ACAMS CAMS Dumps

The most effective strategy is to ensure that jurisdictional and other relevant risks are assessed through the Enterprise-Wide Risk Assessment (EWRA), and that any residual risks fall within the corporation’s defined risk appetite. This structured, risk-based approach supports informed decision-making and protects against reputational damage related to financial crime.

The US Department of the Treasury identifies money services businesses (MSBs) and non-profit organizations with international operations as high money laundering risks when they lose access to traditional financial institutions, as this can push them toward less regulated channels that are more vulnerable to abuse.

In situations involving significant AML concerns, especially with high-risk clients, thecompliance officer must follow proper escalation procedureswithin the institution. The appropriate course of action is toescalate the matter to a senior governance body, such as ahigh-risk client committee, which is typically tasked with balancing AML risk against business considerations.

Unilateral offboarding (Option B)may violate internal protocols.

Persuading the relationship manager (Option C)bypasses formal governance.

Delaying action (Option D)risks further exposure to regulatory or reputational damage.

This escalation ensuresdocumented risk-based decision-makingand demonstrates to regulators that the institution appliesstructured and objective AML governance.

Using brokerage accounts like deposit accounts (e.g., frequent cash deposits or withdrawals) and conducting transactions through nominees or third parties are common red flags in the securities industry. These behaviors can obscure the origin or ownership of funds and are often used to facilitate money laundering.

The Wolfsberg Group and Transparency International are non-governmental organizations that provide information and guidance on AML/CFT matters, helping institutions and policymakers strengthen financial crime prevention practices.

Potential indicators of terrorist financing abuse in non-profit organizations include large, unaccounted cash donations from anonymous sources, which can disguise illicit funding, and operations in high-risk jurisdictions with limited oversight, where regulatory and monitoring frameworks may be weak.

Percentage change in transaction monitoring alerts escalated for investigation and number/percentage of senior PEPs onboarded are key risk indicators that can highlight shifts in the inherent risk profile of the customer base, enabling leadership to proactively address emerging financial crime risks.

Conceptual soundness validation is a foundational element of AML model governance and is emphasized in regulatory guidance on model risk management. It focuses on whether the design, logic, assumptions, and methodology of a model are appropriate for its intended purpose.

Validating conceptual soundness ensures that the model’s underlying framework makes sense for identifying money laundering and terrorist financing risks. This includes evaluating scenario logic, risk factors, thresholds, segmentation, and assumptions used in detection.

Statistical validation and performance testing are separate steps that assess outcomes and predictive power, while technology compatibility relates to system implementation rather than conceptual design. Alignment with regulatory guidance is important, but it is not the core objective of conceptual soundness testing.

Regulators expect institutions to demonstrate that their AML models are fit for purpose before relying on them operationally.

A risk-based approach to anti-financial crimes means allocating resources and implementing controls proportionate to the level of identified risk. This ensures that higher-risk areas receive more focus and resources, improving both effectiveness and efficiency in mitigating financial crime risks.

When reviewing business operations of a Money Services Business (MSB), it is critical to identify behaviors that indicate potential money laundering activity. TheCAMS Study Guide – 6th Editionoutlines severalred flagscommonly associated with MSBs.

Option Ais correct:

A customer beinghesitant to provide beneficiary information, such as the name or address, is a red flag. It may indicate attempts to hide the true purpose or recipient of the funds and could suggeststructuring or layering activity.

Option Dis correct:

A customer usingmultiple accounts under different namesto conduct transactions is a strong red flag. This could indicate efforts toobscure ownership, avoid detection, or conductsuspicious structuringbehavior to stay below reporting thresholds.

Option Bis incorrect:

While large cash deposits from cash-intensive businesses may require further review, they are not inherently suspicious unlessinconsistent with the nature of the business or transaction volume.

Option Cis incorrect:

Currency exchanges under the reporting threshold, even from high-risk jurisdictions, are not in themselves red flags unless they show a pattern ofstructuringor are part oflarger suspicious behavior.

Option Eis incorrect:

Frequent small-dollar transfers to a native country may benormal remittance behaviorand only become suspicious if tied to additional indicators such asstructuring or third-party involvement.

Nominee shareholders may be used for legitimate commercial reasons; however, FATF guidance identifies nominee arrangements as a significant money laundering risk when they obscure beneficial ownership.

The greatest risk arises when nominee shareholders provide anonymity to the true beneficial owner, preventing transparency in public registers and complicating due diligence. Criminals may exploit this opacity to conceal ownership, evade sanctions, launder illicit proceeds, or avoid tax and regulatory scrutiny.

The ability to hide ownership undermines one of the core objectives of AML/CFT frameworks: identifying and verifying beneficial owners. As a result, regulators require enhanced due diligence and clear documentation when nominee shareholders are involved.

Other features—such as administrative efficiency, compliance with local laws, or ease of share transfer—do not inherently increase financial crime risk when transparency and disclosure requirements are met.

The FATF’s core role is to enhance international cooperation against money laundering and terrorist financing through setting global standards (“Recommendations”) and issuing guidance.

