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ACAMS CAMS Certified Anti-Money Laundering Specialist (CAMS7 the 7th edition) Exam Practice Test

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Total 313 questions

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

Question 1

Which of the following are included in the 11 Immediate Outcomes outlined in the Financial Action Task Force (FATF) methodology for assessing technical compliance with the FATF Recommendations and the effectiveness of AML/CFT/CPF systems during mutual evaluations? (Select Three.)

Options:

A.

International cooperation provides actionable information to use against criminals

B.

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

C.

Money laundering offenses are investigated and criminally prosecuted

D.

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

E.

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

Question 2

According to guidelines issued by Basel Committee on Banking Supervision relating to corporate governance principles for banks, what is the role of the board of directors in addressing an institution's AML oversight and governance?

Options:

A.

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.

B.

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.

C.

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.

D.

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.

Question 3

According to the Financial Action Task Force (FATF) methodology, which situations would require a financial institution (FI) to consider filing a suspicious activity report?

Options:

A.

A beneficiary of a transaction is a politically exposed person.

B.

A FI is unable to verify the relevant customer due diligence documents.

C.

A FI identifies the payer is a dealer in precious metals or stones.

D.

A transaction involves funds exchanged from crypto to fiat currencies.

Question 4

When considering purchasing AFC tools from a vendor to implement into the customer lifecycle, which of the following measures should be taken during the process? (Choose two.)

Options:

A.

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

B.

Assessing whether internal staff members can provide training on the tools

C.

Assessing the cost of implementation and cost of maintaining the tools

D.

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

Question 5

Which statement is the most accurate describing who must comply with Office of Foreign Assets Control (OFAC) sanctions?

Options:

A.

All US citizens and permanent residents while located in the US, all US incorporated entities and their foreign branches, and all individuals within the United States

B.

All US citizens and permanent residents regardless of where they are located, all US incorporated entities excluding their foreign branches, and all individuals and entities within the United States

C.

All US citizens except those with dual nationality, US permanent residents, all US incorporated entities, and all individuals within the United States

D.

All US citizens and permanent residents regardless of where they are located, all US incorporated entities and their foreign branches, and all individuals and entities within the United States

Question 6

Criminals may misuse financial statements prepared by accountants to hide illicit assets.

Which of the following scenarios poses the greatest risk of financial statement manipulation by criminals?

Options:

A.

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

B.

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

C.

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

D.

Accountants being used as intermediaries to introduce criminals to financial institutions

Question 7

What is the relationship between the EU Anti-money Laundering Directives (AMLD) and local anti-money laundering (AML) regulations in European Union (EU) member states, in terms of their relevance for, applicability to, and impact on EU banks? (Select Two.)

Options:

A.

The EU AMLD and local AML regulations are separate and unrelated legal frameworks.

B.

The EU AMLD and local AML regulations must have identical requirements.

C.

Local AML regulations may impose additional or more stringent requirements than the EU AMLD.

D.

The EU AMLD take precedence over local AML regulations.

E.

Local AML laws and regulations override the requirements of the EU AMLD.

F.

The EU AMLD provide a framework that member countries must implement through local AML regulations.

Question 8

Which section of the USA PATRIOT Act relates to forfeiture of funds and allows for extraterritorial reach?

Options:

A.

Section 319(b)

B.

Section 314(b)

C.

Section 314(a)

D.

Section 319(a)

Question 9

Which money laundering risks are posed by the misuse of trust and asset management services? (Select Three.)

Options:

A.

Concealing sources of funds

B.

Allowing for third-party custody safekeeping of funds

C.

Adding a layer of anonymity to transactions

D.

Concealing true legal and beneficial owners

E.

Establishing escrow accounts for real estate transactions

Question 10

Which scenario best justifies why a customer's account might be closed by a financial institution?

Options:

A.

The customer is the object of a civil subpoena.

B.

The customer uses a shipping company dealing with specially designated nationals.

C.

The account shows periodic fixed amount remittances for tuition fees.

D.

The account has transactions that triggered multiple suspicious activity reports.

Question 11

What are the roles of a government Financial Intelligence Unit (FIU)? (Select Three.)

Options:

A.

Disseminate analysis of suspicious transaction and suspicious activity reports to foreign judicial systems to enhance their anti-money laundering and terrorist financing investigations and prosecutions

B.

