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ACAMS Certified Anti-Money Laundering Specialist (CAMS7 the 7th edition) Sample Questions (Q128-Q133):

NEW QUESTION # 128
What are some red flags pertaining to potentially suspicious transactions by a customer? Choose 3 answers

A. Having multiple individuals use the ATM card connected with the account m different cities
B. Having multiple addresses and/or moving frequently
C. Having a commercial account with cash deposits
D. Have a common address with several other bank clients

Answer: A,B,D

NEW QUESTION # 129
A financial institution (FI) is conducting a complex investigation of unusual patterns of activity involving multiple businesses, triggered by an automated monitoring system alert.
Which techniques would be most efficient for conducting the investigation? (Select Two.)

A. Use social media platforms to connect with the businesses and request details about the account activity.
B. Perform a control and ownership assessment of the businesses involved, using the information available in the client files.
C. Contact the account manager and ask for the reasons behind the patterns of activity highlighted in the AML alerts.
D. Review the information presented in the automated monitoring system's alert description and decline any future transactions.
E. Contact local law enforcement and request that they assist in the analysis and investigation.

Answer: B,C

Explanation:
When investigating unusual transactions, financial institutions must focus on data-driven risk assessment and internal review first.
Option A (Correct): Assessing business ownership and control structures helps determine if multiple businesses are connected through hidden links (e.g., shell companies or common ownership).
Option C (Correct): The account manager may provide valuable insight on whether the customer's activity aligns with their expected profile.
Option B (Incorrect): Law enforcement should only be contacted after internal review confirms suspicious activity.
Option D (Incorrect): Declining transactions without thorough investigation could lead to missed SAR filings or improper risk assessment.
Option E (Incorrect): Social media is not a reliable investigative tool for AML casework.
Key Red Flags in Business AML Investigations:
Frequent transactions between businesses with no clear commercial relationship.
Ownership structures that obscure beneficial owners.
Rapid movement of funds through multiple accounts without economic justification.
Best Practices for Investigating Complex Cases:
Verify ownership and control through official company registries.
Conduct negative news screening and PEP/sanctions screening.
Request supporting documentation from the customer.
Reference:
FATF Recommendation 10 (Customer Due Diligence)
Wolfsberg Group Guidance on Transaction Monitoring and Investigations
FinCEN Red Flags for Business Money Laundering Investigations

NEW QUESTION # 130
A compliance officer is tasked with implementing an enterprise-wide anti-money laundering program for a bank, which operates in multiple countries. Not all the bank products and services are available in all countries.
Which three factors should be considered as part of the approach? (Choose three.)

A. The customer onboarding platform that will be used
B. The types of customers serviced by the bank
C. The anti-money laundering risk posed by the products and services offered by the bank
D. The amount of resources needed to implement the anti-money laundering program in the countries
E. The extent of anti-money laundering regulations in the various countries

Answer: B,C,E

Explanation:
A compliance officer should consider the following three factors as part of the approach to implement an enterprise-wide anti-money laundering program for a bank that operates in multiple countries:
* The types of customers serviced by the bank: Different types of customers may pose different levels of money laundering risk, depending on their nature, source of funds, geographic location, transaction patterns, and other factors. A compliance officer should identify and assess the money laundering risk associated with each customer type and segment, and apply appropriate due diligence measures, monitoring systems, and risk mitigation strategies accordingly12.
* The extent of anti-money laundering regulations in the various countries: A compliance officer should be aware of the legal and regulatory requirements and expectations for anti-money laundering compliance in each country where the bank operates, and ensure that the bank's policies and procedures are consistent with them. A compliance officer should also monitor any changes or updates in the anti- money laundering laws and regulations in the various countries, and adjust the bank's program accordingly34.
* The anti-money laundering risk posed by the products and services offered by the bank: Different products and services may have different features and functionalities that could be exploited by money launderers, such as anonymity, cross-border transfers, cash transactions,complex structures, or new technologies. A compliance officer should evaluate the money laundering risk associated with each product and service offered by the bank, and implement appropriate controls, safeguards, and oversight mechanisms to prevent and detect money laundering activities5 .
1: ACAMS, CAMS Study Guide, 6th Edition, Chapter 2: Risk Assessments
2: FATF, Guidance for a Risk-Based Approach: The Banking Sector
3: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT)
4: Deloitte, AML Program Effectiveness Reform
5: ACAMS, CAMS Study Guide, 6th Edition, Chapter 4: AML Program Design
[6]: OCC, Money Laundering: A Banker's Guide to Avoiding Problems

