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

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

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

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

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

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

Allowing fixed income securities to mature

Using brokerage accounts like deposit accounts

Engaging in transactions involving nominees or third parties

wire transfers in different currencies between accounts held at different banks for the same client.

an incoming third-party wire transfer followed by the purchase of real estate in the client's name.

an incoming wire transfer followed by the loan payment to a third party that is a business associate of the client.

multiple wire transfers sent to counterparties associated with the client as per KYC documentation.

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

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

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

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

Use of art storage facilities located in tax-free zones

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

promotes financial transparency and protects the integrity of the financial systems

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

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

red notice

white list

yellow notice

grey list

Exchange operational information between public authorities and obliged entities

Exchange strategic information between FIUs and obliged entities

Exchange strategic information between financial institutions

Create a common database of key information and share analysis of suspicious activities with FATF

The beneficiary of the wire transfers is a foreign company whose shareholders and director are other companies

The wire transfers are for different amounts but with the same beneficiary

The beneficiary of the wire transfer is a resident of a grey-list country

The beneficiary of the wire transfers is a resident of a foreign country bearing the same family name as the business owner

simultaneous encryption and decryption for underlying data.

full access to underlying data with full and uninterrupted calculations made on the data.

secure processing of data while it remains encrypted.

transfer, decryption and storage of data by the data processor.

The Bank Secrecy Act (BSA) extraterritorial reach requires that the Travel Rule be applied to all financial institutions globally, including all USD transactions

The Anti-Money Laundering Act of 2020 (AML Act) extraterritorial reach covers all USD transactions throughout the global economy

The Office of Foreign Assets Control's (OFAC's) economic and trade sanctions may pose extraterritorial risks for financial institutions and businesses outside of the US

Section 319(b) of the USA PATRIOT Act extraterritorial reach permits the seizure of funds from a correspondent bank account in the US that have been opened and maintained for the foreign bank

Establish policies and procedures to ensure due diligence activities are identical for all customers.

Establish policies and procedures to identify and verify customers, beneficial owners, and any individuals that can transact on behalf of their customers.

Establish policies and procedures for customer due diligence that vary based on risk.

Are prohibited from offering numbered accounts to customers, even if procedures are established to gather and maintain due diligence information.

Establish policies and procedures that encourage processing transactions while due diligence information is being established and verified.

Attempts to circumvent or evade sanctions imposed by the UNSC can constitute a criminal offense if designated under local laws and regulations

The UN can impose arms embargoes but cannot prohibit direct or indirect exports of other goods to specific countries

Member countries of the United Nations are expected to implement and enforce sanctions imposed by the UNSC

Direct breaches of sanctions imposed by the UNSC constitute a criminal offense in all member countries

Adaptable to new AFC typologies through continuous model training

Completely unbiased and without error through continuous model training

More consistent and reliable detection outcomes

Transparent and easy to explain algorithms for regulator and compliance purposes

Low thresholds for transactions

Frequent use of cash

Cross-border transactions

Weak KYC policies and procedures

Regulation (EU) 2024/1624 of the European Parliament

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

USA Patriot Act Section 314(a)

USA Patriot Act Section 314(b)

Sanctions can only be placed on certain individuals in foreign countries as designated by OFAC

Blocked funds must be placed into an interest-bearing account on a financial institution's books

Sanctions can be either comprehensive or selective using the blocking of assets and trade restrictions to accomplish foreign policy and national security goals

OFAC sanctions automatically expire after five years unless renewed by Congress

Relying on self-reported compliance certifications from vendors and employees to confirm adherence to AML standards on a periodic basis

Establishing a surveillance program for employees, vendors, and third parties, including periodic risk assessments, access controls, and regular reviews of their compliance with AML policies

Implementing background checks for employees and vendors prior to onboarding or the start of engagement to identify any red flags

Limiting the number of vendors and third parties in high-risk jurisdictions in order to reduce exposure to compliance risks

An existing local league footballer trying to open a bank account with a bank in their local jurisdiction

The current prime minister of a country trying to open a bank account in another country

The former personal secretary to the minister of transport in a low-risk country 25 years ago opening a bank account at a bank in a neighboring low-risk country

A bank located in a higher risk country trying to establish a correspondent-respondent banking relationship with a bank in a lower-risk country

An individual with a current bank account who resides in one country becoming the ambassador of another country

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

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

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

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

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

cross-border purchases

purchases in the name of a natural person

paying true market price for a property

non-financed purchases

Subscribing lo a regulators' newsletter

Using a specific provider for regulatory horizon scanning

Regularly contacting the regulator to inquire about updates and future developments

Relying on information and insights from peers and working groups

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

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

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

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

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

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

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

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

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

Review the transaction history of the account to identify patterns, including the frequency, destination, and purpose of the wire transfers

Notify senior management and suggest account closure due to potential risks

Immediately file a suspicious activity report (SAR) based on the employee's report of suspicious behavior

Contact the customer directly to ask for clarification on the reason for the large cash withdrawal

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

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

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

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

Customer privacy regulations should guide the development of due diligence and other money laundering and terrorist financing preventive measures.