Receive reports of suspicious transactions and suspicious activities from reporting institutions or obliged institutions

C.

Disseminate the analysis of suspicious transaction and suspicious activity reports to local law enforcement agencies and foreign FIUs to combat money laundering

D.

Investigate and where appropriate prosecute all suspicious transaction and suspicious activity reports received from reporting institutions or obliged institutions

E.

Analyze all suspicious transaction and suspicious activity reports received from reporting institutions or obliged institutions

Question 12

When a financial institution (FI) is considering providing traditional banking services to a virtual asset service provider (VASP), consideration should be given to whether the FI: (Select Two.)

Options:

A.

has a general understanding of virtual assets.

B.

consistently reviews transactions between fiat and virtual currencies.

C.

implements enhanced KYC measures.

D.

owns virtual currencies itself.

Question 13

The UN Security Council's primary role in imposing sanctions is that it has the authority to:

Options:

A.

impose sanctions to maintain or restore international peace and security.

B.

impose sanctions on countries that lack AML/CFT controls.

C.

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

D.

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

Question 14

Which of the following is a primary objective of public sector groups in the fight against money laundering?

Options:

A.

Advising private financial institutions on how to enhance their profitability through AML efforts

B.

Establishing and enforcing legal frameworks to detect, prevent, and punish money laundering and related financial crimes

C.

Providing funding to private and non-governmental organizations (NGOs) for the development of advanced compliance technologies

D.

Acting as intermediaries between private sector firms and non-governmental organizations (NGOs) to streamline AML compliance programs

Question 15

An adequate organizational policy is: (Choose two.)

Options:

A.

up to date and reflects all relevant regulatory developments

B.

signed off by the board of directors and regulators

C.

approved by the clients and third parties

D.

clearly communicated and understood by staff

Question 16

What is the primary purpose of anti-bribery and corruption regulations?

Options:

A.

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

B.

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

C.

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

D.

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

Question 17

Which attributes are typically used to assess the vulnerability to money laundering risk of products offered by an insurer? (Choose three.)

Options:

A.

Purpose and intended use

B.

Liquidity

C.

Age of the beneficiary

D.

Customer anonymity or third-party transactions

E.

Length of waiting period

Question 18

Which of the following is an important factor to consider when setting up an anti-financial crimes (AFC) compliance program governance structure?

Options:

A.

Ensuring the structure is reviewed by an outside auditor or consultant

B.

Establishing a system of internal controls commensurate with the institution’s size and complexity

C.

Designating a qualified board of directors to monitor day-to-day compliance

D.

Establishing clear roles and responsibilities for AFC risk escalations and issues

Question 19

The Financial Action Task Force (FATF) routinely publishes a catalogue of jurisdictions requiring enhanced monitoring which is commonly called the:

Options:

A.

red notice

B.

white list

C.

yellow notice

D.

grey list

Question 20

The degree of attraction that a company holds to criminal organizations is influenced by the (Select Two.)

Options:

A.

amount of annual fees associated with the jurisdiction.

B.

permissibility of bearer shares.

C.

rules governing the disclosure of beneficial ownership by the jurisdiction.

D.

ease of travel to the jurisdiction.

Question 21

A financial institution's transaction monitoring system flags an unusually high volume of international wire transfers originating from a small business account. The transfers are being sent to multiple jurisdictions known for limited regulatory oversight. Additionally, an employee reports suspicious behavior from the account holder during an in-person visit, where they requested a large cash withdrawal without providing a clear business justification. As part of the investigation, the compliance team must assess whether this activity is suspicious and determine the appropriate next steps.

Which of the following steps should be taken first in the investigation process to properly gather information and assess whether the transactions are suspicious?

Options:

A.

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

B.

Notify senior management and suggest account closure due to potential risks

C.

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

D.

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

Question 22

Beyond the physical and mental harm caused to individuals, which of the following problems can be linked to significant costs from unregulated online gambling and gaming?

Options:

A.

Economic and societal

B.

Political and regulatory

C.

Governance and compliance

D.

Sectoral and jurisdictional

Question 23

There are three types of factors that can be used to authenticate someone ownership, knowledge, and inherent factors.

Which of the following factors falls under inherent factors?

Options:

A.

Challenge-response

B.

Fingerprint

C.

