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

Question 1

Which non-governmental bodies typically issue information and guidance related to AML/CFT issues? (Choose two.)

Options:

A.

Wolfsberg Group

B.

Transparency International

C.

Financial Action Task Force (FATF)

D.

Tax Justice Network

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Question 2

A compliance officer is developing management reporting information to provide leadership with insights into the financial crime risk related to an institution's customer population.

Which of the following is a key risk indicator to include in the reporting to allow leadership to monitor whether there are any key changes to the inherent risk of the customer population? (Choose two.)

Options:

A.

Percentage of regulatory reports for high-risk customers not completed within the required regulatory deadlines

B.

Percentage change of transaction monitoring alerts escalated for investigation compared to the previous quarter

C.

Percentage of customers for whom onboarding verification was not completed within KYC policy service-level agreement (SLA) requirements

D.

Number and percentage of senior politically exposed persons (PEPs) who were onboarded in the past quarter compared to all active customers

Question 3

Which risks inherent to real estate sector carry the highest AML/CFT risk? (Select Two.)

Options:

A.

Use of cash to purchase property

B.

Unlicensed real estate agents acting as front companies

C.

Use of a registered trust for the purchase of property

D.

Use of a company for the purchase of property

E.

Manipulation of the value of a property

Question 4

The primary objectives of the United Nations in developing sanctions regimes include: (Choose three.)

Options:

A.

to force developing nations to adopt liberal or substantive democracies.

B.

to support governments and regimes in the peaceful resolution of conflict.

C.

to punish governments for having weak financial crime controls.

D.

to deter non-democratic and non-constitutional changes within countries.

E.

to support the protection of human rights.

Question 5

When considering purchasing AFC tools from a vendor to implement into the customer lifecycle, which of the following measures should be taken during the process? (Choose two.)

Options:

A.

Ensuring the tools are compatible and integration with current systems is possible

B.

Assessing whether internal staff members can provide training on the tools

C.

Assessing the cost of implementation and cost of maintaining the tools

D.

Basing business requirements on the features offered by the vendor's tools

Question 6

Non-compliance with relevant anti-money laundering laws and regulations can result in: (Select Two.)

Options:

A.

increased reputation risk.

B.

inclusion on the UN Consolidated List.

C.

civil and criminal penalties

D.

delisting of public filing status.

Question 7

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

Options:

A.

Accounting

B.

Model risk management

C.

Technology solutions and IT security

D.

Marketing

E.

Fraud risk management

Question 8

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

Options:

A.

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

B.

Natural persons having more than one insurance policy

C.

High-premium life insurances that provide high payouts

D.

Regularly switching policies and accepting penalties

E.

Beneficiary payouts to elderly people

Question 9

The purpose of a risk appetite statement is to:

Options:

A.

clearly define the level of risk exposure to financial crime which a financial institution is willing to take.

B.

help investors understand the risk a financial institution is willing to take.

C.

help customers understand which financial institutions may be willing to bank their business.

D.

eliminate high-risk business types from a financial institution.

Question 10

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

Options:

A.

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

B.

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

C.

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

D.

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

Question 11

When deciding on the fuzzy matching threshold for sanctions screening, consideration should be given to:

Options:

A.

the operational burden of dealing with potential matches.

B.

the value of fines for non-compliance.

C.

the experience of the team dealing with potential matches.

D.

whether the data to be screened is reliable and verified.

Question 12

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

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

Options:

A.

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

B.

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

C.

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

D.

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

Question 13

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

Options:

A.

Account opening staff

B.

Middle management

C.

Senior management

D.

First-level management

Question 14

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

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

Options:

A.

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

B.

approval by money-laundering reporting officer for the proposal.

C.

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

D.

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

E.

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

F.

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

Question 15

What is the relationship between the EU Anti-money Laundering Directives (AMLD) and local anti-money laundering (AML) regulations in European Union (EU) member states, in terms of their relevance for, applicability to, and impact on EU banks? (Select Two.)

Options:

A.

The EU AMLD and local AML regulations are separate and unrelated legal frameworks.

B.

The EU AMLD and local AML regulations must have identical requirements.

C.

Local AML regulations may impose additional or more stringent requirements than the EU AMLD.

D.

The EU AMLD take precedence over local AML regulations.

E.

Local AML laws and regulations override the requirements of the EU AMLD.

F.

The EU AMLD provide a framework that member countries must implement through local AML regulations.