Nations should work towards implementing targeted financial sanctions in alignment with the UN Security Council.

Nations should take measures to ensure there is transparency to the beneficial ownership of legal persons.

Nations should establish frameworks that take a risk-based approach to prevent and mitigate money laundering and terrorist financing.

Governments must work toward developing identical administrative and operational frameworks for investigating and prosecuting crime.

Regulators should direct Financial Institutions to establish appropriate frameworks to avoid banking higher risk customers.

Restrict the client's access to the account

Request information from the relationship manager assigned to the account that caused the alert

Perform below-the-line testing to ensure the automated monitoring system is operating effectively

Send a request for information to the counterparty bank involved in the transaction that caused the alert

Only commit to action plans that require no new investment to maximize shareholder value

Draft action plans in consultation with the jurisdiction's FIU to remain aligned with other similar companies

Only commit to action plans that can be implemented and closed within the three-month management reporting cycle

Draft action plans to address the root cause of the deficiencies, regardless of how long they will take to fully implement

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

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

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

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

executing cross-border transactions for their own business which is not commensurate to the PEP's wealth.

in a position to provide more information regarding the PEP's whereabouts and hidden properties.

travelling to offshore jurisdictions often on holiday which exposes them to higher risks for AML.

used as intermediaries to facilitate bribery or corruption or to conceal the illicit wealth of the PEP.

Using brokerage accounts like deposit accounts

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

Allowing fixed income securities to mature

Engaging in transactions involving nominees or third parties

Challenge-response

Fingerprint

Security token

Passphrase

It reduces the overall cost of compliance programs.

It eliminates the need for periodic audits of low-risk customers.

It ensures focus on high-risk areas while maintaining operational efficiency.

It standardizes compliance processes across all regions.

To prohibit the payment of anything of value by persons or entities to government officials or employees of state-owned enterprises to obtain an improper business advantage

To prohibit the conversion of illegally obtained money into legal money by senior government figures

To protect against election interference by corrupt foreign adversaries facilitated by illicit funds

To protect against the use of illegal means by senior political figures to avoid paying taxes

Eliminating spontaneous information sharing between FIUs to reduce the burden of excess investigative work

FIU cooperation should always be channeled through designated intermediaries

Information exchange should take place informally, without too many formal prerequisites

Formal Egmont Group membership requirements ensure a high commitment of the eligible FIUs

It is within an FIU's authority to sign Memorandums of Understanding independently

Perform a control and ownership assessment of the businesses involved, using the information available in the client files

Contact local law enforcement and request that they assist in the analysis and investigation

Review the information presented in the automated monitoring system's alert description and decline any future transactions

Contact the account manager and ask for the reasons behind the patterns of activity highlighted in the AML alerts

Use social media platforms to connect with the businesses and request details about the account activity

amount of annual fees associated with the jurisdiction.

permissibility of bearer shares.

rules governing the disclosure of beneficial ownership by the jurisdiction.

ease of travel to the jurisdiction.

National Risk Assessment

Regulatory guidance or publications

Government or state-run newspapers

Guidance issued by international bodies

Policies and procedures developed by other banks

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

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

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

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.

Accountants can prepare ledgers and spreadsheets, draft annual returns and make payments to government offices

Accountants can advise on the structuring of companies as well as ensure compliance with local tax regulations

Accountants are knowledgeable about financial management, including what to record over the course of the accounting year

Accountants are able to create and structure companies, falsify accounts and manipulate financial statements

Cash-intensive businesses risks

Unknown third-party risks

Geographic risks

Anonymous transactions risks

remote verification of identity by third-party program managers

heavy usage by senior political figures.

heightened risks of returned transactions.

informal networks used for cross-border transactions outside of the formal banking system

difficulty in tracking the originator recipient, and source of transactions.

Accounting

Model risk management

Technology solutions and IT security

Marketing

Fraud risk management

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

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

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

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

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

Document the customer's transaction history and keep the investigation confidential until further suspicious activity is detected.

Immediately escalate the case to senior management, recommending the closure of the customer's accounts due to potential reputational risk.