Security token

D.

Passphrase

Question 24

Which of the following is a common strategy employed by non-governmental organizations (NGOs) to combat money laundering?

Options:

A.

Helping Financial Intelligence Units (FIUs) to analyze the suspicious activity reports (SARs)

B.

Directly prosecuting money launderers in court

C.

Providing financial assistance to governments to strengthen their anti-money laundering efforts

D.

Raising awareness about the issue of money laundering and its consequences

Question 25

When under a regulator's consent order or similar action, who at an organization is ultimately accountable for the remediation of any violations of applicable AML/CFT laws and regulations?

Options:

A.

Designated AML compliance officer

B.

Chief executive officer

C.

Chief operating officer

D.

Board of directors

Question 26

While gaming platforms are typically used for recreational purposes, they can potentially be used for terrorist financing through games in which players can:

Options:

A.

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

B.

exchange in-game items with other players.

C.

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

D.

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

Question 27

Which of the following attributes would enhance an AML program's effectiveness?

Options:

A.

Providing basic AML training to all employees

B.

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

C.

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

D.

Providing effective challenge with AML staff and continuous cross-training

Question 28

Which of the following are red flags pertaining to potentially suspicious transactions by a customer? (Select Three.)

Options:

A.

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

B.

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

C.

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

D.

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

E.

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

Question 29

Which of the following ate efficient approaches lo performing horizon scanning? (Select Two.)

Options:

A.

Subscribing lo a regulators' newsletter

B.

Using a specific provider for regulatory horizon scanning

C.

Regularly contacting the regulator to inquire about updates and future developments

D.

Relying on information and insights from peers and working groups

Question 30

The compliance officer at an EU bank is investigating one of the customer accounts maintained with the bank for the last two years. According to bank records, the company's primary economic activity is import and export of petrochemical products Over a period of one year, the account transactions have exceeded US$500 million with various high-value inward wire transfers received from suppliers in Yemen followed by outward wire transfers to counterparties in Azerbaijan.

Which factor should give the compliance officer the greatest concern If observed in the investigation?

Options:

A.

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

B.

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

C.

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

D.

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

E.

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

Question 31

Which of the following statements best describes the financial crime risk associated with gatekeepers?

Options:

A.

Gatekeepers have specialized knowledge that can be abused to facilitate the movement of illicit funds and conceal the Involvement of their clients in illicit schemes.

B.

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

C.

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

D.

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

Question 32

Which of the following are key financial crime risks associated with real estate companies? (Choose four.)

Options:

A.

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

B.

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

C.

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

D.

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

E.

Real estate transactions often involve financial institutions and other professional gatekeepers

F.

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

Question 33

According to FinCEN, which red flags within a bank account may, taken together, be indications of modern slavery, human trafficking, and exploitation? (Select Two.)

Options:

A.

Incoming fund transfers from third-party payment processors, with limited originator information

B.

Transactional activity with a registered virtual currency exchange

C.

Large amounts of cash payments to migrant agricultural workers

D.

Frequent payments for online advertisements or non-local classified ads

Question 34

Which of the following can be considered a reliable, independent source document, data, or information?

Options:

A.

Information provided by a prospective customer

B.

Photocopy of a copy of a government-issued identity document

C.

Information obtained from an open-source database

D.

Information obtained directly from a government-managed registry

Question 35

A global financial institution is conducting a comprehensive review of its due diligence processes to strengthen its defenses against financial crime. Recent incidents have highlighted vulnerabilities related to employee misconduct, including unauthorized transactions and sharing of sensitive customer information. Additionally, the FI has faced issues with third-party vendors who failed to meet compliance standards, leading to increased regulatory scrutiny.

Which of the following measures would be most effective in addressing the bank's due diligence needs for employees, vendors, and third parties to mitigate insider threats and ensure compliance with AML regulations?

Options:

A.

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

B.

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

C.

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

D.

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

Question 36

According to the Basel Committee principles, which actions would make a customer identification program at a bank more robust? (Select Two.)

Options:

A.

Understanding why a customer has selected a particular financial institution for banking

B.

Verifying the identity of a customer with reputable online source documentation

C.

Limiting the online activities of a new customer during the first two months

D.