Question 16

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

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

Options:

A.

Money laundering typologies applicable to monetary instrument reporting

B.

Applicable AML laws and regulations

C.

Regulatory exam best practices

D.

Money laundering typologies applicable to corporate loans

Question 17

Which of the following are common indicators of possible money laundering within the securities industry? (Select Two.)

Options:

A.

Receiving securities into an existing brokerage account following the death of a spouse

B.

Allowing fixed income securities to mature

C.

Using brokerage accounts like deposit accounts

D.

Engaging in transactions involving nominees or third parties

Question 18

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

Options:

A.

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

B.

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

C.

transaction structures that appear unnecessarily complex

D.

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

E.

invoices with prices that are much higher than market price

F.

fluctuations in the pricing of standard goods and services

Question 19

According to the Financial Action Task Force (FATF). potential risk indicators related to money laundering proceeds from environmental crimes include. (Select Two.)

Options:

A.

waste management sector companies based in high-risk jurisdictions with payments or trade invoices tor types of waste aligned with those they are authorized to process.

B.

frequent payments from companies in the logging. milling, or waste trade sectors to individuals or beneficiaries unrelated to the legal parson activity or business.

C.

unexplained wealth and cash transfers involving senior officials or politically exposed persons for their family members) with a position of responsibility related to the management or preservation of natural resources.

D.

small cash transfers from cash-Intensive businesses to beneficiaries in areas known as a source of gold mining, illegal logging, and Illegal land clearing.

Question 20

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

Options:

A.

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

B.

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

C.

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

D.

A patron routinely places multiple bets on the same sporting events

Question 21

The US Department of the Treasury notes that which of the following represent high money laundering risk when de-risked from traditional financial institutions (FIs)? (Choose two.)

Options:

A.

Money services business (MSB)

B.

Multinational corporations

C.

Individual foreign customers

D.

Non-profit organizations with international operations

Question 22

What is the first step that an investigator should take when beginning a financial investigation into a potential suspicious activity?

Options:

A.

Determining whether the potential suspicious activity is consistent with the customer's transactional behavior, nature of business, and occupation

B.

Contacting the country's financial intelligence unit's (FIU's) officers to seek advice on whether the potential suspicious activity is indeed a suspicious activity

C.

Gathering and assessing internal sources of information, including information obtained from the customer, transactions, and value and volume

D.

Identifying and reviewing external information, including online presence, customer-related entities, and relevant media

Question 23

Which action should a financial institution take when it receives a grand-jury subpoena regarding a customer?

Options:

A.

Make copies of the customer's documents and submit the originals to the enforcement agency

B.

Notify the customer being investigated before submitting documents

C.

Keep the customer's accounts open at the enforcement agency's verbal request

D.

Have the institution's assigned legal counsel review the subpoena

Question 24

Which regulation permits financial institutions, upon providing notice to the US Department of the Treasury, to share information with one another in order to identify and report activities that may involve money laundering or terrorist activity to the federal government?

Options:

A.

Regulation (EU) 2024/1624 of the European Parliament

B.

Collaborative Sharing of Money Laundering/Terrorism Financing (ML/TF) Information & Cases (COSMIC)

C.

USA Patriot Act Section 314(a)

D.

USA Patriot Act Section 314(b)

Question 25

Which principle about safeguarding privacy and data should an auditor adhere to when performing an AML investigation?

Options:

A.

AML and Data Protection Privacy laws should not be mutually exclusive.

B.

During evidence gathering, privacy laws are less important than local AML laws.

C.

Terrorist financing is more relevant in the context of data protection and supersedes laws.

D.

Countries should clarify where AML and Data Protection Privacy laws are not balanced.

Question 26

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

Options:

A.

Concealing sources of funds

B.

Allowing for third-party custody safekeeping of funds

C.

Adding a layer of anonymity to transactions

D.

Concealing true legal and beneficial owners

E.

Establishing escrow accounts for real estate transactions

Question 27

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

Options:

A.

Devaluation

B.

Smart contract vulnerabilities

C.

Potential for anonymity

D.

Global reach

E.

High transaction fees

F.

Use to layer illicit funds

Question 28

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

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

Options:

A.

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

B.

Periodic review of client profiles to ensure that the most up-to-date information is on file for high-risk clients in line with the bank's internal policies and procedures

C.

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

D.

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

Question 29

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

Options:

A.

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

B.

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

C.

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

D.

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

E.

