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

Establishing BSA/AML compliance staff reporting to the management of the business line in the first line of defense

Ensuring BSA/AML compliance staff is primarily outsourced

Providing BSA/AML compliance staff a reporting line to compliance or other second line of defense internal control function

Providing BSA/AML compliance staff with a reporting line to the chief financial officer

Ensure that the second line reviews, monitors, and escalates risk-related issues as needed to senior management while maintaining independent oversight from the third line

Have senior management handle risk-related issues directly when possible because they are ultimately responsible for the organisation's overall risk management strategy

Delegate some risk-related issues to the first line to avoid overwhelming the second line and to ensure operational efficiency

Assign risk-related oversight duties to the third line to provide an independent review and address issues more effectively by avoiding conflicts of interest in the first and second lines

Information security office (ISO)

Marketing and sales

Human resources (HR)

Data privacy office (DPO)

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

ensure that all adverse media sources are comprehensively analyzed without the need for human review.

significantly reduce human errors arising from repetitive tasks by delivering consistent and highly accurate analysis.

instantly identify intent behind media articles, allowing for more effective risk scoring.

automate the process of identifying new information and distinguishing it from previously encountered data.

cover multiple languages and scripts, surpassing the limitations of human linguistics.

buy in-game items with virtual in-game currencies.

exchange in-game items with other players.

trade in-game items with other players that can be exchanged for fiat currency

obtain in-game materials by performing in-game activities.

Surrendering a policy early to liquidate funds

Focusing excessively on the investment performance of an insurance product

Using a credit card to purchase an insurance policy

Using cryptocurrencies or other non-fiat currencies to fund an insurance policy

Accounting

Model risk management

Technology solutions and IT security

Marketing

Fraud risk management

Devaluation

Smart contract vulnerabilities

Potential for anonymity

Global reach

High transaction fees

Use to layer illicit funds

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

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

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

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

have never worked in previous assignments within the AMUCFT departments.

have no involvement with the organization's AML/CP T compliance staff.

have been screened by the board of directors before the audit starts

be sufficiently trained in AML to be able to provide an independent review.

Obtaining prior senior manager approval for all related transactions

Understanding the purpose of the business relationship

Performing adverse media searches on the customer

Identifying and verifying the customer's identity

fraudulent identities involving stolen or manufactured identification.

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

hidden beneficial owners.

transaction patterns involving transactions that exceed a certain dollar amount.

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

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

Analyzing customer sentiment through feedback and surveys

Identifying individuals or entities linked to criminal activities or sanctions

Periodically monitoring regulatory updates and enforcement actions for associated entities

Scanning publicly available news articles and regulatory alerts

Monitoring changes in credit scores of individuals or entities

Ensuring sanctions compliance by relying solely on international bodies like the UN because there is no requirement to adhere to local laws

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

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

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

Challenge-response

Fingerprint

Security token

Passphrase

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

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

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

transaction structures that appear unnecessarily complex

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

invoices with prices that are much higher than market price

fluctuations in the pricing of standard goods and services

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

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

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

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

Real estate transactions often involve financial institutions and other professional gatekeepers

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

impose sanctions to maintain or restore international peace and security.

impose sanctions on countries that lack AML/CFT controls.

conduct research on and analyze the impacts of sanctions to improve the effectiveness of sanctions regimes.

impose sanctions on economic targets to maintain or restore financial stability within a country.

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

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

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

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

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

An RAS defines the amount and type of risk an organization is willing to take to achieve its objectives and should be communicated clearly to all stakeholders with corresponding controls implemented

An RAS is a detailed plan for managing operational risks and does not cover strategic or financial risks

An RAS is a formal document meant for regulatory compliance that does not influence day-to-day risk management practices within the organization

An RAS is used to outline the risk tolerance limits to external stakeholders and does not need to be communicated within the organization

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 board of directors should be responsible for overseeing the management of the bank's compliance risk but not involved in establishing a compliance policy that explains the processes by which compliance risks are to be identified and managed throughout the organization.

The board of directors should establish a compliance function and approve the bank's policies for identifying, assessing, monitoring, reporting, and advising on compliance risk.

The compliance function must have sufficient authority, stature, independence, and resources to be effective on its own and should not have access to the board of directors.

The compliance function should report directly to the CEO concerning the bank's compliance with applicable laws, rules, and standards and only update the board of directors on the bank's efforts in managing compliance risk when required.

When using network analysis data to fight money laundering and financial crime, data protection and privacy can be disregarded because fighting crime takes precedent

Network analysis tools are an efficient means of generating relevant results because they only need a limited amount of data and computation power and artificial intelligence (Al) allows less-skilled people to quickly learn to use these systems

When using artificial intelligence (Al) with network analysis tools, it must be ensured that the algorithms used are not biased towards social criteria, such as race, gender, or religion

Network analysis allows for the identification of individuals or entities in a network by analyzing connections or links between them and can be used to study a wide range of systems, such as social or transportation networks

Analyzing relationships between individuals in a social network allows for the identification of hierarchies, the detection of behaviors and geographical movements, or an understanding of how groups are organized

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

Purpose and intended use

Liquidity

Age of the beneficiary

Customer anonymity or third-party transactions

Length of waiting period

Defining a common communication approach and language between all involved parties.

Delays in the investigation due to a foreign FIU awaiting the results of queries performed by third parties.

Conducting an investigation in all countries through which ML funds were transferred when one or more of the countries do not have an FIU.

Investigations which involve high-ranking politicians, who often have influence over the local FIU.

