ACAMS CAMS Actual Questions

According to the CAMS Study Guide (the 6th edition), page 184, when an FI receives a formal law enforcement request to produce documents, such as a subpoena, a search warrant, or a court order, it should designate a person responsible for the internal investigation in preparation of documents for the request. This person should be familiar with the FI’s policies and procedures, the applicable laws and regulations, and the nature and scope of the request. The designated person should also coordinate with the FI’s legal counsel, compliance officer, and senior management, and ensure that the FI preserves the confidentiality and integrity of the documents and the investigation.

TheBoard of Directorsholdsultimate responsibilityforAML/CFT compliance and governance.

Option B (Correct):TheBoardmustoversee, approve, and ensure AML programs are effective.

Option A (Incorrect):TheCOO manages operations, butdoes not hold ultimate accountability.

Option C (Incorrect):While theAML officer executes compliance programs, theBoard provides oversight.

Option D (Incorrect):TheCEO is responsible for strategy, butAML failures fall under Board accountability.

Economic sanctions are measures imposed by countries or international bodies to exert pressure on individuals, entities, or nations that engage in undesirable behavior or actions. Sanctions aim to restrict or prohibit certain economic activities with the targeted parties, such as trade, investments, or financial transactions. They serve various purposes, including achieving foreign policy and national security objectives and deterring undesired actions by countries or entities. Sanctions can be comprehensive (affecting an entire country) or targeted (specific businesses, groups, or individuals), with a recent trend toward minimizing harm to innocent civilians12.

Aproper investigation of unusual transactions requires a mix of data analysis, contextual review, and expert judgmentto assess potential risks.

Option B (Correct):Cross-referencing transactions with external factors(e.g.,political events, commodity price fluctuations, news reports) helps identifypotential links to illicit activities.

Option C (Correct):Therelationship managermay provide insights intowhether a transaction aligns with the customer’s known profile and business activity.

Option D (Correct):Arisk-based approachensures thathigher-risk transactions receive enhanced scrutiny, while lower-risk ones undergo standard monitoring.

Why Other Options Are Incorrect:

Option A (Incorrect):Focusing only on transaction amountsignorescontextual factors, such asunusual behavior in low-value transactions.

Option E (Incorrect):Automated alerts are valuable but cannot replace human analysis and judgment.Manual reviews remain necessary for complex cases.

Red Flags in Unusual Transactions:

Large or frequent transactions inconsistent with a customer’s normal profile.

Payments from/to high-risk jurisdictions without a clear purpose.

Use of intermediaries or shell companies to move funds.

Best Practices for AML Investigations:

Use both qualitative and quantitative factorsto assess transaction risks.

Collaborate with business units(e.g., relationship managers) to understand client behavior.

Apply a risk-based approach to allocate investigation resources efficiently.