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

Question 30

Which of the following are benefits of the latest KYC solutions, including but not limited to digital onboarding, eKYC, digital identity, facial recognition, liveness checks, biometrics, and geolocation? (Choose three.)

Options:

A.

Guaranteeing 100% accuracy in regulatory compliance across all jurisdictions

B.

Improving customer satisfaction by offering personalized recommendations

C.

Reducing identity theft effectively

D.

Providing reliable customer authentication to enhance trust

E.

Decreasing the time required for customer authentication

Question 31

Having a risk-based approach is central to a financial institution understanding the money laundering and terrorist financing risk to which they are exposed. The development of a money laundering and terrorist financing risk assessment is a key starting point.

Commonly used risk factors include. (Select Three.)

Options:

A.

product risk.

B.

credit risk.

C.

geographic risk.

D.

customer risk.

E.

liquidity risk.

Question 32

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

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

Options:

A.

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

B.

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

C.

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

D.

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

E.

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

Question 33

The Financial Action Task Force (FATF) routinely publishes a catalogue of jurisdictions requiring enhanced monitoring which is commonly called the:

Options:

A.

red notice

B.

white list

C.

yellow notice

D.

grey list

Question 34

A long-term client of an insurance company makes changes to a policy that require payment of an additional lump sum. The amount payable is high, though within the client's means based on the KYC information collected. The payment is made via a company in another jurisdiction that is known to have lax AML controls.

Which indicator of suspicious activity is present?

Options:

A.

A long-term client wants a change to a policy that is already in force

B.

The payment was made via a company that appears to be owned and controlled by the client being insured

C.

The additional premium payable appears to be within the client's means based on the KYC information collected

D.

The payment was made via a company in a jurisdiction known to have lax AML controls

Question 35

Which red flags could indicate increased terror financing and money laundering risks related to cultural objects? (Select Three.)

Options:

A.

Engagement of third-party art advisors as representatives at art auctions

B.

High-quality single pieces of significant value sold on social media platforms

C.

Use of art and antiquity experts to verify an item's authenticity

D.

Paying fair market value or premium prices for valuable art, gems, or precious metals at auction

E.

Use of art storage facilities located in tax-free zones

Question 36

According to the Financial Action Task Force (FATF) Recommendation regarding "tipping off," which of the following statements accurately describes the obligations of reporting entities?

Options:

A.

Reporting entities are prohibited from disclosing to clients or third parties that a suspicious activity report (SAR) has been filed or that an investigation is ongoing

B.

Reporting entities can share general information about suspicious activities internally within the organization without compromising confidentiality

C.

Reporting entities must inform their clients if a suspicious activity report (SAR) has been filed, as part of maintaining transparency in customer relations

D.

Reporting entities are allowed to discuss suspicious activities with clients if it helps clarify a situation before submitting a suspicious activity report

Question 37

A bank in the Netherlands has been requested to share information about a series of transactions and related customers with a bank in Italy. Both banks are subject to European Union jurisdiction.

Which factor is the most important to consider before the Dutch bank shares the requested information with the Italian bank?

Options:

A.

The Dutch bank should limit any information sharing to what is necessary, reasonable, and proportionate, in line with applicable laws and regulations

B.

The Dutch bank's legal obligations to protect customer privacy and bank secrecy prohibit it from sharing any such information

C.

The Dutch bank should require a production order from the Italian bank and receive approval from its legal department before sharing the requested information

D.

The need to fight financial crime outweighs the EU's data protection and privacy regulations

Question 38

A National Risk Assessment (NRA) can impact a financial institution's (Fl's) risk-based approach to anti-money laundering and terrorism financing by:

Options:

A.

dictating what predicate offences must be considered in the Fl's risk assessment.

B.

providing guidance on the types of customers and transactions that pose the highest risk.

C.

defining exactly what policies and procedures must be implemented.

D.

determining the maximum fines that can be imposed for AML violations.

Question 39

Which practices should financial institutions (FIs) adopt for the process of terminating customer relationships? (Choose three.)

Options:

A.

Utilizing a flexible communication style that adapts to different customer situations during the termination process

B.

Implementing a standardized procedure for customer termination that includes risk assessments and necessary documentation

C.

Performing a final review of a customer's transaction history and records to address any unresolved issues prior to termination

D.

Keeping records of the termination process, including the justification for the decision and any correspondence with the customer

E.

