

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)

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.

Financial institutions should have a standardized process for terminating customer relationships, including conducting risk assessments and documenting the reasons for termination. A final review of the customer’s transaction history helps address any outstanding concerns or unresolved issues. Keeping thorough records of the termination process ensures compliance and provides documentation in case of any future inquiries or disputes.

Corruption risks in the supply of goods and services often arise when contractors receive preferential treatment, enabling inflated margins, and when procurement processes lack sufficient oversight, making it easier for bribes or kickbacks to influence tender outcomes.

Open-source tools offer cost-effective access to diverse data sources, making them valuable for financial crime investigations. They also support partial automation of data collection and analysis, reducing manual effort and improving efficiency in identifying suspicious patterns or links.

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.

Application Programming Interfaces (APIs)are tools that enableinterconnectivity and data exchangebetween different software applications. In AML contexts, APIs are commonly used tointegrate third-party systems, such as screening tools, customer databases, and transaction monitoring platforms, ensuring real-time and accurate flow of information.

This technological capability supports enhancedautomation, agility, and efficiencyin AML processes.

A key benefit of machine learning in identifying suspicious transactions is its adaptability to new anti-financial crime typologies through continuous model training, enabling the system to evolve with emerging threats and patterns.

Conceptual soundness validation is a foundational element of AML model governance and is emphasized in regulatory guidance on model risk management. It focuses on whether the design, logic, assumptions, and methodology of a model are appropriate for its intended purpose.

Validating conceptual soundness ensures that the model’s underlying framework makes sense for identifying money laundering and terrorist financing risks. This includes evaluating scenario logic, risk factors, thresholds, segmentation, and assumptions used in detection.

Statistical validation and performance testing are separate steps that assess outcomes and predictive power, while technology compatibility relates to system implementation rather than conceptual design. Alignment with regulatory guidance is important, but it is not the core objective of conceptual soundness testing.

Regulators expect institutions to demonstrate that their AML models are fit for purpose before relying on them operationally.

Effective customer due diligence relies on authoritative, reliable, and relevant external data sources, as outlined in FATF standards and national AML regulations.

Sanctions lists, such as those maintained by OFAC, the EU, and the UN, are mandatory screening sources to ensure compliance with sanctions regimes. Registers of stolen or forged documents, where available, help detect identity fraud and false documentation during onboarding.

Additionally, beneficial ownership registers and adverse media sources are essential for identifying hidden ownership structures, corruption exposure, and reputational risk.

Customer reviews and lifestyle assessments from social media are not considered reliable or appropriate primary sources for AML screening due to privacy, accuracy, and governance concerns.