“The FATF is an intergovernmental body whose purpose is the development and promotion of national and international policies to combat money laundering and terrorist financing.”

The FATF does not have authority to oversee FIUs, nor does it regulate financial markets directly.

Virtual Asset Service Providers (VASPs) are considered higher-risk customers under FATF guidance due to their exposure to anonymity, speed of transactions, and cross-border activity. When onboarding a VASP, a financial institution must conduct a thorough risk assessment to determine whether the relationship aligns with its financial crime risk appetite.

Understanding the percentage of higher-risk clients served by the VASP is critical, as it indicates the level of exposure to illicit activity and the robustness of the VASP’s own risk management practices. A high concentration of higher-risk customers may significantly increase money laundering and terrorist financing risk.

Identifying which registered institutions act on behalf of the VASP, such as wallet providers or exchange operators, is also essential. Reliance on third parties introduces additional risk and requires assessment of those entities’ regulatory status and AML controls.

Finally, knowing who the VASP’s clients are, including the proportion of foreign versus domestic customers, is a core component of geographic and customer risk analysis. Cross-border exposure often elevates risk due to differing regulatory standards.

Data privacy practices and the use of central bank digital currencies, while relevant operational considerations, are not primary determinants of AML risk appetite decisions.

The combination of frequent address changes and a recent change in the ultimate beneficial owner raises potential red flags that warrant immediate investigation. To mitigate risk, the insurance company should investigate these changes and temporarily decline any payment or withdrawal instructions until the review is complete and appropriate steps are agreed upon. This ensures both regulatory compliance and protection against potential misuse of the policy.

Governance arrangements (A):“Sound governance and risk management arrangements are fundamental to assessing and managing ML/TF risk in products and services.”(CAMS 6th Edition, Risk-Based Approach for Products and Services)

Complexity of the products (B):“Complexity increases risk—products that are highly complex, opaque, or allow for multiple layers or jurisdictions are more vulnerable to misuse for ML/TF.”(CAMS 6th Edition, Product Risk Assessment)

Incorrect Options:

C: Last audit results inform program effectiveness, not inherent product risk.

D: Business financial status is considered in customer risk assessment, not product risk.

E-commerce business models are exposed to several financial crime risks that are clearly identified in Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) regulatory guidance, including publications from the Financial Action Task Force (FATF) and national supervisory authorities.

One key risk is the use of stolen bank card or payment data to purchase goods or services online. E-commerce platforms are particularly vulnerable to card-not-present fraud, where criminals exploit remote payment channels to generate illicit proceeds.

Another common risk is fraud against customers through non-delivery of goods or services. In these cases, fraudulent merchants accept payments without any intention of fulfilling orders. This form of consumer fraud is recognized as a predicate offense to money laundering under AML frameworks.

Additionally, online marketplaces may be abused to move or disguise criminally obtained funds. Criminals may conduct fake transactions, self-purchases, or repeatedly buy and resell goods to legitimize illicit funds. This activity aligns with recognized typologies such as transaction laundering and trade-based money laundering.

Although export control evasion and bribery and corruption are serious financial crimes, they are not typically considered common or inherent financial crime risks specific to standard e-commerce business models in AML/CFT guidance.

The relationship manager is in the best position to identify and report money laundering risks due to their direct and ongoing interaction with clients. They have detailed knowledge of clients’ profiles, financial behaviors, and any unusual activities that may raise red flags.

A robust transaction monitoring system is a core component of an effective Anti-Money Laundering (AML) and Counter-Financial Crime (AFC) program. Regulatory guidance from FATF and national supervisors emphasizes that the primary purpose of transaction monitoring systems is to detect unusual or suspicious activity by analyzing customer transactions and identifying anomalies or patterns that may indicate money laundering, terrorist financing, or other financial crimes.

These systems use predefined rules, thresholds, and increasingly advanced analytics to monitor transactions in real time or retrospectively. Alerts generated by the system are reviewed by compliance professionals, who determine whether further investigation or reporting is required.

While transaction monitoring systems may support the preparation of regulatory reports, such as SARs or CTRs, the actual filing of these reports typically requires human review and approval and is not the defining capability of the monitoring system itself. Features such as automatic document translation or integration of social media profiles are not considered core or necessary functions under AML regulatory expectations.

Therefore, the essential capability of a robust transaction monitoring system is its ability to monitor transactions and detect anomalies indicative of suspicious activity.

A global organization must ensure its group policies accommodate compliance with each country’s specific AML and sanctions regulations to effectively manage risks across multiple jurisdictions.

Using multiple sanctions lists ensures that financial institutions meet international regulatory obligations and can identify sanctions-related risks across different jurisdictions. This comprehensive approach strengthens compliance and reduces the likelihood of exposure to sanctioned individuals or entities.

Public-Private Partnerships (PPPs)are collaborative initiatives involvinglaw enforcement, FIUs, and financial institutions. Their objective is to improve theefficiency and effectivenessof the fight against money laundering, terrorist financing, and other financial crimes bysharing both operational and strategic intelligence.