Understanding the nature and purpose behind a new business opening an account at the bank

Question 37

A large international bank is conducting a comprehensive review of its risk management framework to ensure it effectively addresses various financial crime risks, including AML, CFT,

sanctions, fraud, anti-bribery and corruption (ABC), and tax evasion.

The bank’s compliance team is responsible for evaluating the current risk assessment processes, identifying potential gaps, and recommending enhancements to better mitigate these risks. During this review, the team needs to consider the different types of risk assessments and how to integrate findings into the overall risk management strategy.

Which approach should the compliance team prioritize to enhance the bank’s ability to identify, assess, and mitigate the identified risks?

Options:

A.

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

B.

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

C.

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

D.

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

Question 38

A large financial institution (FI) is considering expanding business to an area of the world with weak AML laws. The risk-based assessment indicates that the location will increase the FI's risk appetite beyond the stated acceptable amount.

Which risk factors should be used to identify the priority of the FI?

Options:

A.

Cash-intensive businesses risks

B.

Unknown third-party risks

C.

Geographic risks

D.

Anonymous transactions risks

Question 39

The relationship manager in the corporate banking department at a bank is required to take specialized AML training tailored to the risks the department is most likely to encounter.

Which types of content are most appropriate for this training? (Select Two.)

Options:

A.

Money laundering typologies applicable to monetary instrument reporting

B.

Applicable AML laws and regulations

C.

Regulatory exam best practices

D.

Money laundering typologies applicable to corporate loans

Question 40

The chief compliance officer (CCO) at a bank approved offering trade finance services to a company which is established within a country with a weak democratic system routinely reviews news on upcoming targeted economic sanction regulations in the EU, a major import partner for the country's production of crude oil.

Which of the following pieces of news would be of greatest concern?

Options:

A.

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

B.

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

C.

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

D.

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

Question 41

A high volume of incoming wire transfers generates an alert about a client. The funds are immediately debited by cash withdrawals and outgoing wire transfers.

Which information should be reviewed first to investigate this alert/case?

Options:

A.

Open source information

B.

Customer profile

C.

Adverse media search

D.

Account activity

Question 42

A prospective client walks into an accounting firm wanting to incorporate a company. The accountant feels uncomfortable after the meeting.

Which two of the accountant's observations warrant escalation to the compliance officer? (Select Two.)

Options:

A.

The principal activities of the proposed company are importing and exporting new furniture

B.

The prospective client presents confusing details about the proposed business and has very little knowledge about the proposed business activity

C.

The prospective client is unable to provide information about the beneficial owners

D.

The prospective client exhibits confidence when speaking to the accountant when providing personal details

E.

The prospective client is able to provide source of funds and source of wealth documents

Question 43

Which of the following presents the highest money laundering risk from a money services business (MSB)?

Options:

A.

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

B.

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

C.

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

D.

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

Question 44

Which action could be taken by an organization to better understand the threats faced from proliferation financing?

Options:

A.

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

B.

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

C.

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

D.

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

Question 45

At a high level, the risk assessment process involves identifying and rating the inherent risks associated with customers, products, countries, and delivery channels, and then:

Options:

A.

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

B.

implementing new controls to eliminate all risks

C.

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

D.

documenting the historical risk incidents for future reference.

Question 46

Reference data screening includes the screening of which types of datasets? (Select Two.)

Options:

A.

Types of payment messages

B.

Customers

C.

Third-party service providers

D.

Customer spouses

Question 47

Section 319(a) of the USA PATRIOT Act:

Options:

A.

Allows the appropriate federal banking agency to require a financial organization to produce, within 120 hours, records or information related to the organization's AML compliance or related to a customer of the organization or any account opened, maintained, administered, or managed in the U.S. by the financial organization.

B.

Provides the U.S. Department of Treasury with the authority to apply graduated, proportionate measures against a foreign jurisdiction, foreign financial organization, type of international transaction, or type of account.

C.

Permits the U.S. Government to seize funds from a correspondent bank account in the U.S. that has been opened and maintained for a foreign bank in the same amount as has been deposited with the foreign bank.

D.

Requires due diligence, and in certain situations enhanced due diligence (EDD), for foreign correspondent accounts, which includes virtually all account relationships that organizations can have with a foreign financial organization and private banking for non-citizens of the U.S.

Question 48

Why is it important to use multiple sanctions lists, such as United Nations (UN), Office of Foreign Assets Control ("OFAC"), and European Union ("EU") lists, in name screening systems?