Report the investigation to external auditors and await further guidance before taking any action.

Draft a SAR that includes a detailed chronology of the transactions, customer background and the rationale for suspicion, and submit it to the relevant financial intelligence unit (FIU) within the regulatory timelines.

Inquiring about the source of wealth and source of funds

Asking to provide a list of immediate family members

Verifying the financial crime awareness of the client

Collecting necessary documents to verify the veracity of information

Ensuring an effective export control and treaty compliance system

Administering and enforcing economic and trade sanctions

Designating jurisdictions as primary money laundering concerns

Managing trade agreements between the US and foreign countries

List-based

Secondary

Country-based

Sectoral

A court order requests the bank to disclose the SAR subject to obtaining agreement from the legal team

A customer asks about potential reporting to the local Financial Intelligence Unit (Fill)

An external consultant inquires about the details of the SAR

A third-country police directly inquires about the customer.

Relevant information should be shared throughout the organization.

Revenue-generating business sectors should have precedence over compliance.

First line of defense should establish its own policies independently.

Cost of compliance should increase proportionately to revenues.

Whether the vendor has documented appropriate internal controls for designing system and data integration schema

Whether the permissions and user access settings for reviewing, investigating, and reporting details of alerts generated by the system are commensurate with those in use at other banks

Whether the monitoring system is adequate with respect to the bank's size, activities, complexity, and risks

Whether the monitoring system can be configured to enable the bank to execute trend analysis of transaction activity and to identify unusual business relationships and transactions

Change the risk profile to "high-risk" if an existing customer becomes a sanctioned entity and continue monitoring further transactions.

Adopt automatic screening systems to detect designated persons and entities.

Conduct enhanced due diligence for prohibited entities on the sanctions list.

Freeze the funds or assets of designated persons and entities once this decision is approved by the board.

identification of the customer's occupation.

identification and verification of the customer's identity.

identification of the customer's work address.

identification of the beneficial owner.

verification of the customer's credit history.

[verification of the customer's income sources.

Collect donations from various sources, and their primary objective is philanthropy and social wellbeing

Are usually legitimate establishments and will not use the funds collected through donation for the profit of individuals or entities

Have a global presence that provides a framework for national and international operations and financial transactions that are often in or near areas most exposed to terrorist activity

Enjoy the public trust and have access to considerable sources of funds, and their activities are often cash intensive

The bank's designated AML compliance officer is likely to face criminal prosecution because the bank received a regulatory order

The bank's designated AML compliance officer and senior management can face civil prosecution but not criminal prosecution for violation of AML laws

The bank's designated AML compliance officer and senior management may face personal liability if they failed to take actions while aware of AML violations at the bank

The bank's designated AML compliance officer is the only individual in the company's senior management team that can face personal liability for violation of AML laws

protect the rights of the citizens of the state target against their own government and improve financial stability in the region.

indicate that the use of military force is likely unless the state or non-state target complies with the government's

interests encourage non-governmental organizations to increase the provision of humanitarian and charitable aid to the target

alter the behavior of the state or non-state target that threatens the interests of that government or violates international norms

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

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

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

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

Sponsoring the research and development of advanced technological surveillance tools to be used nationally

Prosecuting significant cases of money laundering or terrorist financing falling under national jurisdiction

Sharing real-time criminal intelligence gathered from national law enforcement agencies with the private sector

Serving as a national center for the collection and analysis of suspicious activity

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

Notify the customer being investigated before submitting documents

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

Have the institution's assigned legal counsel review the subpoena

Make a note in the customer's account that the customer's gambling activities are frequently conducted below the reporting limit

Follow internal reporting procedures to escalate the activity as suspicious and report to appropriate authorities

Inform the customer their activity Is suspicious and request an explanation

Contact law enforcement to launch an Investigation into the customer's financial activities

The account activity includes deposit activity into both savings and checking accounts

The account activity includes incoming funds transfers at irregular intervals from small businesses located in New York

The account activity includes deposits made in multiple branches around New York City into the same account.

The account activity includes frequent purchases of tickets to industry conferences and other events.

Address control of payments in EU countries to reduce money laundering.

Build a network of financial institutions that work together to prevent money laundering across the EU.

Establish a consistent regulatory environment across the EU to prevent money laundering.

Allow member states to discuss the draft legislation with the cooperation of the EU financial intelligence units.

Types of payment messages

Customers

Third-party service providers

Customer spouses

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.