NEW QUESTION # 131
What is an aspect of the USA PATRIOT Act that has extraterritorial reach?

A. To mandate stricter money laundering controls across the continent.
B. To strengthen US measures to prevent, detect and prosecute international money laundering and financing of terrorism.
C. To implement economic and trade sanctions based on US foreign policy.
D. To require scrutiny of foreign financial institutions (FIs) and classes of international transactions that are susceptible to criminal abuse.

Answer: B

NEW QUESTION # 132
Which key factor would result in the decision for a financial institution (FI) to exit a client relationship?

A. Client transactions generate ongoing transaction monitoring alerts that did not result in any SAR/STR filings.
B. The client is a registered charity known to remit funds to high risk geographies where there is limited due diligence information available.
C. After assessing all risk factors the level of residual client risk exceeds the FI's risk appetite.
D. Closing the client accounts will help reduce the number of transaction monitoring alerts.

Answer: C

Explanation:
The key factor that would result in the decision for a financial institution (FI) to exit a client relationship is when the level of residual client risk exceeds the FI's risk appetite. Residual client risk is the remaining risk after applying the FI's risk mitigation measures, such as customer due diligence, transaction monitoring, and suspicious activity reporting. Risk appetite is the level and type of risk that the FI is willing and able to accept inpursuit of its business objectives. If the residual client risk is higher than the risk appetite, the FI may decide to terminate the relationship to avoid potential regulatory, reputational, or operational consequences.
The other options are not necessarily key factors for exiting a client relationship, because:
* The client is a registered charity known to remit funds to high risk geographies where there is limited due diligence information available. This option may indicate a higher level of inherent client risk, but it does not necessarily mean that the FI should exit the relationship. The FI may be able to apply enhanced due diligence, ongoing monitoring, and risk-based controls to mitigate the risk and comply with the regulatory requirements. The FI may also consider the nature and purpose of the client's activities, the source and destination of the funds, and the potential impact on the client's beneficiaries.
* Closing the client accounts will help reduce the number of transaction monitoring alerts. This option may suggest a possible benefit of exiting the relationship, but it is not a key factor for making the decision. The FI should not base its decision solely on the volume of transaction monitoring alerts, but rather on the quality and relevance of the alerts, the results of the investigation, and the risk assessment of the client. The FI should also ensure that its transaction monitoring system is properly calibrated and validated to avoid generating excessive or false alerts.
* Client transactions generate ongoing transaction monitoring alerts that did not result in any SAR/STR filings. This option may indicate a need for reviewing and improving the transaction monitoring system or the investigation process, but it does not necessarily imply that the FI should exit the relationship.
The FI should not assume that the absence of SAR/STR filings means that the client is low risk or that the alerts are irrelevant. The FI should conduct a thorough and timely investigation of the alerts and document the rationale for filing or not filing a SAR/STR. The FI should also consider the overall risk profile of the client and the nature and frequency of the transactions.
ACAMS Study Guide for the CAMS Certification Examination - 6th Edition, Chapter 3: AML Programs, Section 3.2: AML Program Components, Subsection 3.2.2: Risk Assessment, pp. 77-79 FFIEC BSA/AML Examination Manual, Section: Assessing Compliance with BSA Regulatory Requirements, Subsection: Suspicious Activity Reporting, pp. 4-5 Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations, Question 2, pp. 2-3

NEW QUESTION # 133
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