Free Practice Questions for ACAMS CAMS Exam

Global organizations must ensure their policies and procedures comply with local laws and regulations in each country where they operate, even when maintaining group-wide consistency. Relying solely on international or U.S. standards does not ensure compliance with all local requirements, which may be more stringent or specific.

“A global group-wide program should ensure adherence to local AML and sanctions laws and regulations in every jurisdiction in which it operates. Local adaptation of policies is essential to address jurisdiction-specific risks and legal requirements.”

(CAMS 6th Edition, International AML/CFT Standards; FATF Recommendations 18, 35; EU & US Sanctions Regulations)

Classic indicators of suspicious activity often involve use of proxies, unusual cash access, or attempts to avoid scrutiny, as highlighted in FATF and FIU guidance.

Frequent access to a safe deposit vault to withdraw cash by a person closely associated with a government official raises heightened concern. Such behavior may indicate attempts to conceal illicit funds, particularly given the potential exposure to corruption risk associated with politically exposed persons (PEPs) and their close associates.

Similarly, requesting a third party to execute wire transfers on one’s behalf to a FATF grey-listed jurisdiction is a well-recognized red flag. This behavior suggests an attempt to evade transaction monitoring, sanctions screening, or enhanced due diligence requirements by distancing oneself from the transaction.

The remaining scenarios describe activities that are either legitimate or explainable with proper documentation and transparency. Merely dealing with an institution previously fined for AML violations or conducting legitimate trade with customs compliance does not, on its own, constitute suspicious activity.

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.

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.

Key performance indicators (KPIs) are essential for evaluating the effectiveness and efficiency of transaction monitoring systems within an AML/CFT program. Regulators expect institutions to monitor how well their systems identify, prioritize, and resolve suspicious activity.

The number of alerts raised provides insight into system sensitivity and potential over- or under-alerting. Tracking alerts by region helps institutions identify geographic risk concentrations and emerging threats. The average time to review an alert measures operational efficiency and whether investigations are conducted promptly, as required by regulatory expectations.

Hiring timelines and transaction volumes by top customers are operational or business metrics and do not directly assess transaction monitoring effectiveness.

Business entities in offshore financial centers often pose money laundering risks due to limited organizational disclosure and recordkeeping requirements, which can obscure beneficial ownership and make it easier to conceal illicit financial activities.

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.