Notifying the customer of the termination decision only after completing the termination process to prevent possible disputes

Question 40

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

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

Options:

A.

Trade-based

B.

Check Kiting

C.

Microstructuring

D.

Structuring

Question 41

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

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

Options:

A.

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

B.

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

C.

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

D.

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

Question 42

The financial industry relies heavily on rules-based approaches to transaction monitoring to detect suspicious activities.

Scenario-based systems use technology and algorithms to identify: (Choose three.)

Options:

A.

fraudulent identities involving stolen or manufactured identification.

B.

suspicious behavior involving a transaction that occurs at an unusual time of day.

C.

hidden beneficial owners.

D.

transaction patterns involving transactions that exceed a certain dollar amount.

E.

anomalies involving a transaction that occurs in a location far away from the customer's usual spending patterns.

Question 43

A real estate buyer purchases multiple high-value properties in cash through a series of transactions in a short period of time and without any clear economic justification.

Which of the following is the most likely money laundering risk associated with this behavior in the real estate sector?

Options:

A.

The buyer is using high-value real estate transactions to obscure the origin of the funds.

B.

The buyer is quickly diversifying their investment portfolio through structuring payments in order to take advantage of the liquidity of cash transactions in real estate.

C.

The buyer is capitalizing on favorable market conditions and using cash purchases to outbid competitors in a competitive real estate market using insider information.

D.

The buyer is a real estate developer acquiring multiple properties for a potential redevelopment project with a business partner located in a high-risk jurisdiction.

Question 44

Criminals may misuse financial statements prepared by accountants to hide illicit assets.

Which of the following scenarios poses the greatest risk of financial statement manipulation by criminals?

Options:

A.

A lack of professional body oversight or required use of accounting and auditing standards in the country of incorporation of the entity

B.

Criminals posing as individuals seeking financial advice to place assets out of reach to avoid future liabilities

C.

Incomplete records being provided during bookkeeping, making them difficult to audit

D.

Accountants being used as intermediaries to introduce criminals to financial institutions

Question 45

Which of the following is a primary objective of public sector groups in the fight against money laundering?

Options:

A.

Advising private financial institutions on how to enhance their profitability through AML efforts

B.

Establishing and enforcing legal frameworks to detect, prevent, and punish money laundering and related financial crimes

C.

Providing funding to private and non-governmental organizations (NGOs) for the development of advanced compliance technologies

D.

Acting as intermediaries between private sector firms and non-governmental organizations (NGOs) to streamline AML compliance programs

Question 46

An AML analyst at a bank is investigating cases triggered by transaction monitoring alerts.

Which circumstances might cause the analyst to suspect a case involves terrorist financing? (Select Two.)

Options:

A.

Transactions involving non-profit organizations with no internet presence

B.

Small dollar payments sent to crowdfunding initiatives with detailed descriptions of the project being financed

C.

Transactions involving structured currency deposits below the reporting threshold to avoid paying taxes

D.

Small dollar payments sent to higher-risk jurisdictions with no prior history

E.

Transactions involving domestic non-profit organizations providing charitable aid to refugees from higher-risk countries

Question 47

A compliance officer is completing a case and has determined that the events do not merit filing a suspicious activity report (SAR).

Which of the following should be included in the case notes to justify not filing a SAR? (Choose two.)

Options:

A.

Who made the decision not to file the SAR

B.

Why the officer deemed that the case did not merit filing a SAR

C.

How much money was involved in the case

D.

How the money flowed through the institution

E.

When the unusual activity occurred

Question 48

Which action could be taken by an organization to better understand the threats faced from proliferation financing?

Options:

A.

Work with the front-line to understand their strategic growth targets specifically aimed at increasing their market share around military technology and dual-use products

B.

Review the organization's sanction risk assessment to better understand the potential for exposure to Russia and the Democratic People's Republic of Korea

C.

Read and analyze the most recent National Proliferation Financing Risk Assessment produced by the relevant body of the organization's jurisdiction

D.

Undertake a detailed review of all payment-related transactions to any clients identified as defense contractors, paying special attention to the beneficial owners of those clients

Question 49

Which of the following can be considered a reliable, independent source document, data, or information?

Options:

A.

Information provided by a prospective customer

B.

Photocopy of a copy of a government-issued identity document

C.

Information obtained from an open-source database

D.

Information obtained directly from a government-managed registry

Question 50

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

Options:

A.

Developing a culture of compliance

B.

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

C.