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

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

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

Make an official request directly from the head of Country A's anti-corruption authority to Country B's corresponding law enforcement authority

Make a request for the required evidence using Country A's mutual legal assistance treaty with Country B

Use the International Criminal Police Organization (INTERPOL) network to obtain the required evidence from Country B

Use the Egmont Secure Web to obtain the required evidence from Country B's financial intelligence unit

funds being stolen from other users.

obscuring the source of illicit funds.

layering transactions to hide the origin of funds derived from illicit activity.

difficulty converting into physical currency.

facilitating payment for other illicit activities and goods.

In-person training sessions

Comprehensive curriculum delivered by senior management

Comprehensive content with engaging delivery methods

Generalized content designed to apply to a broad audience

Establishing risk controls

Assessing risk controls

Ongoing risk monitoring

Conducting a risk assessment

Past employment records.

Personal references from close associates.

Personal resume.

Internet and public media searches.

Criminal history searches.

A limited liability company incorporated in a foreign jurisdiction

A private company that has no activity in a tax haven jurisdiction

A company with nominee shareholders and directors in a local jurisdiction

A company with bearer shares incorporated in a tax haven jurisdiction

A private investment company incorporated in a tax haven jurisdiction with strict secrecy laws

It is against international laws on data protection to access information from foreign countries

Sovereignty of nations means that information cannot be accessed from foreign countries

Any information related to money laundering can be received from any organization at any time regardless of jurisdiction

Countries that are members of the Egmont Group can request assistance for information from each other

Send a 314(b) request to the corporation's bank in Hong Kong

Call the receiving individual to review identity verification documents

Confirm that neither the beneficiary nor the originator are sanctioned parties

Request supporting documents, including invoices and contracts to confirm the purpose of the payment

Check for negative news in public sources on the sender and receiver

Devaluation

Smart contract vulnerabilities

Potential for anonymity

Global reach

High transaction fees

Use to layer illicit funds

Memorandum of Agreement.

Declaration of Understanding.

Memorandum of Understanding.

Mutual Legal Assistance Treaty.

Request for Urgent Information.

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

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

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

A patron routinely places multiple bets on the same sporting events

Providing basic AML training to all employees

An AML officer being appointed to the board as a working member of management with increased authority

Auditors providing prescriptive guidance and support to the program following a less than satisfactory audit

Providing effective challenge with AML staff and continuous cross-training

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

Assessing whether internal staff members can provide training on the tools

Assessing the cost of implementation and cost of maintaining the tools

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

A customer being hesitant to provide beneficiary name or address information when sending international wire transfers

Cash-intensive businesses, such as convenience stores or restaurants, making large cash deposits

A customer exchanging foreign currency from a higher-risk jurisdiction for domestic currency under the reporting threshold

A customer using multiple accounts under different names to conduct transactions

A customer completing frequent small-dollar international money transfers to their native country

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

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

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

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

International cooperation provides actionable information to use against criminals

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

Money laundering offenses are investigated and criminally prosecuted

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

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

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.

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

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.

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

The customer is attempting to convert illicit funds into “clean” withdrawals

The customer is attempting to avoid high fees by minimizing gambling activity

The customer is testing the gaming platform’s payout system for potential fraud

The customer is a high-risk gambler who regularly places large bets

Forming a trust on behalf of a customer with a complex setup and acting as a nominee director

Auditing a firm that provides payroll software to large corporate customers

Preparing financial statements for a listed or a privately owned firm

Providing tax advice to an international customer hoping to move their assets out of their home country

Assisting an offshore corporation from a jurisdiction with no available beneficial owner information to buy property in the UK

Information provided by a prospective customer

Photocopy of a copy of a government-issued identity document

Information obtained from an open-source database

Information obtained directly from a government-managed registry

Introduction of new products or services

Mergers or acquisitions

Restructuring of the FI's risk and compliance functions

Use of new technologies for delivering existing products

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

Inform local LEA and regulator of the request for awareness

Close the client's accounts immediately to avoid any undue risk

Review the client's activity, determine if suspicious activity exists, and report accordingly

Advise the LEA that the government needs to be contacted for extradition

Comply immediately with the foreign jurisdiction and turn over all client information

cross-border purchases.

purchases in the name of a natural person.

paying true market price for a property.

non-financed purchases.

A client frequently submits financial statements much earlier than required appearing overly eager

A client insists on using a personal bank account for business transactions despite being advised otherwise

A new client shows a preference for minimal direct interaction and relies primarily on indirect communication methods, citing convenience or time constraints

The client is a publicly listed company but very diversified

The ultimate beneficial ownership is unclear

Use of wire transfers

Loitering

Instructions or involvement from third parties

Amended letters of credit without reasonable justification

Non-standard settlement arrangements

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

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

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

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