Pass the ACAMS AML Certifications CAMS Questions and answers with CertsForce

A robust AML training program should incorporate the followingbest practicesto ensure awareness and ongoing engagement:

Option A – Tailored and regular training:

Training should berisk-based and role-specific, ensuring employees understand how AML applies to their function.

Option D – Variety and resources:

Use ofinteractive, digital, live, and scenario-based methodskeeps training effective and adaptable. Providing materials and resources supports continued learning.

Option E – Communication and measurement:

Ongoing AML awareness campaigns andfeedback mechanismshelp assess theeffectivenessof training and reinforce its importance.

Option Bis too vague and not recognized as a best practice.

Option C, while helpful, isnot sufficient alone—annual frequency without contextual or tailored content is inadequate.

According to the FATF Recommendation 40, which sets the standards for international cooperation in relation to money laundering, associated predicate offences and terrorist financing, countries should ensure that exchanged information is used only for the purpose for which it was sought or provided, and that any dissemination or use of the information beyond the original scope is subject to prior authorization by the requested competent authority. Moreover, countries should have safeguards in place to ensure that the information exchanged is protected in a manner that is consistent with the way they protect their own information of a similar nature. One of the possible safeguards is to require the use of non-disclosure agreements or other legal instruments to prevent unauthorized access or disclosure of the exchanged information.

= FATF Recommendation 40, Section A.3; Compliance Trends: AML Information Sharing, Section: Cross-border AML information sharing; Safeguarding AML Information Exchanged with Other Countries, Section: Answers.

A Penza scheme, also known as a Ponzi scheme, is a form of fraud that lures investors and pays profits to earlier investors with funds from more recent investors1 The scheme relies on attracting new investors with unrealistic promises of high returns and low risk, while using their money to pay off the previous investors2 An unlicensed investment advisor who offers profits other investments cannot guarantee is likely to be involved in a Penza scheme, as this is a common way to entice unsuspecting victims3 The other options are not necessarily indicative of a Penza scheme, as they could be legitimate or involve other types of fraud.

 1 Ponzi scheme - Wikipedia; 2 Ponzi Schemes: Definition, Examples, and Origins - Investopedia; 3 What is Ponzi Scheme? - Sanction Scanner

 Mutual Legal Assistance Treaties (MLATs) are agreements between two or more countries that provide the legal framework for the exchange of information and evidence in criminal and related matters. MLATs enable law enforcement authorities and prosecutors to obtain evidence, information, and testimony abroad in a form admissible in the courts of the requesting state. MLATs also establish the procedures and channels for making and receiving requests for assistance, as well as the grounds and conditions for granting or denying such requests. MLATs are an important tool for international cooperation and information exchange to combat transnational crimes, such as money laundering, terrorist financing, fraud, and corruption.

1: Treaties and Agreements - U.S. Department of State

2: Mutual legal assistance treaty - Wikipedia

3: International Exchange of Information Manual - GOV.UK

4: Convention on Mutual Administrative Assistance in Tax Matters

The following were the key features of the Second Directive:

• It extended the scope of the First Directive beyond drug-related crimes. The definition of “criminal activity” was expanded to cover not just drug trafficking, but all serious crimes, including corruption and fraud against the financial interests of the European community.

• It explicitly brought bureaux de change and money remittance offices under AML coverage.

• It clarified that knowledge of criminal conduct can be inferred from objective factual circumstances.

Option A indicates potential money laundering activity by a lawyer, as it involves the use of a trust account to receive and transfer funds from unknown sources in high risk jurisdictions, without any apparent legitimate purpose or explanation. This could be a sign of layering, where the money launderer attempts to conceal the origin and ownership of the illicit funds by moving them through multiple accounts and jurisdictions. Option B does not necessarily indicate money laundering, as the source of the funds is a reputable entity and the transfer could be explained by a legitimate transaction or service. Option C does not necessarily indicate money laundering, as the bank draft could be a payment for a legal service or a settlement between parties. Option D does not necessarily indicate money laundering, as the cash deposit could be a fee for a legal service or a donation, and the amount could be below the reporting threshold to avoid unnecessary paperwork or scrutiny.