Reducing transaction monitoring false positives for all financial institutions

D.

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

Question 51

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

Options:

A.

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

B.

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

C.

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

D.

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

Question 52

What areas of laws and regulations have the greatest impact on AML/CFT applications? (Choose three.)

Options:

A.

Information security, data privacy, and cybersecurity

B.

Foreign exchange control, and precious gemstone and metal dealing

C.

Ombudsman and anti-competition authority

D.

Electronic contract and biological signature acceptance

E.

Consumer protection, financial inclusion, and environmental, social and governance

Question 53

Which of the following statements describe the strengths associated with public-private partnerships (PPPs)? (Choose two.)

Options:

A.

Public organizations can belter understand what the private sector experiences and inform policy and the enactment of laws

B.

Data-protection privacy policies provide an opportunity to develop information sharing protocols to prevent unauthorized access to information

C.

Data-protection privacy policies prohibit the evolution of PPPs due to restrictions based on legacy government legislation

D.

Small business owners can choose third-party providers or financial institutions to keep their private data safe which can easily be shared within a PPP

Question 54

Which of the following are included in the 11 Immediate Outcomes outlined in the Financial Action Task Force (FATF) methodology for assessing technical compliance with the FATF Recommendations and the effectiveness of AML/CFT/CPF systems during mutual evaluations? (Select Three.)

Options:

A.

International cooperation provides actionable information to use against criminals

B.

Those convicted of money laundering offenses are denied access to basic banking services

C.

Money laundering offenses are investigated and criminally prosecuted

D.

Financial intelligence information is collected by authorities and shared with the FATF for further investigation

E.

Supervisors regulate financial institutions and non-bank financial institutions and their risk-based AML/CFT programs

Question 55

Which of the following are considered best practices regarding senior management involvement in a financial crime compliance program? (Choose two.)

Options:

A.

Setting tone from the top

B.

Mandatory participation in all regulatory inspections

C.

Mandatory attendance and review of all financial crime trainings

D.

Setting clear criteria for escalations to senior management

Question 56

Professions such as lawyers, accountants, and trust and company service providers (TCSPs) are sometimes referred to as "gatekeepers" because they:

Options:

A.

often do not understand and are not covered by money laundering laws and regulations, unwittingly allowing criminals to enter the legitimate economy.

B.

are an entry point to the financial system and a first line of defense against the infiltration of illicit funds into the legitimate economy.

C.

are required under money laundering laws and regulations in all jurisdictions to stop any criminals from being able to integrate illicit funds into the legitimate economy.

D.

are high-risk actors who can deliberately allow criminals to enter the legitimate economy.

Question 57

Which of the following entities could potentially pose a higher money laundering risk and require additional review prior to onboarding? (Select Two.)

Options:

A.

A large multinational corporation with extensive, documented wire transfer activity

B.

A local convenience store that replenishes the onsite automated teller machine (ATM) with cash from its till

C.

A local used car sale lot that allows individuals to pay their monthly bill in cash

D.

A virtual asset service provider (VASP), facilitating peer-to-peer cryptocurrency transactions

Question 58

Challenges in the implementation of new technologies for AML/CFT include: (Select Four.)

Options:

A.

data privacy.

B.

enhanced due diligence (EDD) policies.

C.

the Travel Rule.

D.

data quality.

E.

complexity.

F.

regulatory.

Question 59

An internal audit team is reviewing the anti-financial crime (AFC) program of its firm.

Which of the following attributes of the third line of defense would be most critical to ensure unbiased and effective oversight?

Options:

A.

Consistency of approach

B.

Periodic training of the function

C.

Qualification of the team

D.

Independent testing

Question 60

According to the Egmont Group, which benefits do public-private partnerships (PPPs) provide to Financial Intelligence Units (FIUs)? (Select Three.)

Options:

A.

Helping overcome data protection and information sharing limitations

B.

Enhancing the quality of reporting and additional informational input

C.

Helping to alleviate the financial cost burden on law enforcement

D.

Helping to design common approaches and identify desired deliverables

E.

Offering flexibility, agility, and opportunities to adjust to the ML/TF threat environment

Question 61

Under the Egmont Group Principles, information exchange among financial intelligence units (FIUs) should be conducted:

Options:

A.

Without the expectation of reciprocity on how the information will be used.

B.

Only if the status of the foreign FIU is related to law enforcement.

C.

Freely, spontaneously, and upon request, on the basis of reciprocity.