Option A – Exchange operational information between public authorities and obliged entities:

PPPs often facilitate real-time or near-real-time information sharing that supportsspecific investigations and the detection of suspicious activity, helping financial institutions respond quickly and accurately to ongoing threats.

Option B – Exchange strategic information between FIUs and obliged entities:

Strategic-level intelligence sharing helps financial institutionsunderstand typologies, risk trends, and evolving criminal methods, thereby strengthening their risk assessments and transaction monitoring frameworks.

Option Cis incorrect: Strategic information exchange between private institutions is limited and heavily regulated.

Option Dis incorrect: FATF does not collect or manage databases of suspicious activity reports; it sets standards and reviews national frameworks.

Trade finance red flags include account activity inconsistent with the account's stated purpose, unnecessarily complex transaction structures, poorly worded or foreign-language trade documents that may obscure details, and invoices with prices significantly above market value, which can indicate trade-based money laundering or fraud.

Transaction monitoring governanceinvolves ensuring thatAML detection systems are effective, aligned with regulatory standards, and capable of identifying evolving threats.

Option B (Correct):Legal cooperation is essential for responding to subpoenas and law enforcement inquiries.

Option D (Correct):Regularly updating transaction monitoring scenarios ensures that the system adapts to emerging financial crime trends.

Why Other Options Are Incorrect:

Option A (Incorrect):SARs cannot be withdrawn unless an error was made—once filed, SARs remain confidential and must be retained.

Option C (Incorrect):Client profile updates are a CDD/KYC function, not directly related to transaction monitoring governance.

Best Practices for Transaction Monitoring Governance:

Regularly review system effectiveness through validation tests.

Collaborate with legal and compliance teams for risk mitigation.

Use AI and data analytics to refine detection accuracy.

Tax evasion is a criminal offense and is widely recognized as a predicate offense to money laundering under FATF standards and national AML laws.

It involves the deliberate non-payment or under-reporting of taxes, often through false declarations, concealment of income, or failure to file required tax returns. The key distinction is intentional deception of tax authorities.

In contrast, tax avoidance refers to lawful strategies used to minimize tax liability within the boundaries of the law. Deductions and tax planning activities are legal and do not constitute tax evasion.

Because tax evasion generates illicit proceeds, it is directly relevant to AML/CFT frameworks, and financial institutions must be alert to indicators of tax-related financial crime.

B: If a bank fails to demonstrate sustained improvement or cannot resolve identified deficiencies, it can face civil or even criminal penalties from regulators. Regulators expect not just policy changes, but proof of effectiveness and ongoing compliance improvements.

C: Even after addressing many concerns, if all issues are not resolved—such as outstanding transaction monitoring backlogs—regulators may issue orders to further remediate the AML program until full compliance is achieved.

CAMS 6th Edition and regulatory guidance clarify that “regulators may impose penalties, issue consent orders, or require further remediation where weaknesses persist.”

Incorrect:

A: Secondary sanctions generally apply to sanctions violations, not standard AML program weaknesses.

D: Regulatory actions can be public and do pose reputational risk.

E: While transparency is sometimes required, this is not a universal regulatory response.

OFAC sanctions are a key element of the U.S. AML/CFT framework. According to the CAMS 6th Edition and OFAC regulations:

Blocked funds must be placed into an interest-bearing account on a financial institution's books (B):“Blocked property must be held in a separate interest-bearing account on the books of the U.S. financial institution.”(CAMS 6th Edition, Sanctions Compliance; OFAC FAQs)

Sanctions can be either comprehensive or selective using the blocking of assets and trade restrictions (C):“OFAC administers both comprehensive and targeted (selective) sanctions programs to fulfill U.S. foreign policy and national security goals.”(CAMS 6th Edition, Sanctions Compliance)

Incorrect Options:

A: OFAC can sanction entities, vessels, and organizations—not just individuals or those in foreign countries.

D: There is no automatic expiration of OFAC sanctions after five years.

A: The absence of professional oversight or accounting/auditing standards creates a high-risk environment for financial statement manipulation. Without external checks or mandated standards, criminals can more easily falsify statements to hide illicit assets.

“The lack of regulatory oversight and professional standards in accounting and auditing significantly increases the risk of manipulation and fraud in financial reporting.”(CAMS 6th Edition, Professional Service Providers; FATF Guidance on the Risk-Based Approach for Accountants)

Public-private partnerships facilitate strategic information exchange between FIUs and obliged entities and operational information sharing between public authorities and obliged entities, improving collaboration and effectiveness in detecting and preventing financial crime.

Accounting can help detect irregular financial patterns, technology solutions and IT security provide systems for monitoring and data protection, and fraud risk management identifies and mitigates suspicious activities - all of which are essential to supporting AML and sanctions compliance programs.

Public-private partnerships help develop a culture of compliance across sectors and improve the quality and quantity of data through information sharing, enhancing the collective ability to detect and prevent financial crime.

An effective name screening process is a critical component of sanctions and AML compliance. Regulators expect financial institutions to implement strong governance, risk-based design, and ongoing validation.