Options:

A.

To avoid sanctions breach related to payments

B.

To avoid onboarding customers previously exited due to true match

C.

To meet international regulatory requirements and identify risks across jurisdictions

D.

To be in line with the risk appetite statement

Question 49

Why is the prevention of financial crime so important?

Options:

A.

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

B.

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

C.

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

D.

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

Question 50

Business entities established in offshore financial centers (OFCs) pose unique risks for money laundering because they often:

Options:

A.

have informal business arrangements between persons or entities.

B.

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

C.

include trusts, investment funds, and insurance companies.

D.

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

Question 51

According to the Financial Action Task Force (FATF). potential risk indicators related to money laundering proceeds from environmental crimes include. (Select Two.)

Options:

A.

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.

B.

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

C.

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.

D.

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

Question 52

Which customer actions are red flags for virtual currency peer-to-peer transactions? (Choose two.)

Options:

A.

A customer receives funds from a popular decentralized mixer

B.

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

C.

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

D.

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

Question 53

According to the Financial Action Task Force (FATF) Recommendation 22. when involved in customer transactions that include the buying and selling of real estate, real estate professionals are required to apply which customer due diligence (CDD) measures? (Select Two.)

Options:

A.

Obtaining prior senior manager approval for all related transactions

B.

Understanding the purpose of the business relationship

C.

Performing adverse media searches on the customer

D.

Identifying and verifying the customer's identity

Question 54

According to the Financial Action Task Force (FATF) report on terrorism financing, charities and nonprofit organizations are often vulnerable to terrorist financing because they: (Select Two.)

Options:

A.

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

B.

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

C.

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

D.

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

Question 55

An institution is looking to alter an existing threshold-based monitoring scenario because it is generating too many alerts that do not yield suspicious activity reports.

Documentation submitted to the relevant committee for supporting this proposal should include details on: (Choose three.)

Options:

A.

evidence that the increased residual risk arising from the change is within the bank's risk appetite.

B.

approval by money-laundering reporting officer for the proposal.

C.

how many resources are spent on the less productive lower threshold and the associated costs.

D.

the number of cases that will not be filed and the resources that can be freed up for other tasks.

E.

minutes of meeting held with the regulator where agreement was obtained that the higher threshold was justified.

F.

historical analysis proving that the current scenario generates a disproportionate number of false positives.

Question 56

Which of the following statements is true regarding Office of Foreign Assets Control (OFAC) sanctions? (Select Two.)

Options:

A.

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

B.

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

C.

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

D.

OFAC sanctions automatically expire after five years unless renewed by Congress

Question 57

Financial crime risk related to the use of "hawalas" can stem from: (Select Two.)

Options:

A.

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

B.

remote verification of identity by third-party program managers.

C.

heavy usage by senior political figures.

D.

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

E.

heightened risks of returned transactions.

Question 58

Which of the following is a critical consideration for private sector firms when sharing data and intelligence to combat financial crime?

Options:

A.

The preference of upper management regarding which teams should participate in the data-sharing initiative

B.

The cost of the data-sharing system and whether it its within the existing IT budget

C.

The potential return on investment (ROI) from the data shared versus the financial crime prevention effort

D.

Ensuring that the shared data complies with applicable data protection regulations while maintaining the integrity and accuracy of the information

Question 59

It is essential to identify any "family members" or "close associates" of politically exposed persons (PEPs) as part of the KYC/CDD process because they could be:

Options:

A.

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

B.

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

C.

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

D.

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

Question 60

Which o! the following are considered best practices regarding senior management involvement in a financial crime compliance program? (Select Two.)

Options:

A.

Mandatory participation in all regulatory inspections

B.

Mandatory attendance and review of alt financial crime trainings

C.

Setting clear criteria for escalations to senior management

D.

Setting tone from the top

Question 61

A financial institution's US Branch receives a subpoena from law enforcement requesting detailed records of a customer's account activity. The customer is part of an ongoing investigation into a money laundering operation. At the same time, the institution has received a FinCEN 314(b) information-sharing request from another bank seeking details on transactions linked to the same customer. The compliance team is tasked with responding to both the subpoena and the FinCEN 314(b) request.

What should the compliance officer prioritize in responding to these requests while ensuring that all legal and regulatory obligations are met?