D.

With set limits on the amount of financial and administrative information provided.

Question 62

Which of the following statements best describes the financial crime risk associated with gatekeepers?

Options:

A.

Gatekeepers have specialized knowledge that can be abused to facilitate the movement of illicit funds and conceal the Involvement of their clients in illicit schemes.

B.

Gatekeeper positions ate of a secretive nature, often making it difficult to verify (heir source of wealth.

C.

Gatekeepers have unique relationship structures, making it difficult to determine beneficial ownership

D.

Gatekeepers are entrusted with prominent functions and code of conduct that can assist laundering Illicit funds.

Question 63

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

Which request is legitimate and requires the bank to respond?

Options:

A.

Keep an account open upon verbal request

B.

Produce documents and testimony without a subpoena

C.

Seize privileged documents upon written request

D.

Freeze an account in terms of a court order

Question 64

A bank has been fined for failing to take reasonable care to establish and maintain effective systems and controls for high-risk customers, including politically exposed persons (PEPs).

Which typical financial crime risks should the bank have addressed? (Choose three.)

Options:

A.

Gathering sufficient information to establish the source of funds and source of wealth

B.

Assessing the level of money laundering risk posed by prospective and existing high-risk customers

C.

Assessing and reviewing the minutes of the relevant committee responsible for onboarding customers

D.

Ensuring an employee is responsible for liaison with the authorities on matters related to countering the finance of terrorism

E.

Ensuring that resources in its compliance and AML areas kept pace with the bank's growth

Question 65

Which of the options below is an indicator of potential insider activity that may warrant escalation For further investigation?

Options:

A.

A relationship manager advocates for overriding the results of the company's client risk rating model that resulted in a client's high-risk rating.

B.

An If employee shares information about a firm's risk management framework with employees of other firms at an industry convention.

C.

An investigator does not complete the automated transaction monitoring system alerts assigned to them before the time required by company procedures.

D.

A relationship manager makes an exception to company policy and proceeds with onboarding a customer without documenting a passport for customer identification

Question 66

A trust and company services provider that offers a variety of services to businesses is approached by a client interested in establishing a new company. The client requests assistance with the incorporation process, a local business address, annual maintenance services, and the designation of individuals to serve in official capacities for the new company.

Which of the following services involves a higher money laundering risk?

Options:

A.

Appointing individuals to serve in official capacities of the company

B.

Annual maintenance services

C.

Provision of a local business address

D.

Company incorporation services

Question 67

The chief compliance officer (CCO) at a bank approved offering trade finance services to a company which is established within a country with a weak democratic system routinely reviews news on upcoming targeted economic sanction regulations in the EU, a major import partner for the country's production of crude oil.

Which of the following pieces of news would be of greatest concern?

Options:

A.

The European Commission and the High Representative issue a joint proposal for an import ban on refined oil products.

B.

The European Commission and the High Representative issue a joint proposal for an import ban on oil extraction equipment

C.

The Council of the European Union adopts a new export control regime for electronic equipment

D.

The Council of the European Union adopts a new import restriction regime for goods coming from countries that do not respect human rights

Question 68

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

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

Options:

A.

Information security office (ISO)

B.

Marketing and sales

C.

Human resources (HR)

D.

Data privacy office (DPO)

Question 69

From an international standards perspective both the EU and Financial Action Task Force (FATF) consider data sharing a crucial component of effective anti-money laundenng measures because data sharing:

Options:

A.

allows Financial Intelligence Units (FlUs) to enact sanctions against perpetrators of financial crime

B.

promotes financial transparency and protects the integrity of the financial systems

C.

needs to be approved by the Financial Intelligence Unit (FIU) before sharing between financial institutions

D.

helps financial institutions to be more effective in fighting crime with data analysis

Question 70

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

Options:

A.

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

B.

AML/CFT laws are the primary focus for FIs, and other regulations like data privacy and consumer protection may only indirectly influence their compliance obligations

C.

Environmental, social, and governance (ESG) frameworks can influence a Fl's risk management strategies but are generally considered separate from core AML/CFT compliance requirements

D.

Data privacy laws can restrict the sharing of customer information, while financial inclusion initiatives require FIs to avoid excessive de-risking that could exclude vulnerable populations.

Question 71

Which scenario indicates potential money laundering activity by a lawyer?

Options:

A.

