ACAMS ACAMS Certifications CAMS Questions & Answers

• Question 101:

  A bank's transaction surveillance system triggers an alert for a deposit of 250.000 USO into a client's account. According to the bank's KYC information, the client works for a financial advisory firm, and earns approximately 100,000 USD per year. Which actions should be taken? (Select Three.)

  File the suspicious transaction immediately to the financial intelligence unit.

  A. Discard the alert as a false positive hit

  B. Request information and documentation from the client on the background of the transaction.

  C. Contact the client advisor to learn if he has any insight on the transaction background.

  D. Review the alert if the deposit is made in cash.

  E. Review the transaction background in the bank's transaction platform.

  Correct Answer: BCE

  According to the Certified Anti-Money Laundering Specialist (CAMS) Manual , 6th edition, if a bank's transaction surveillance system triggers an alert for a deposit of 250.000 USD into a client's account, the bank should take the following

  actions:

  Request information and documentation from the client on the background of the transaction (CAMS Manual, 6th edition, page 46).

  Contact the client advisor to learn if he has any insight on the transaction background (CAMS Manual, 6th edition, page 47).

  Review the transaction background in the bank's transaction platform (CAMS Manual, 6th edition, page 47).

  Discarding the alert as a false positive hit and reviewing the alert if the deposit is made in cash should not be done.

  The bank should request additional information and documentation from the client to better understand the nature of the transaction. Additionally, the bank should reach out to the client advisor to learn if they have any insight on the

  transaction background. Finally, the bank should review the transaction background in the bank's transaction platform to determine if any additional alerts or anomalies are present. (CAMS Manual, 6th Edition, Pages 117-118)

• Question 102:

  In accordance with Financial Action Task Force (FATF) standards, when the minimum AML requirements of the host country where a financial institution (Fl) operates are less strict than those of the Fl's home country, the Fl:

  A. should always apply additional measures on their branches and majority-owned subsidiaries in host countries to manage the money laundering and terrorist financing risk overseas.

  B. is required to ensure that their branches and majority-owned subsidiaries in host countries implement the requirements of the home country, to the extent that host country laws and regulations permit.

  C. is required to impose more strict requirements on host country branches, disregarding if host country laws and regulation permit such action.

  D. should close down its operations in the host countries where minimum AML requirements are less strict than those of the home country.

  Correct Answer: B

  In accordance with Financial Action Task Force (FATF) standards [1][2], when the minimum AML requirements of the host country where a financial institution (Fl) operates are less strict than those of the Fl's home country, the Fl is required to ensure that their branches and majority-owned subsidiaries in host countries implement the requirements of the home country, to the extent that host country laws and regulations permit. This means that the Fl should not impose more strict requirements on host country branches, disregarding if host country laws and regulation permit such action, and should not close down its operations in the host countries where minimum AML requirements are less strict than those of the home country. However, the Fl should always apply additional measures on their branches and majority- owned subsidiaries in host countries to manage the money laundering and terrorist financing risk overseas.

• Question 103:

  Under the Wolfsberg Correspondent Banking Principles, which action is considered an enhanced due diligence obligation to correspondent banking clients that present greater risks?

  A. Conducting reviews on all high-risk relationships

  B. An evaluation done by the compliance officer in charge of the account

  C. Approval of a high-risk relationship by a senior management committee

  D. Ongoing monitoring of clients located in tax haven countries

  Correct Answer: C

  Under the Wolfsberg Correspondent Banking Principles, conducting enhanced due diligence (EDD) is an obligation for correspondent banking clients that present greater risks. This may include conducting additional research and analysis of the client's background, ownership structure, and transactions. EDD may also involve obtaining additional documentation, verifying the client's identity, and conducting periodic reviews to ensure ongoing compliance. The level of EDD required should be commensurate with the level of risk posed by the correspondent banking relationship. Therefore, option B and D are incorrect. Option A is not specific enough to address the question. Option C is the correct answer as it highlights the importance of senior management approval for high-risk relationships, which is a key component of EDD. Reference: Certified Anti-Money Laundering Specialist (the 6th edition) Study Guide, Chapter 7, page 12. Wolfsberg Correspondent Banking Principles (2014)

• Question 104:

  Client A is flagged for a high volume of outgoing transfers. Further investigation reveals Client A has a potentially key role in a network linked to human trafficking.

  After filing a suspicious activity report, what step should the investigator take next?

  A. Prepare a summary for senior management recommending client off-boarding.

  B. Inform other local financial institutions about the client so they can halt potential services.

  C. Restrain or block the client's account(s) until law enforcement makes an arrest.

  D. Contact the Federal Bureau of Investigation (FBI) to communicate the investigation findings.

  Correct Answer: A

  After filing a suspicious activity report (SAR), an investigator should prepare a summary for senior management recommending client off-boarding. This is because client off-boarding is a risk-based decision that requires senior management approval and may involve legal considerations. Informing other local financial institutions about the client, restraining or blocking the client's account(s), or contacting law enforcement directly are not appropriate actions for an investigator to take after filing a SAR, as they may compromise the confidentiality of the SAR, violate privacy laws, or interfere with ongoing investigations.