Clearly defining the screening scope, frequency, and alert adjudication procedures in policies ensures consistency, transparency, and accountability across the organization.

Conducting a risk assessment allows institutions to make informed, proportionate decisions on which data attributes to screen (e.g., names, aliases, addresses), how frequently to screen, and which databases to use. This aligns with the risk-based approach.

Regular testing and validation ensure that screening systems continue to perform as intended, detect true matches, and minimize false positives or missed hits.

Selecting the most popular database or assigning a single individual for control ownership does not ensure effectiveness and may introduce governance risk.

Open-source tools offer cost-effective access to diverse data sources, making them valuable for financial crime investigations. They also support partial automation of data collection and analysis, reducing manual effort and improving efficiency in identifying suspicious patterns or links.

Fingerprint is an inherent factor because it is a biometric trait - something the user is. Inherent factors rely on physical or behavioral characteristics such as fingerprints, facial recognition, or voice, which are unique to the individual.

Financial institutions should have a standardized process for terminating customer relationships, including conducting risk assessments and documenting the reasons for termination. A final review of the customer’s transaction history helps address any outstanding concerns or unresolved issues. Keeping thorough records of the termination process ensures compliance and provides documentation in case of any future inquiries or disputes.

Cryptoassets, such as cryptocurrencies, pose specific ML/TF risks due to their technological characteristics and usage patterns:

Potential for anonymity (C): Cryptoassets allow users to make transactions without revealing their true identities, which hinders law enforcement from tracking illicit activity. The CAMS 6th Edition states:“Cryptoassets can be transferred or exchanged between users without the need for identification, presenting a significant risk due to the potential for anonymity.”(CAMS 6th Edition, Chapter: Risks and Methods of Money Laundering and Terrorist Financing, Virtual Assets section)

Global reach (D): Cryptoassets operate on a global scale, enabling rapid cross-border transfers without the limitations of traditional financial systems. This increases the complexity of monitoring and controlling illicit transactions.“The global nature of virtual assets makes it easy for criminals to move value across borders quickly, evading jurisdictional controls.”(CAMS 6th Edition; FATF Guidance on Virtual Assets 2019)

Use to layer illicit funds (F): The ability to move cryptoassets between numerous wallets and exchanges allows criminals to obscure the source of funds through layering, a key stage of money laundering.“Layering can be achieved by rapidly moving cryptoassets between wallets, exchanges, and across different jurisdictions, making tracing more difficult.”(CAMS 6th Edition, Chapter: Risks and Methods of Money Laundering and Terrorist Financing)

In a mutual evaluation, a country must demonstrate to the FATF that it has an effective framework to protect its financial system from abuse. This process assesses both technical compliance with FATF Recommendations and the effectiveness of the country's AML/CFT measures.

Before opening for business, a bank must have independent compliance testing to ensure controls are functioning, qualified staff who understand AML/CFT requirements, and documented policies and procedures to guide day-to-day compliance. These are foundational elements of an effective AML/CFT framework.

Professional service providers can be misused as enablers of money laundering when they abuse their trusted positions and expertise. FATF guidance highlights several risks linked to such abuse.

The creation of shell companies is a common method used to obscure beneficial ownership and facilitate placement or layering of illicit funds. Similarly, opening third-party accounts to mask the true client identity directly undermines transparency and due diligence requirements.

Additionally, actively directing or facilitating the structuring or movement of illicit funds constitutes direct involvement in money laundering schemes and is a serious criminal offense.

By contrast, opening estate or trust accounts for legitimate, transparent purposes does not inherently pose a financial crime risk when proper due diligence is applied.

Case notes should document who made the decision and the rationale for not filing the SAR to ensure transparency, support auditability, and demonstrate compliance with regulatory expectations.

In anEnterprise-Wide Risk Assessment (EWRA),residual riskis the level of risk that remains after applying mitigating controls to theinherent risk(the risk present before controls are applied).

In this scenario, theinherent risk is highdue to the nature of private banking—high net worth clients,cross-border transactions,complex ownership structures, andhigh-value financial products. However, the institution has implementedrobust CDD and EDD, as well asadvanced transaction monitoring systems.

According to the CAMS Study Guide – 6th Edition, wheneffective and properly implemented controlsare in place, they cansignificantly reducethe residual risk—even in high-risk business areas like private banking. However, no control framework caneliminate all riskentirely.

Option Ais correct: Controls can significantly reduce the residual risk when strong, effective systems and procedures are in place.

Option Bis partially true but suggests inadequacy, which is not indicated here.

Option Cincorrectly assumes residual risk cannot be lowered even with controls.

Option Dis incorrect because residual riskcannot be eliminated entirely.

After identifying and rating inherent risks, the next key step in the risk assessment process is to evaluate the effectiveness of existing controls. This allows the organization to calculate the residual risk - i.e., the level of risk remaining after controls are applied.

Predicate offenses are crimes that generate proceeds which may subsequently be laundered. FATF standards and national AML laws define a wide range of serious crimes as predicate offenses.