A lawyer located in a higher risk country deposits their firm's bank draft issued from their trust account to another lawyer's trust account located in a low-risk country for legal services rendered.

B.

A lawyer's trust account regularly receives wire transfers from unknown remitters from a higher risk country and immediately transfers the same amount of funds received to a known beneficiary's account in a low-risk country.

C.

A lawyer's trust account receives a large-value wire transfer from a regulated insurance company and immediately transfers the same amount of funds received to the beneficiary's bank account located in a low-risk country.

D.

A lawyer's trust account receives a large wire transfer deposit from a client that wanted to purchase a piece of property and then transfers the same amount to the property seller's lawyer's trust account.

Question 72

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

How would these controls impact the assessment of residual risk?

Options:

A.

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

B.

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

C.

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

D.

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

Question 73

The primary objectives of the Financial Action Task Force (FATF) are to: (Choose two.)

Options:

A.

evaluate and monitor compliance with the FATF standards and provide recommendations for improvement.

B.

assist countries in implementing EU, UN, and regional sanctions regimes.

C.

develop and promote international standards to prevent money laundering and terrorist financing.

D.

conduct investigations on countries legislations and laws to prevent them from being used for money laundering and terrorist financing.

E.

ensure that countries follow its laws to maintain financial stability.

Question 74

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

Options:

A.

Using gaming accounts to transfer illicit funds between players undetected

B.

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

C.

Providing false personal information to evade regulatory oversight

D.

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

E.

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

Question 75

Which of the following are red flags pertaining to potentially suspicious transactions by a customer? (Select Three.)

Options:

A.

A customer deposits a large number of consecutively numbered money orders.

B.

A customer requests loans made to local companies or secured by obligations of local banks.

C.

A customer has regular deposits and withdrawals primarily in wire transfers.

D.

A customer receives wire transfers from different unknown accounts which are immediately wired onwards to a third party.

E.

A customer withdraws cash in amounts just under the reporting threshold.

Question 76

Money laundering has social and economic impacts, especially within developing countries. A high volume of money laundering in a country may: (Select Two.)

Options:

A.

Dissuade government tax incentive programs

B.

Reduce confidence in the country's financial sector.

C.

Dissuade foreign investment.

D.

Lower the employment rate.

E.

Reduce volatility in exchange and interest rates.

Question 77

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

Options:

A.

In-person training sessions

B.

Comprehensive curriculum delivered by senior management

C.

Comprehensive content with engaging delivery methods

D.

Generalized content designed to apply to a broad audience

Question 78

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

Options:

A.

Introduction of new products or services

B.

Mergers or acquisitions

C.

Restructuring of the FI's risk and compliance functions

D.

Use of new technologies for delivering existing products

E.

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

Question 79

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

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

Options:

A.

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

B.

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

C.

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

D.

Suggest EDD for 50% of the clients is appropriate.

Question 80

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

Options:

A.

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

B.

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

C.

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

D.

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

E.

Real estate transactions often involve financial institutions and other professional gatekeepers

F.

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

Question 81

Which strategies are most effective for prioritizing resources within an anti-financial crime (AFC) program using a risk-based approach (RBA)? (Choose two.)

Options:

A.

Prioritizing resources towards lower-risk areas to reduce workload

B.

Regularly reassessing risks to adjust resource allocation

C.

Allocating more resources to areas with higher financial crime risk

D.

Providing equal resources to all departments to maintain consistency

E.

Using a fixed resource allocation plan without adjustments

Question 82

News published in Country A reports that a politically exposed person (PEP) had received a bribe from a transnational company headquartered in a developing country of approximately USS1.5 million deposited into on account at a financial institution (Fl> located in Country B Both countries are members of the Egmont Group The account where the money was deposited belongs to the PEP's immediate family member. To corroborate the facts, the PIU of Country A sent a formal request via secure communication channels for further information from its counterpart FIU in Country B.

According to Egmont principles, the FIU of Country B can:

Options:

A.

provide the information available to them because the exchange is between two FlUs that are members of the Egmont Group, and the formal request was made using secure communication channels.

B.

provide the requested information only if a memorandum of understanding (MoU) is signed between Country A and Country

C.

direct the FIU of Country A to the Fl where the account was opened for further information.

D.

deny the request if the FIU of Country B has not received a suspicious activity report (SAR) from the Fl where the account was opened.

Question 83

What are the rules imposed by the Office of Foreign Assets Control (OFAC) for legal entities and persons related to the US? (Select Two.)