• Question 105:

  The law enforcement agency (LEA) of a foreign jurisdiction contacts a financial institution (Fl) regarding one of the Fl's clients. The LEA advises that the client is currently wanted for prosecution as a result of a series of human trafficking charges. What should the Fl do? (Select Two.)

  A. Review the client's activity, determine if suspicious activity exists, and report accordingly.

  B. Advise the LEA that the government needs to be contacted for extradition.

  C. Comply immediately with the foreign jurisdiction and turn over all client information.

  D. Inform local LEA and regulator of the request for awareness.

  E. Close the clients accounts immediately to avoid any undue risk.

  Correct Answer: AD

  According to the Certified Anti-Money Laundering Specialist (the 6th edition), the financial institution (Fl) should take the following actions:

  A. Review the client's activity, determine if suspicious activity exists, and report accordingly. The Fl should assess the risk of the situation and determine if there is any suspicious activity that needs to be reported to the appropriate authorities. This would involve conducting a review of the client's account activity and transactions to determine if there are any indicators of money laundering or terrorist financing. D. Inform local LEA and regulator of the request for awareness. The Fl should inform the local law enforcement agency and regulator of the request from the foreign jurisdiction to raise awareness of the situation and determine if any further actions need to be taken.

• Question 106:

  Using the customer profile and expected activity information, a financial institution should be able to identify transactions that are difficult to:

  A. make economic sense.

  B. make viable profitability.

  C. be strategically viable.

  D. cross verify.

  Correct Answer: A

  Using the customer profile and expected activity information, a financial institution should be able to identify transactions that are difficult to make economic sense. Transactions that don't make economic sense may be suspicious, and should be investigated further to determine if they may be related to money laundering or other illicit activities. For example, if a customer is profiting from a series of transactions that don't make economic sense, such as buying and selling the same stock multiple times in a short period of time, then this could be a sign of money laundering or other illicit activities.

• Question 107:

  Which product type is subject to US extra jurisdictional reach over non-US banks and non- US persons under the USA PATRIOT Act?

  A. Correspondent banking

  B. Commercial lending

  C. Trade finance

  D. Private banking

  Correct Answer: A

  The product type that is subject to US extra jurisdictional reach over non-US banks and non- US persons under the USA PATRIOT Act is Correspondent Banking. According to the Certified Anti- Money Laundering Specialist (the 6th edition) Study Guide, "The USA PATRIOT Act extends the reach of the Bank Secrecy Act and other anti-money laundering statutes to non-U.S. banks and non-U.S. persons. This extra jurisdictional reach includes, but is not limited to, correspondent banking."

• Question 108:

  Which are characteristics of Mutual Legal Assistance Treaties (MLATs)? (Select Three.)

  A. MLATs are neither public nor binding under international law.

  B. MLATs cannot be used for obtaining banking records from treaty partners.

  C. MLATs do not provide a legal basis for transmitting evidence.

  D. MLATs only involve two countries.

  E. MLATs cooperatively combat crime between countries.

  F. MLATs are useful for gathering evidence and intelligence in a foreign country.

  Correct Answer: DEF

  Mutual Legal Assistance Treaties (MLATs) are characteristics of D. only involving two countries, E. cooperatively combating crime between countries, and F. being useful for gathering evidence and intelligence in a foreign country. MLATs are public and binding under international law (A), can be used for obtaining banking records from treaty partners (B), and provide a legal basis for transmitting evidence ?

• Question 109:

  Which is true about Financial Action Task Force (FATF)-Style Regional Bodies (FSRBs)?

  A. FSRBs set standards for their member countries that supplement FATF's standards.

  B. Tools used by FRSBs include training measures and mutual evaluations of its members.

  C. AFATF-member country cannot also be a member of an FSRB.

  D. To be a member of an FSRB, a country must have enacted AML and Anti-Terrorist Financing laws.

  Correct Answer: B

  FSRBs are regional bodies that work with FATF to promote the implementation of AML and CFT standards. FSRBs are made up of member countries that have agreed to work together to combat money laundering and the financing of terrorism [1]. The tools used by FSRBs to promote the implementation of AML and CFT standards include training measures, mutual evaluations of its members, technical assistance, and the sharing of information. FSRBs may also adopt recommendations and best practices based on the FATF's 40 Recommendations.

• Question 110:

  Typical events to identify and investigate potential AML activities include: (Select Three.)

  A. blocked transactions involving individuals included in the Office of Foreign Assets Control Specially Designated Nationals and Blocked Persons List.

  B. internal tips from employees of the bank about potential suspicious activity.

  C. alerts triggered by the automated AML monitoring system.

  D. subpoenas requesting information for civil cases.

  E. requests from law enforcement agencies.

  F. accounts going to dormant status.

  Correct Answer: BCE