Bribery and corruption are among the most common predicate offenses, often involving large illicit payments that require laundering to disguise their origin. Fraud, including financial, consumer, and corporate fraud, is another primary source of illicit proceeds and is universally recognized as a predicate offense.

Organized crime and racketeering encompass coordinated criminal activities designed to generate ongoing illegal income, making them central predicate offenses under AML frameworks.

While arson may be considered a serious crime in some jurisdictions, and assault is generally not associated with financial gain, AML regimes focus primarily on crimes that generate substantial proceeds. Therefore, bribery, fraud, and organized crime are the most consistently recognized predicate offenses across jurisdictions.

The Bank Secrecy Act (BSA) is the foundational Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) law in the United States. Enacted in 1970, the BSA requires financial institutions to establish and maintain effective AML programs designed to detect and prevent money laundering and terrorist financing.

Under the BSA and its implementing regulations, financial institutions must implement key controls such as Customer Identification Programs (CIP), customer due diligence (CDD), enhanced due diligence (EDD) for higher-risk customers, transaction monitoring, record-keeping, and the filing of Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) with FinCEN.

While the USA PATRIOT Act expanded AML obligations—particularly in relation to terrorist financing—it amended and strengthened the BSA rather than replacing it. The Money Laundering Control Act criminalized money laundering activities but does not establish the operational compliance framework. MiCA is an EU regulation and does not apply in the U.S.

Therefore, the BSA remains the cornerstone of U.S. AML/CFT compliance requirements.

When using network analysis tools, it’s important to avoid algorithmic bias toward social criteria to ensure fairness, analyze connections between individuals or entities to identify links and structures, and study relationships within networks to uncover hierarchies, behaviors, movements, and group organization relevant to detecting criminal activity.

This scenario presents multiple classic money laundering red flags, particularly within the life insurance sector, which is recognized by FATF as vulnerable to misuse due to its investment and payout features.

The use of an offshore trust in a jurisdiction with no clear link to the customer raises concerns about concealment of beneficial ownership and layering. Criminals frequently use trusts and offshore structures to obscure the origin and destination of illicit funds.

The client’s request to split premium payments into multiple transactions to avoid bank charges is indicative of structuring, a known money laundering technique used to evade monitoring and reporting thresholds.

Furthermore, the lack of a legitimate source of wealth or income consistent with the high-value policy is a significant red flag. Purchasing high-value insurance products with no apparent financial means is a common placement method for laundering illicit proceeds.

While fraud or sanctions evasion could be relevant in other contexts, the combination of structuring, unexplained wealth, offshore structures, and non-residency most strongly indicates money laundering risk.

UN sanctions regimes are not punitive but aim to:

B: “Support peaceful resolution of conflicts.”

D: “Deter non-democratic and unconstitutional changes of government.”

E: “Promote respect for human rights and humanitarian law.”(CAMS 6th Edition, United Nations Sanctions; UN Security Council Mandates)

Incorrect:

A: The UN does not impose sanctions to force regime type.

C: Sanctions are not for punishing weak AML controls.

Regulatory frameworks and enforcement actions consistently emphasize individual accountability at the highest levels of governance when AML/CFT compliance programs are deficient in design or implementation.

The board of directors is ultimately responsible for oversight of the institution’s AML/CFT framework. This includes approving policies, setting risk appetite, and ensuring that adequate resources and governance structures are in place. Failure to fulfill these responsibilities can result in regulatory findings and personal accountability.

Senior management is responsible for implementing the board-approved AML/CFT strategy and ensuring that controls operate effectively in practice. This includes overseeing compliance functions, addressing identified weaknesses, and ensuring timely remediation. Deficiencies in program design—such as inadequate risk assessments or ineffective controls—often lead regulators to hold senior management accountable.

While the compliance department plays an important role in execution and advisory functions, accountability for program design and effectiveness rests with the board and senior management, not committees or individual departments.

The Office of Foreign Assets Control (OFAC), part of the U.S. Department of the Treasury, is responsible for theadministration and enforcement of economic and trade sanctions. These sanctions are based on U.S. foreign policy and national security objectives and target:

Foreign countries and regimes

Terrorist organizations

Narcotics traffickers

Individuals and entities engaged in activities related to the proliferation of weapons of mass destruction

OFAC acts under various authorities, including national emergency powers granted by the President and specific legislation. One of its primary tools is theSpecially Designated Nationals(SDN) List, which identifies individuals and entities whose assets are blocked and with whom U.S. persons are generally prohibited from dealing.

It is important to note that OFAC is not responsible for designating jurisdictions as primary money laundering concerns (a task handled by FinCEN under Section 311 of the USA PATRIOT Act), nor does it manage trade agreements.

A low number of sanctions screening alerts relative to the size and scope of operations may indicate overly restrictive or inappropriate monitoring parameters. Revisiting and adjusting the post-transaction monitoring system parameters and thresholds ensures that the system is calibrated to detect potential sanctions breaches effectively.

Accountants are classified as designated non-financial businesses and professions (DNFBPs) under FATF standards and must apply a risk-based approach to AML/CFT compliance.