Options:

A.

Notify the customer of the information-sharing request from the other financial institution and seek their consent before responding

B.

Consult the institution's legal counsel to validate the subpoena, then respond directly to law enforcement while ensuring all documentation is properly recorded

C.

Respond to the FinCEN 314(b) request first, as it allows for voluntary information sharing with partner organizations

D.

Provide the requested records to both law enforcement and the other financial institution immediately to ensure full cooperation and transparency

Question 62

The chief compliance officer at a global bank that operates in the US, EU, and other countries is responsible for navigating the US and EU regulations related to anti-money laundering (AML) and sanctions as well as any local regulations in the countries where it operates.

What should be the primary compliance concern of the bank?

Options:

A.

US anti-money laundering regulations are stricter than the EU AML Directives, making it easier for the global bank to be compliant in the EU

B.

US and EU regulations require the bank to build separate compliance teams, making it necessary to establish completely separate systems for US and EU operations

C.

The EU's sanctions regime is stricter than that of the US Office of Foreign Assets Control (OFAC), so the bank must prioritize compliance with EU regulations over US laws and train the staff in Europe accordingly

D.

Balancing compliance with the US BSA and OFAC sanctions while ensuring adherence to EU AML directives and the GDPR, which complicates cross-border data sharing

Question 63

Which payment type presents the highest financial crime risk?

Options:

A.

A check returning a mortgage overpayment made in error

B.

A payment made to a mixer platform

C.

A regular standing order to a high-interest savings account

D.

A bill payment made to a friend after splitting a dinner bill

Question 64

The owner of a real estate investment company deposits multiple cashier's checks that were bought using cash over a three-month period, from the sale of two apartments. This account also receives several electronic transfers from other financial institutions for US$10,000 each.

What activity is considered suspicious of money laundering?

Options:

A.

Receiving electronic transfers for US$10,000 amounts from other financial institutions

B.

Using cash to buy multiple cashier's checks over a period of time

C.

Performing operations with real estate investment companies

D.

Using cashier's checks in the transactions with the real estate investment company's account

Question 65

The primary roles of a Country's Financial Intelligence Unit (FIU) include: (Select Two.)

Options:

A.

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

B.

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

C.

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

D.

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

E.

enacting legislation regarding the operations of financial institutions.

Question 66

Which of the below statements are supported by the Financial Action Task Force (FATF) 40 Recommendations adopted in 2012? (Select Two.)

Options:

A.

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

B.

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

C.

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

D.

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

E.

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

F.

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

Question 67

How can public-private partnerships (PPPs) foster collaboration in the fight against financial crime? (Choose two.)

Options:

A.

Developing a culture of compliance

B.

Improving governance in the public sector by requesting feedback from financial institutions

C.

Reducing transaction monitoring false positives for all financial institutions

D.

Improving the quality and quantity of data available for analysis by sharing information

Question 68

When services are provided by a trust and company service provider (TCSP) connected to a high-risk country, which of the following may present an immediate financial crime risk concern?

Options:

A.

Management structure

B.

Governance framework

C.

Asset structure

D.

Origin of the funds

Question 69

An international bank is investigating a payment requested by one of its correspondent relationships that generated an alert in the automated transaction monitoring system. The payment originated from a corporation located in Hong Kong and the final beneficiary is an individual located in New York.

Which steps should the bank take first to address the alert? (Select Three.)

Options:

A.

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

B.

Call the receiving individual to review identity verification documents

C.

Confirm that neither the beneficiary nor the originator are sanctioned parties

D.

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

E.

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

Question 70

Which of the following corporate structures present a higher money laundering risk because of reduced transparency? (Select Three.)

Options:

A.

A limited liability company incorporated in a foreign jurisdiction

B.

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

C.

A company with nominee shareholders and directors in a local jurisdiction

D.

A company with bearer shares incorporated in a tax haven jurisdiction

E.

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

Question 71

During a routine periodic KYC refresh of a policyholder and client of an insurance company, updated business registry documentation has highlighted that the policyholder's business has changed addresses five times during the last year and that the ultimate beneficial owner (UBO) changed two weeks ago.

What actions should be taken immediately?

Options:

A.

Investigate the changes of address and change of UBO and in the meantime decline payment and withdrawal instructions from the policy until completion of the investigation and next steps are agreed upon

B.