Options:

A.

The head office of a foreign legal entity which has a branch in the US does not need to comply with OFAC rules.

B.

A foreign individual visiting the US for a short vacation is obligated to follow OFAC rules.

C.

Nationals of the US must comply with OFAC rules, regardless of where they are located in the world.

D.

Any foreign corporation is also penalized if it conducts transactions with sanctioned countries under OFAC rules.

E.

A subsidiary of a legal entity of the US, which is formally registered in a foreign country, is exempt from OFAC rules.

Question 84

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

Options:

A.

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

B.

implementing new controls to eliminate all risks

C.

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

D.

documenting the historical risk incidents for future reference.

Question 85

In order to prevent financial crime risk, the implemented policies, controls, and procedures must:

Options:

A.

include sophisticated and automated controls that use the newest types of technology available (for example, artificial intelligence (Al) and machine learning).

B.

be proportionate with regard to the size and nature of the firm, approved by senior management, and regularly reviewed

C.

be completed by the business and validated by an external firm (for example, an auditing or consulting firm)

D.

be created approved, and owned only by the First Line of Defense business team, and reviewed annually

Question 86

Which section of the USA PATRIOT Act permits the US government to seize funds deposited in a US correspondent account of a foreign bank, creating extraterritorial impact?

Options:

A.

Section 314(a)

B.

Section 314(b)

C.

Section 319(b)

D.

Section 319(a)

Question 87

A wealthy individual is using a complex corporate structure to facilitate illegal logging and then illegal mining of the resulting resources from that land.

Which category of predicate crime is taking place?

Options:

A.

Trade-based money laundering

B.

Corruption

C.

Illicit resource trade

D.

Environmental crime

Question 88

A prospective client walks into an accounting firm wanting to incorporate a company. The accountant feels uncomfortable after the meeting.

Which two of the accountant's observations warrant escalation to the compliance officer? (Select Two.)

Options:

A.

The principal activities of the proposed company are importing and exporting new furniture

B.

The prospective client presents confusing details about the proposed business and has very little knowledge about the proposed business activity

C.

The prospective client is unable to provide information about the beneficial owners

D.

The prospective client exhibits confidence when speaking to the accountant when providing personal details

E.

The prospective client is able to provide source of funds and source of wealth documents

Question 89

Money services businesses (MSBs), payment service providers, and e-commerce platforms usually have a high volume of daily transactions.

What are the risks associated with these types of businesses? (Choose two.)

Options:

A.

These businesses are all cash intensive, increasing the risk of financial crime

B.

KYC challenges arise because e-commerce platforms face global customers making customer due diligence complex and resource intensive

C.

These businesses are highly regulated and therefore have no reason to be non-compliant as this would put them at risk of sanctions and fines

D.

Criminals can make use of identify fraud to fulfill KYC processes for layering purposes

E.

The settlement systems of these businesses are not sophisticated enough to cope with the high transaction volume

Question 90

As emphasized in the Basel Committee guidance for "Sound management of risks related to money laundering and financing of terrorism", the third line of defense, or audit function, should:

Options:

A.

Conduct AML audits no less often than every 12 months for consistency in annual reporting.

B.

Remain independent from expressing opinions on the sufficiency of remediation or action plans to address findings and recommendations.

C.

Be involved in the day-to-day operations of the AML program to immediately prevent control failures.

D.

Report to the audit committee of the board of directors to maintain independence.

Question 91

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

Options:

A.

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

B.

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

C.

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

D.

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

Question 92

Which of the following conditions contribute to a politically exposed person (PEP) posing greater risk than a typical high-risk bank customer? (Select Two.)

Options:

A.

The family members and close associates of PEPs may be involved in illicit activities.

B.

PEPs are granted unlimited credit and financial immunity under international banking regulations.

C.

PEPs may exploit embassy activities to conceal bribery and corruption transactions.

D.

PEPs can have illegitimate fund sources but are legally protected from having their accounts closed for activities outside a bank's risk appetite.

Question 93

A financial institution is exploring automation to assist investigators in reviewing flagged transactions. Currently, investigators spend a significant amount of time gathering data from multiple sources.

Which of the following automation features would be most effective in improving investigator efficiency?

Options:

A.

Pre-populated templates for SAR filing

B.

Integration of open-source tools to gather real-time intelligence

C.

Automated case prioritization based on risk scoring

D.

AI-powered dashboards summarizing flagged transactions

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