A customer acceptance policy is a key tool that helps accountants define which clients or engagements fall outside their risk appetite. This supports consistent onboarding decisions and ensures high-risk clients are either subject to enhanced due diligence or declined.

Additionally, due to the nature of accounting services—such as advisory, tax preparation, and financial reporting—traditional automated transaction monitoring systems used by banks are often not appropriate. Instead, accountants rely more heavily on engagement-based risk assessments, client profiling, and professional judgment.

Accountants are subject to record-keeping requirements longer than two years in most jurisdictions, and geographic risk is always relevant when assessing AML/CFT exposure. Risk assessments must be comprehensive and proportionate, not artificially limited.

Virtual Asset Service Providers (VASPs) are considered higher-risk customers due to their exposure to anonymity, speed, and cross-border transactions. FATF guidance highlights several red flags indicative of potential money laundering activity.

The use of shell companies to move funds into and out of a VASP is a strong indicator of attempts to conceal beneficial ownership and obscure transaction flows. Similarly, frequent use of mixers and tumblers is a well-recognized technique used to break transaction trails and hinder blockchain tracing.

Receiving funds from jurisdictions with weak AML frameworks significantly increases geographic risk, particularly when combined with other red flags.

By contrast, peer-to-peer infrastructure use and market volatility are inherent features of the virtual asset ecosystem and do not, on their own, indicate money laundering.

Adverse media screening is an important component of customer due diligence, but reliance on general search engines presents several limitations recognized by AML practitioners and regulators.

Search engines typically provide unstructured data, which makes it difficult to systematically analyze and document results for compliance purposes. Information may be incomplete, duplicated, or lack context.

The process is also time-consuming and highly manual, particularly for institutions screening large customer populations. Manual reviews increase operational burden and introduce inconsistency and human error.

Additionally, search engine algorithms vary, meaning results can differ depending on timing, location, and personalization, leading to inconsistent outcomes that are difficult to audit or reproduce.

While language coverage and relevance may be challenges, the most critical limitations relate to lack of structure, inefficiency, and inconsistent results.

The Basel Committee on Banking Supervision (BCBS) requires that the board of directors establish and oversee the compliance function and approve the bank's AML/CTF compliance policies and procedures, including processes for identifying, assessing, monitoring, and reporting compliance risks.

“The board of directors should establish a compliance function and approve compliance policies and processes for identifying, assessing, monitoring, and reporting compliance risks throughout the organization.”

(CAMS 6th Edition, Corporate Governance and Oversight; BCBS, Corporate Governance Principles for Banks, Principle 6)

Large individual cash transactions pose the highest money laundering risk for money services businesses. Cash is difficult to trace and, when handled in significant amounts, can be used to introduce illicit funds into the financial system with minimal transparency.

Residual risk represents the remaining level of risk after considering the effectiveness of controls. Under a risk-based approach, strong controls reduce risk, while weak or ineffective controls increase it.

In this scenario, the inherent risk is assessed as moderate, meaning the underlying exposure is neither low nor extreme. However, the controls are evaluated as less than satisfactory, indicating that existing measures are not adequately mitigating the identified risks.

When controls are weak, residual risk increases above the inherent risk level, as vulnerabilities remain unaddressed. Regulators expect financial institutions to escalate residual risk ratings and implement remediation plans in such cases.

Therefore, the most likely residual risk conclusion is high, reflecting the combination of moderate inherent risk and ineffective controls. This outcome aligns with AML best practice and regulatory expectations.

Explainable artificial intelligence (AI) and machine learning (ML) technologies are increasingly adopted within AML/CFT compliance to enhance effectiveness while maintaining regulatory transparency. Regulators emphasize that explainability and human oversight are essential when using advanced analytics.

One key benefit is the ability to process and analyze large volumes of data quickly and accurately. AML programs must review massive transaction datasets, customer profiles, and behavioral patterns. AI and ML models improve detection capabilities by identifying complex patterns and anomalies that may not be evident through traditional rule-based systems.

Another critical benefit of explainable AI is improved auditability, accountability, and governance. Explainable models allow compliance teams, auditors, and regulators to understand how decisions are made, why alerts are generated, and how risks are assessed. This transparency supports regulatory compliance and model governance requirements.

AI systems are not intended to replace human involvement or eliminate compliance staff. Human judgment remains essential for investigations, decision-making, and regulatory reporting.

Reference data screening is a core element of AML/CFT programs and typically covers:

Customers (B):“All customers must be screened against sanctions, PEP, and adverse media lists as part of onboarding and ongoing due diligence.”(CAMS 6th Edition, Due Diligence and Screening)

Third-party service providers (C):“Screening should extend to relevant third parties, such as agents and service providers, to prevent indirect exposure to sanctioned entities.”(CAMS 6th Edition, Third-Party Screening; FATF Recommendations)

Incorrect Options:

A: Types of payment messages are not screened; the entities/individuals are.

D: Customer spouses may be screened in some KYC processes but are not a standard dataset for reference screening.