Request the relationship manager set up a meeting with the policyholder to update their address and submit details of the new UBO in the name of good customer service

C.

Investigate the changes of address and change of UBO and in the meantime freeze the client's policy

D.

File a suspicious transaction report because the insurance company was not made aware of the business' change of UBO

Question 72

What are the rules imposed by the Office of Foreign Assets Control (OFAC) for legal entities and persons related to the US? (Select Two.)

Options:

A.

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

B.

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

C.

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

D.

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

E.

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

Question 73

Which activities would be considered money laundering red flags when reviewing the business operations of a money services business (MSB)? (Select Two.)

Options:

A.

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

B.

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

C.

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

D.

A customer using multiple accounts under different names to conduct transactions

E.

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

Question 74

Which of the following statements is true regarding the 2012 Financial Action Task Force (FATF) 40 Recommendations and'or 11 Immediate Outcomes?

Options:

A.

The 40 Recommendations have not been updated to reflect the impact of new technology

B.

Each jurisdiction can reach out to the FATF for private access to the interpretive notes to the 40 Recommendations

C.

The 11 Immediate Outcomes are recommendations specific to high-risk jurisdictions requiring enhanced monitoring.

D.

The cornerstone of the 40 Recommendations is the adoption of a risk-based approach by each jurisdiction

Question 75

A multinational corporation is considering expanding into a new market with a history of political instability and corruption.

Which strategy would be most effective in mitigating reputational risk from a financial crime perspective associated with such an expansion?

Options:

A.

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

B.

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

C.

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

D.

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

E.

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

Question 76

Which section of the USA PATRIOT Act permits the US government to seize funds deposited in a US correspondent account of a foreign bank, creating extraterritorial impact?

Options:

A.

Section 314(a)

B.

Section 314(b)

C.

Section 319(b)

D.

Section 319(a)

Question 77

Which of the following measures is one that the FATF recommends that Financial Institutions and Designated Non-Financial Businesses and Professions (DNFPB) take to mitigate risks arising from business relationships with foreign politically exposed persons (PEPs)?

Options:

A.

Raise transaction monitoring thresholds for PEP accounts in automated systems to account for higher transaction values and complex legal vehicles and financial structures

B.

Require approval from the prudential regulator for entering into or continuing the business relationship

C.

Subscribe to commercial databases to assist in the detection of PEPs

D.

Establish processes to understand the PEP's source of wealth and the source of funds, and to refresh that understanding on a regular basis

Question 78

What are the primary advantages of using open-source tools in financial crime investigations? (Choose two.)

Options:

A.

Partial automation of data collection and analysis

B.

Cost-effective access to a wide range of data

C.

Real-time monitoring of selected transactions and data sources

D.

Ability to conduct investigations with minimal human oversight

E.

Enhanced ability to identity connections across various data sets

Question 79

When applying new technologies to AML, application programming interfaces (APIs) allow for:

Options:

A.

Digital identification on mobile devices

B.

Different applications to connect and communicate

C.

Authentication via artificial intelligence (AI) and biometrics

D.

Quick CDD and client traits analysis during onboarding

Question 80

Which of the following entities could potentially pose a higher money laundering risk and require additional review prior to onboarding? (Select Two.)

Options:

A.

A large multinational corporation with extensive, documented wire transfer activity

B.

A local convenience store that replenishes the onsite automated teller machine (ATM) with cash from its till

C.

A local used car sale lot that allows individuals to pay their monthly bill in cash

D.

A virtual asset service provider (VASP), facilitating peer-to-peer cryptocurrency transactions

Question 81

Which principles of the Egmont Group of Financial Intelligence Units (FIUs) are aimed at maximizing cooperation between FIUs to more effectively combat money laundering? (Select Two.)

Options:

A.

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

B.

FIU cooperation should always be channeled through designated intermediaries

C.

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

D.

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

E.

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

Question 82

A bank is preparing for a regulatory exam after a previous regulatory exam identified weaknesses in the bank's AML program. Since the last exam, the bank has improved the written AML program, hired an experienced AML compliance officer, and has taken actions to demonstrate a strong culture of compliance. The bank is now focused on getting through their transaction monitoring case backlog and completing enhancements to its sanctions screening program.