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CAMS Certification Package - 6th Edition | ACAMS1

CAMS Certifications: How to Get CAMS Certified | ACAMS2

ACAMS CAMS Certification Video Training Course - Exam-Labs3

Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)4

Financial Intelligence Units (FIUs) are the primary channels for sharing financial intelligence both within countries and across borders. FIUs cooperate with each other and other relevant law enforcement, regulatory, or intelligence agencies in the fight against money laundering, terrorism financing, and other financial crimes.

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.

 a financial institution must perform a continuing review of the account for a period of 90 days. The continuing review must include an analysis of any transactions that occur in the account, as well as any changes in the customer's risk profile. The review should be updated as needed to ensure that the customer is not engaging in any suspicious activities.

According to the CAMS Certification Package - 6th Edition1, one of the essential components of customer due diligence is verifying the identity of the customer using reliable and independent sources. This verification process should be done before or during the establishment of the business relationship, and should not be delayed unless there is a low risk of money laundering or terrorist financing, and the delay is necessary to avoid interrupting the normal course of business. Therefore, after customers have provided acceptable identification, the financial institution should next confirm the validity of the customer information, as option A suggests. Option B is not necessary, as an electronic picture of each customer is not a mandatory requirement for customer verification, and may not be feasible or effective in some cases. Option C is not the next step, as closely monitoring the account for 30 days is part of the ongoing due diligence process, which should be performed after the customer verification is completed and the account is established. Option D is not advisable, as establishing the account based on the information provided without verifying its validity may expose the financial institution to money laundering and terrorist financing risks, and may violate the KYC and AML regulations.

1: CAMS Certification Package - 6th Edition | ACAMS, Chapter 3: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), pages 69-70.

https://www.wolfsberg-principles.com/sites/default/files/wb/pdfs/wolfsbergstandards/10.%20Wolfsberg-Private-Banking-Prinicples-May-2012.pdf

2.4 Senior Management Approval

The bank's internal policies should indicate whether, for any one or more among these categories, Senior

Management must approve entering into new relationships.

Relationships with Politically Exposed Persons may only be entered into with the approval of Senior Management.

A: The main objective of anti-bribery and corruption regulations is to prohibit bribes to government officials or employees of state-owned enterprises for the purpose of obtaining or retaining business or securing improper advantages.

“Anti-bribery and corruption regulations, such as the FCPA and UK Bribery Act, prohibit offering anything of value to public officials to gain a business advantage.”(CAMS 6th Edition, Anti-Bribery and Corruption)

 the U.S. government has the authority to seize and forfeit funds in a correspondent account of a non-U.S. bank if the funds are involved in or traceable to a money laundering offense, regardless of where the offense occurred. This is based on the USA PATRIOTAct, which expanded the definition of “proceeds of specified unlawful activity” to include any property that is derived from or traceable to a foreign offense that would be a predicate offense if committed in the U.S12

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1: ACAMS Study Guide for the CAMS Certification Examination, 6th Edition, Chapter 4, page 137

2: USA PATRIOT Act, Title III, Section 319(b)

A. Geographic risks should be used to identify the priority of the Fl in this scenario. According to the CAMS Manual (6th Edition), "Geographic risk refers to the possibility that the location of a customer, transaction, or product may increase the likelihood of money laundering or terroristfinancing because of weak or nonexistent AML/CFT controls" (p. 59). In this scenario, the expansion to an area of the world with weak AML laws would increase the Fl's geographic risk.

Money laundering through real estate is a common method of disguising the source and ownership of illicit funds. Real estate transactions often involve large amounts of money, complex legal structures, and cross-border transfers, which can obscure the true nature and origin of the funds. The new business customer in this scenario raises several red flags that warrant enhanced due diligence, such as:

The business was established five years ago but has a vague website and no physical presence in the state where it is registered.

One of the principals has an international phone number and lives abroad, which could indicate a foreign shell company or a politically exposed person.