A proposed EU import ban on refined oil products would be of greatest concern to the bank’s trade finance services, as it directly targets a core revenue-generating sector (oil production) of the company’s country. This could lead to significant disruptions in trade flows, regulatory risk exposure, and potential sanctions violations.

Unusual wire transfer transactions may include transfers in different currencies between accounts at different banks for the same client, which can be used to obscure fund flows, and incoming third-party transfers followed by real estate purchases, which may indicate layering and integration stages of money laundering. These patterns deviate from typical financial behavior and warrant closer scrutiny.

A National Risk Assessment (NRA) provides valuable guidance on which customers, products, services, and transactions pose the highest risk for money laundering and terrorist financing, enabling financial institutions to tailor their risk-based approach and allocate resources more effectively.

Appointing individuals to serve in official capacities poses a higher money laundering risk because it can be used to obscure the true beneficial ownership and control of the company, making it easier to conceal illicit activities or the identity of those directing the business.

FATF standards identify several designated non-financial businesses and professions (DNFBPs) as obliged entities due to their exposure to money laundering risks. These gatekeepers are required to perform customer due diligence (CDD).

Notaries involved in real estate transactions play a critical role in property transfers and are required to identify parties and beneficial owners. Dealers in precious metals and stones handle high-value, portable assets attractive to criminals. Real estate agents facilitate property purchases often used to launder large sums of money. Accountants and auditors may assist in financial structuring, tax planning, or company formation and must conduct CDD when providing covered services.

Casino security guards and judges are not obliged entities under AML/CFT frameworks.

Understanding the source and origin of assets (C):According to the CAMS 6th Edition (Chapter: Customer Due Diligence and Enhanced Due Diligence) and the EU 4th & 5th AML Directives, regulated entities are required to take adequate measures to understand the source of funds and the origin of assets of their customers, especially when there are higher risk factors such as large transactions or PEPs.“Firms must identify the source and origin of assets to ensure they are not the proceeds of crime or corruption, particularly for higher-risk customers.”(CAMS 6th Edition, CDD/EDD Requirements; EU Directive 2015/849, Article 20)

Performing negative news checks of prospective customers (D):Adverse media screening is an essential part of the onboarding process for identifying potential risks related to money laundering, terrorist financing, or reputational harm.“Negative news or adverse media checks form a vital component of the due diligence process, helping organizations detect links to criminal or suspicious activities.”(CAMS 6th Edition, CDD/EDD Requirements)

Incorrect Options:

A: Onboarding interviews may be part of EDD, but are not a standard or required AML control.

B: PEPs are not to be automatically rejected; instead, enhanced due diligence should be applied.

E: Producing financial stability reports is not an AML control, but may be relevant for credit or investment assessment.

Correspondent banking relationships are recognized as higher risk under FATF guidance primarily because transactions are cross-border and conducted on behalf of third-party customers.

In correspondent banking, a respondent bank may process transactions for customers that the correspondent bank does not have a direct relationship with. This reduces transparency and limits the correspondent’s ability to fully assess customer identity, beneficial ownership, and transaction purpose.

While correspondent transactions may involve high-risk jurisdictions, this is not always the case. They are not anonymous by design, and payment messaging standards often require significant information. However, the indirect customer relationship and cross-border nature introduce complexity, jurisdictional risk, and reliance on the respondent bank’s controls.

Therefore, third-party and cross-border exposure is the key driver of heightened risk.

The CAMS 6th Edition specifically lists environmental crime as a predicate offense for money laundering. Environmental crimes include activities such as illegal logging, illegal mining, and illegal trade in wildlife.

“Environmental crime, including illegal logging and mining, is recognized as a predicate offense to money laundering. Such crimes often involve complex corporate structures to hide the illicit origin of the proceeds.”

(CAMS 6th Edition, Chapter: Risks and Methods of Money Laundering and Terrorist Financing; FATF Recommendations, Predicate Offenses)

Incorrect Options:

A: Trade-based ML refers to manipulating trade transactions, not the underlying crime.

B: Corruption may be involved, but the primary crime is environmental.

C: Illicit resource trade describes the act, but the official predicate crime category is environmental crime.

The real estate sector is recognized by FATF as vulnerable to money laundering due to the high value of transactions and the ability to integrate illicit funds into legitimate assets.

Key red flags include the use of commercial properties in ways inconsistent with the declared business purpose, which may indicate the property is being used to park or disguise illicit funds rather than generate legitimate income.

The use of complex loans or credit financing arrangements can be employed to obscure the true source of funds and create artificial legitimacy. Similarly, corporate vehicles and complex ownership structures are frequently used to conceal beneficial ownership.

Unexplained cash payments are among the most common and serious indicators of money laundering in real estate transactions, particularly when inconsistent with the buyer’s profile or local market practices.

The mere use of mortgages or agricultural land does not inherently indicate money laundering risk.

Analyzing the most recent National Proliferation Financing Risk Assessment from the relevant authority provides an organization with authoritative, up-to-date insights into current threats, high-risk sectors, and jurisdictional exposures, enabling better understanding and mitigation of proliferation financing risks.