Which of the following are correct? (Select Two.)

Options:

A.

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

B.

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

C.

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

D.

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

E.

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.

Question 83

A compliance officer is reviewing an institutional banking prospect proposal for a new foreign entity that is a multinational business but headquartered in a country where most businesses are state-owned.

Which risks should be prioritized in the review? (Choose two.)

Options:

A.

Politically exposed persons (PEPs)

B.

Capital flight risk

C.

Anti-bribery and corruption risk

D.

Tax evasion

Question 84

Which of the following are considered best practices for effective AML/CFT training programs? (Select Three.)

Options:

A.

Training should cover practical examples, use case studies, and provide information on how to comply with policies.

B.

Up-to-date records including logs of training and completion dates should be maintained.

C.

Training should be broad, high level, and not role-specific in order to reach the largest audience.

D.

Training should cover the consequences of not complying with policies and procedures.

E.

Training should always be provided by an independent third party.

Question 85

When assessing and managing money laundering risks while operating in foreign jurisdictions different from that of the head office, an effective AML monitoring program should:

Options:

A.

Be consistent with the head office audits

B.

Be tailored to the higher of standards between the jurisdictions.

C.

Conform to the foreign jurisdiction policies to align with the head office policies.

D.

Provide all foreign jurisdiction reports to the head office for approval.

Question 86

News published in Country A reports that a politically exposed person (PEP) had received a bribe from a transnational company headquartered in a developing country of approximately USS1.5 million deposited into on account at a financial institution (Fl> located in Country B Both countries are members of the Egmont Group The account where the money was deposited belongs to the PEP's immediate family member. To corroborate the facts, the PIU of Country A sent a formal request via secure communication channels for further information from its counterpart FIU in Country B.

According to Egmont principles, the FIU of Country B can:

Options:

A.

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.

B.

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

C.

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

D.

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.

Question 87

Which of the following programs would most likely be considered part of an effective supervision regime for a regulator?

Options:

A.

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

B.

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

C.

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

D.

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

Question 88

Which of the following is a broader risk specific to casinos and gambling?

Options:

A.

Low thresholds for transactions

B.

Frequent use of cash

C.

Cross-border transactions

D.

Weak KYC policies and procedures

Question 89

An international bank is headquartered in Madrid, Spain with an office in New York City (NYC), US. The Madrid office is investigating a transaction originating from a customer of the NYC office and inquires whether the NYC office can share any relevant further information on the individual. Upon further research, the NYC office finds that they have filed a suspicious activity report (SAR) on the individual in the previous year.

Which factors need to be considered before sharing the requested information? (Select Two.)

Options:

A.

The foreign bank must always request approval by its national anti-financial crime authority to share any information cross-border.

B.

The bank should report this to the Financial Crimes Enforcement Network (FinCEN) and receive formal guidance before sharing the information.

C.

The bank should consider jurisdictional privacy requirements and its own policies and procedures to determine what information to share.

D.

The information should only be shared on a need-to-know basis.

Question 90

According to PinCEN. when a financial institution (PI) identities a suspicious activity that necessitates suspicious activity report (SAR) filing, the SAR supporting documentation should (Select Two.)

Options:

A.

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

B.

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

C.

have written policies and procedures to maintain supporting documentation.

D.

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

Question 91

The goal of the Egmont Group of Financial Intelligence Units (FIUs) is to provide a forum for FIUs to: (Select Three.)

Options:

A.

Securely share sensitive information in the fight against money laundering and the financing of terrorism

B.

Establish an environment to foster trust amongst countries

C.

Sign memoranda of cooperation that recognize and allow room for case-by-case solutions to specific problems

D.

Improve global cooperation between FIUs

E.

Propose legislation to combat financial crime, including money laundering and the financing of terrorism

Question 92

Which is a key goal of the EU's Directives on money laundering?

Options:

A.

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

B.

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

C.

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

D.

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

Question 93

In which of the following situations would it be most crucial for the designated AML compliance officer of a company to perform a complete review of the company's AML program, including identifying the risks and commensurate controls?

Options:

A.

An external audit highlights several deficiencies

B.

The company is merging with or acquiring another entity

C.

Extensive AML legislation is proposed by a legislative body in the company's jurisdiction

D.

A high-profile money laundering case involving another industry is publicized

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Total 313 questions