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

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

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

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

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

include all documents or records that assisted the Fl in making the determination that the activity required a filing.

always be limited to account name, account details, and transaction records.

have written policies and procedures to maintain supporting documentation.

be saved in a single separate file with hard copies stored in a fireproof cabinet.

Allow beneficial owners to provide proxies lot voting on corporate decisions

Obscure beneficial ownership

Allow domicile in the nominee's jurisdiction

Derail investigations

Prioritizing resources towards lower-risk areas to reduce workload

Regularly reassessing risks to adjust resource allocation

Allocating more resources to areas with higher financial crime risk

Providing equal resources to all departments to maintain consistency

Using a fixed resource allocation plan without adjustments

Management structure

Governance framework

Asset structure

Origin of the funds

have informal business arrangements between persons or entities.

are located in geographies that are not accountable to US laws.

include trusts, investment funds, and insurance companies.

have limited organizational disclosure and recordkeeping requirements for establishing these business entities.

Wolfsberg Group

Transparency International

Financial Action Task Force (FATF)

Tax Justice Network

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

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

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

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

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.

National Risk Assessment

Regulatory guidance or publications

Government or state-run newspapers

Guidance issued by international bodies

Policies and procedures developed by other banks

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

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.

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.

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.

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.

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

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

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

Oversight of the Financial Intelligence Units in FATF Member countries

Providing a unique platform for information exchange regarding anti-money laundering efforts

Regulation of financial markets through directives and executive orders

Enhancement of international cooperation to foster anti-money laundering efforts via recommendations and guidance

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.

identify and address the current financial crime trends through the issuance of typologies originating in members outside of their FSRB's Jurisdiction.

provide AM L/C FT technical assistance needed by members in their FSRB junsdiction.

coordinate technical assistance for members in their FSRB jurisdiction

set and amend the FATF 40 Recommendations for members in their FSRB jurisdiction.

identify and address any gaps in the AML/CFT policies for members outside of their FSRB jurisdiction.

offer mutual evaluation and follow-up processes for members in their FSRB Jurisdiction.

impose sanctions lo maintain of restore international peace and security

impose sanctions on countries that lack AML/CFT controls.

conduct research on and analyze the impacts of sanctions to improve the effectiveness of sanctions regimes.

impose sanctions on economic targets to maintain or restore financial stability within a country.

integrates seamlessly with existing systems and processes.

meets budget and cost requirements.

automates all regulatory reporting requirements.

replaces manual compliance training for employees.

Financial crime does enormous damage to society, undermining market integrity and consumers' and market participants' confidence

Financial crime risk incidents always result in fines and losses for the financial firm

Financial crime prevention processes make the onboarding process for clients unnecessarily burdensome and complex but create work

Financial crime prevention is important as it reduces costs and improves customer services.

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

Engage in the PPP without strict data sharing protocols, allowing for open and unrestricted flow of information between the bank, FIUs, and other financial institutions

Rely solely on the intelligence provided by government agencies through the PPP because they have the most comprehensive data on suspicious activities

Establish a clear framework within the PPP that outlines data privacy protections and ensures that information sharing complies with legal and regulatory requirements in all jurisdictions involved

Prioritize the bank’s internal data sources over external intelligence from PPPs, as internal data is easier to control and does not present data privacy challenges

triggers identifying static data changes and data based on client's behaviors in real time.

periodic refreshing at one-, three- and five-year cycles.

ability to prioritize better based on client data rather than driven by schedules alone.

classification of clients into categories of risk.

Onsite and offsite reviews, cooperating on an international basis with access to a range of sanctions and outreach

Onsite and offsite reviews, cooperating on an international and domestic basis with access to a range of sanctions and outreach

Offsite reviews, cooperating on a domestic basis with access to a range of sanctions and outreach

Onsite reviews, cooperating on an international and domestic basis with outreach and access to a range of sanctions

Escalate the matter to the institution's high-risk client committee, presenting the investigation findings and recommending offboarding while also acknowledging the relationship manager's concerns

Proceed with offboarding the customer unilaterally based on their investigation findings and anti-money laundering (AML) concerns

Attempt to persuade the relationship manager to agree with the offboarding recommendation by highlighting the potential reputational and regulatory risks associated with maintaining the relationship

Delay the offboarding decision and continue monitoring the customer's activities, waiting for further evidence to solidify the case for termination

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.

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

remote verification of identity by third-party program managers.

heavy usage by senior political figures.

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

heightened risks of returned transactions.

generative copilots.

small language models.

privacy coins.

crypto-mixers.

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

Low thresholds for transactions

Frequent use of cash

Cross-border transactions

Weak KYC policies and procedures

The Financial Action Task Force (FATF)

The AUSTRAC Fintel Alliance

The Egmont Group

The Wolfsberg Group

increased reputation risk.

inclusion on the UN Consolidated List.

civil and criminal penalties

delisting of public filing status.

Use a static risk assessment model that remains unchanged until a significant regulatory update occurs to ensure consistency in the evaluation process over time

Delegate the risk assessment process to individual business units to conduct independently and allow for specialized assessments tailored to each unit's specific activities

Conduct a periodic enterprise-wide risk assessment that includes identifying inherent risks, evaluating the effectiveness of existing controls, and determining residual risks

Focus primarily on AML risk assessments, as these are typically the most scrutinized by regulators, while addressing other financial crime risks only when issues are identified

Reviewing the enterprise-wide risk assessment methodology

Enhancing staff training on the documentation of justification on closed alerts

Revisiting the post-transaction monitoring system parameters and thresholds

Reviewing the fuzzy logic currently adopted in the screening system

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

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.

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

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.