To maximize the benefits of PPPs while addressing data privacy and regulatory concerns, the bank should establish a clear framework within the partnership that defines privacy protections and ensures all information sharing complies with applicable legal and regulatory requirements across jurisdictions. This approach fosters trust, enables effective collaboration, and mitigates potential legal risks.

Blockchain transactions differ fundamentally from traditional payments because they lack standardized messaging formats such as SWIFT MT or ISO 20022. As a result, conventional screening tools may struggle to consistently detect risks.

Integration with blockchain analytics providers allows institutions to enrich raw blockchain data with contextual intelligence, including wallet attribution, transaction flows, exposure to illicit services, sanctions-linked wallets, and typologies such as mixers and tumblers.

This integration enhances consistency, improves risk detection, and supports sanctions and AML obligations specific to virtual assets. Manual review is not scalable, and focusing only on known wallet addresses creates blind spots. Enhancing traditional payment screening does not address blockchain-specific challenges.

USA PATRIOT Act Section 314(b)allows financial institutions tovoluntarily share information with one another, after notifying the U.S. Treasury, toidentify and report possible money laundering or terrorist financing activities.

Key elements include:

Voluntary participation

Prior notice to FinCEN (part of the U.S. Treasury)

Protection from liability when acting in good faith

Enhanced collaborative detection across institutions

Section 314(a)refers toinformation sharing between law enforcement and financial institutions, not peer-to-peer sharing.

COSMICis an initiative in certain jurisdictions like Singapore, not U.S. regulation.

Regulation (EU) 2024/1624is part of the EU AML framework, not relevant to U.S. institutions.

Countries that are members of the Egmont Group can securely exchange information between their Financial Intelligence Units (FIUs) to support money laundering and terrorist financing investigations, even when the activity involves multiple jurisdictions.

Artificial intelligence (AI) enhances transaction monitoring by complementing or improving upon traditional rules-based systems. Regulators recognize that AI can strengthen AML programs when deployed with appropriate governance and oversight.

One key benefit is the ability to identify changes in customer behavior over time. AI models analyze historical and real-time data to detect deviations from expected patterns, allowing institutions to reassess customer risk more dynamically and accurately.

AI can also generate predictive customer risk scores, helping institutions prioritize alerts and focus investigative resources on higher-risk customers and activities. This improves efficiency and effectiveness while supporting a risk-based approach.

AI is designed to reduce false positives, not increase them, and bias must be carefully managed during training through governance and data controls.

FATF standards require organizations to adopt a risk-based approach (RBA) that is informed by both internal risk factors and national and sectoral risk assessments. These assessments provide critical insight into prevalent money laundering and terrorist financing threats within specific jurisdictions and industries.

Organizations should integrate relevant findings from these assessments into their internal risk assessments to ensure that policies, controls, and monitoring systems are aligned with identified risks. This enables institutions to tailor enhanced due diligence (EDD) measures and allocate compliance resources effectively.

Ignoring national or sectoral assessments would weaken the organization’s ability to respond to known threats and would be inconsistent with regulatory expectations. These assessments are not limited to worst-case scenarios nor intended solely for regulators; they are a foundational input for private-sector AML programs.

When setting a fuzzy matching threshold for sanctions screening, it is crucial to consider the reliability and accuracy of the data being screened. High-quality, verified data supports more effective matching and reduces both false positives and the risk of missing true matches.

Fuzzy logic in customer screening systems is used to handle uncertainty and variability in data by producing outputs that include a range of intermediate possibilities between "Yes" and "No." This enables the system to identify potential matches that are not exact but still relevant, improving the detection of name variations and misspellings.

Establishing a surveillance program with periodic risk assessments, access controls, and regular compliance reviews for employees, vendors, and third parties is the most effective way to mitigate insider threats and ensure ongoing adherence to AML regulations. This proactive approach continuously monitors risk rather than relying solely on initial checks or self-certifications.

Modern KYC solutions help reduce identity theft, provide reliable customer authentication to build trust, and shorten authentication times, enhancing both security and efficiency in customer onboarding and ongoing due diligence processes.

Cross-border money laundering investigations frequently encounter obstacles arising from differences in legal systems, data protection laws, and investigative procedures. International AML/CFT guidance, including FATF recommendations, emphasizes the importance of formal legal cooperation mechanisms to overcome these challenges.

A Mutual Legal Assistance Treaty (MLAT) provides a structured and legally recognized framework for cooperation between jurisdictions. MLATs allow competent authorities to lawfully exchange information, obtain evidence, and coordinate investigative actions while respecting domestic legal requirements and data privacy obligations. This formal mechanism ensures that information shared is admissible and enforceable across jurisdictions.

Relying solely on informal communication channels is insufficient for complex investigations involving sensitive data and legal constraints. Engaging third-party consultants does not address legal barriers and may introduce confidentiality risks. Centralizing an investigation under a single jurisdiction would undermine sovereignty and is not consistent with international cooperation principles.

Therefore, establishing or utilizing an MLAT is the most effective and regulator-aligned approach to enhance cross-border cooperation in complex money laundering investigations.