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

Some MSBs provide bureau de change services to retail customers after they complete a due diligence process.

Some MSBs process large, individual cash transactions on behalf of customers.

Some MSBs allow regular and frequent transactions to the same family members based in another country

Some MSBs process small remittance payments on behalf of workers based abroad sending money home.

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.

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

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

defining exactly what policies and procedures must be implemented.

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

Pre-populated templates for SAR filing

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

Automated case prioritization based on risk scoring

AI-powered dashboards summarizing flagged transactions

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

Use of wire transfers

Loitering

Instructions or involvement from third parties

Amended letters of credit without reasonable justification

Non-standard settlement arrangements

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

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

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

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

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

exchange strategic information between FlUs and obliged entities

exchange strategic information between financial institutions

exchange operational information between public authorities and obliged entities

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

Wolfsberg Group

Transparency International

Financial Action Task Force (FATF)

Tax Justice Network

ML undermines the integrity and stability of financial systems and makes them vulnerable to illegal activity. This can erode investor confidence and hinder economic growth.

When a financial institution (FI) is found to be promoting ML or violating AFC regulations, this can lead to a loss of confidence in the institution and a loss of customers. Interestingly, this scenario might sidestep any legal consequences for the Fl.

When laundered funds flow into legitimate economies, they can be used for illegal purposes, such as funding terrorist activities or organized crime. This distorts resource allocation and undermines development.

Jurisdictions perceived as having insufficient ML measures might be identified as uncooperative or high-risk, potentially facing restricted access to international markets, though economic sanctions by other countries are an unlikely outcome.

Media searches reveal a report that the customer was accused of misconduct three years ago.

The EU bank considers the origin and destination countries Involved in the transactions to be high-risk.

The customer's activity includes multiple cross-border transactions involving various counterparties.

The EU bank received no originator or beneficiary information for the wire transfers.

The customer specializes in the import and export of petrochemical products.

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.

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.

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

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

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.

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.

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

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

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

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

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

Policies are broad guidelines. Procedures are detailed instructions for specific processes. Only procedures are mandatory for knowledge and adherence.

Policies define the principles of an organization and influence the drafting of procedures. Procedures are detailed instructions for specific processes.

Policies are detailed instructions for specific processes. Procedures are an overarching framework. Neither policies nor procedures are mandatory for knowledge and adherence.

Policies are detailed instructions for specific processes. Procedures are an overarching framework. Both policies and procedures are mandatory for knowledge and adherence.

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

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

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

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

Accountants being used as intermediaries to introduce criminals to financial institutions

up to date and reflects all relevant regulatory developments

signed off by the board of directors and regulators

approved by the clients and third parties

clearly communicated and understood by staff

A customer receives funds from a popular decentralized mixer

A customer uses funds from their monthly income to purchase virtual currency

A customer makes a transaction on the blockchain that their traditional financial institution is unaware of

A customer receives multiple wires from different sources and uses those funds to purchase virtual currency

Vishing

Pharming

SMSishing

Spear phishing

the operational burden of dealing with potential matches.

the value of fines for non-compliance.

the experience of the team dealing with potential matches.

whether the data to be screened is reliable and verified.

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

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

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

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

Money services business (MSB)

Multinational corporations

Individual foreign customers

Non-profit organizations with international operations

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.

public administration.

legal assessment.

law enforcement.

legal activity.

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.

Determining detailed risk profiles for customers based on their activities and relationships

Focusing monitoring primarily on previously flagged customers while using standard controls for others

Choosing and applying effective controls that align with the identified risk levels

Performing a comprehensive risk assessment to identify customer, transaction, and geographic risks

Allocating resources equally across all customer segments to ensure fairness

Types of payment messages

Customers

Third-party service providers

Customer spouses

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

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

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

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

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

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.

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

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

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.

E-commerce platforms exploited to move criminal proceeds

Use of stolen bank cards for online purchases

E-commerce platforms susceptible to fraud schemes

E-commerce platforms used as a front for illicit transactions

E-commerce platforms encouraging unregulated peer-to-peer lending

Use of foreign currency to mask criminal proceeds

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

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

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

Companies operating in cash intense businesses not subject to licensing requirement

Companies operating hospitals and health-care services

Companies operating in cash intense businesses subject to licensing requirement

Companies producing pharmaceutical products and medical devices, companies active in the mining industry

Companies operating retail shops countrywide

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)

Helping overcome data protection and information sharing limitations

Enhancing the quality of reporting and additional informational input

Helping to alleviate the financial cost burden on law enforcement

Helping to design common approaches and identify desired deliverables

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

Consistency of approach

Periodic training of the function

Qualification of the team

Independent testing

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.

increased reputation risk.

inclusion on the UN Consolidated List.

civil and criminal penalties

delisting of public filing status.

Past employment records.

Personal references from close associates.

Personal resume.

Internet and public media searches.

Criminal history searches.

Allow beneficial owners to provide proxies lot voting on corporate decisions

Obscure beneficial ownership

Allow domicile in the nominee's jurisdiction

Derail investigations

imposes economic sanctions on jurisdictions with lax AML controls to force them to strengthen their controls.

conducts on-site inspections of financial institutions in jurisdictions with lax AML controls to identify deficiencies and recommend improvements.

publishes annual reports ranking all member jurisdictions based on their self-assessment of AML controls.

conducts a peer review process whereby member countries assess the AML controls of other jurisdictions and provide recommendations for improvement.

using shell companies or trusts for privacy, lax planning, or asset protection.

in the names of unrelated thud patties.

using the proceeds from selling a prior property or liquidating investments to make an all-cash purchase

using legal entities and intermediaries to protect the privacy of the purchasers.

using loans backed by cash or certificates of deposit.

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

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.

cross-border purchases

purchases in the name of a natural person

paying true market price for a property

non-financed purchases

The bank is likely to face secondary sanctions from global financial institutions despite addressing many of the previous concerns.

The bank may face civil or criminal penalties if it is unable to demonstrate sustained improvement in addressing the previous concerns.

The bank may face the risk of regulatory orders to remediate its AML program despite addressing many of the previous concerns.

The bank is protected from reputational risk arising from any regulatory action because regulatory orders must remain confidential.

The regulatory agency may require the bank's board of directors to publicly share the actions taken to address the previous concerns in order to limit its reputational risk.

Private bankers should receive training on AML procedures.

All employees should receive refresher AML training.

The board should review and approve a revised AML policy to change customer due diligence requirements in private banking.

The legal department should conduct a review to assess potential legal consequences.

Independent compliance testing

Qualified and knowledgeable staff

Third-party screening software

An automated monitoring system

Written policy and procedures

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

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

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

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

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

to force developing nations to adopt liberal or substantive democracies.

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

to punish governments for having weak financial crime controls.

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

to support the protection of human rights.

collaborating with law enforcement agencies, financial institutions, and other stakeholders to detect and prevent Illicit financial activities.

conducting examinations of financial institutions to ensure compliance with anti-money laundering regulations.

engaging in providing financial services, including banking and investment activities, to the public and private sectors

facilitating the exchange of information between the public and private sectors.

enacting legislation regarding the operations of financial institutions.

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

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.

integrates seamlessly with existing systems and processes.

meets budget and cost requirements.

automates all regulatory reporting requirements.

replaces manual compliance training for employees.

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

implementing new controls to eliminate all risks

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

documenting the historical risk incidents for future reference.

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.