The other principal works out of a recreational vehicle, which could suggest a lack of legitimate business activity or income.

The business claims to be a real estate business, but does not provide any details about its projects, clients, or partners.

These factors suggest that the business may be involved in money laundering through real estate, either by purchasing properties with illicit funds, using properties to generate illegal income, or selling properties to launder money. Therefore, the financial institution should conduct enhanced due diligence to verify the identity, background, and source of funds of the business and its principals, as well as the purpose and nature of the account relationship.

ACAMS Study Guide for the CAMS Certification Examination - 6th Edition, Chapter 2: Money Laundering Risks and Methods, pp. 46-47

Enhanced Due Diligence in Construction and Real Estate, by James Swenson, Ethixbase 360

Due Diligence & Legal Considerations in Commercial Real Estate, by Justia

Private investment companies (PICs) are potentially vulnerable to money laundering due to the difficulty in identifying the ultimate beneficial owners. PICs are often used to hold and manage private wealth, making them attractive targets for money launderers. Since these entities are privately held and not publicly traded, it can be challenging to identify the individuals whoultimately control or benefit from them. This makes it easier for money launderers to use them to disguise the origins of illicit funds.

Compare customer and transaction records against periodically updated sanctions lists provided by governmental bodies. This is stated in the Certified Anti-Money Laundering Specialist (the 6th edition) manual on page 595, which states: “Sanctions screening requirements include that a financial institution should compare customer and transaction records against periodically updated sanctions lists provided by governmental bodies.”

The audit function should report to the audit committee of the board of directors (or similar oversight body) and independently evaluate the risk management and controls of the bank through periodic assessments, including the adequacy of the bank’s controls to mitigate the identified risks, the effectiveness of the bank’s staff’s execution of the controls, the effectiveness of the compliance oversight and quality controls and the effectiveness of the training.

These are the information that can help the correspondent bank to assess the risk profile, the regulatory compliance, and the operational capacity of the respondent bank, and to verify its identity and legitimacy. The correspondent bank should obtain and verify the following information about the respondent bank:

Respondent’s management, nature of license, and major business activity. This can help the correspondent bank to understand the governance, the legal status, and the core functions of the respondent bank, and to evaluate its reputation, integrity, and competence.

The quality of supervision in the home country. This can help the correspondent bank to determine the level of oversight and regulation that the respondent bank is subject to, and to identify any potential gaps or weaknesses in the anti-money laundering and counter-terrorist financing (AML/CTF) framework of the home country.

Respondent’s location, in particular the existence of a real physical presence. This can help the correspondent bank to verify the actual existence and operation of the respondent bank, and to avoid dealing with shell banks or banks located in high-risk or non-cooperative jurisdictions.

The other option is not necessarily information that should be included to establish a rigorous “Know Your Respondent” procedure, although it may have some relevance or importance depending on the circumstances and the nature of the correspondent relationship. Option 2 describes computer equipment and software capability, which may be useful to assess the technical and operational compatibility and efficiency of the respondent bank, but it is not essential to evaluate its risk or compliance level.

ACAMS CAMS Certification Video Training Course - 6th Edition1

Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)2

ACAMS CAMS Study Guide - 6th Edition, Chapter 7, pages 154-155

https://www.acams.org/wp-content/uploads/2019/09/ACAMS-CAMS-Study-Guide-6th-Edition-Chapter-7.pdf

According to the Wolfsberg Group, a global association of leading banks that develops guidance and standards for the management of financial crime risks, both private and correspondent banks should monitor account and transactional activity after the proper identification and verification of customers, as part of their anti-money laundering and counter-terrorist financing (AML/CTF) measures12. This is consistent with the FATF Recommendation 10, which requires financial institutions to conduct ongoing due diligence on their business relationships, including scrutinising transactions to ensure that they are consistent with the customer’s risk profile and source of funds3. Monitoring account and transactional activity is a key component of the risk-based approach, as it enables banks to detect and report suspicious or unusual transactions, identify changes in customer behaviour or circumstances, and update customer information and risk assessments accordingly4.