CAMS Sample Questions Answers

Inviting prospective customers for an onboarding interview

Rejecting any politically exposed persons (PEPs) as customers

Understanding the source and origin of assets

Performing negative news checks of prospective customers

Producing financial stability reports on interesting customers

Concealing sources of funds

Allowing for third-party custody safekeeping of funds

Adding a layer of anonymity to transactions

Concealing true legal and beneficial owners

Establishing escrow accounts for real estate transactions

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.

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

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

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

Using gaming accounts to transfer illicit funds between players undetected

Structuring transactions to avoid reporting thresholds by keeping them under certain limits

Providing false personal information to evade regulatory oversight

Ensuring identity verification is completed prior to the onboarding of new customers

Investing all gaming winnings into high-risk stocks to conceal funds

wire transfers in different currencies between accounts held at different banks for the same client.

an incoming third-party wire transfer followed by the purchase of real estate in the client's name.

an incoming wire transfer followed by the loan payment to a third party that is a business associate of the client.

multiple wire transfers sent to counterparties associated with the client as per KYC documentation.

Management structure

Governance framework

Asset structure

Origin of the funds

Subscribing lo a regulators' newsletter

Using a specific provider for regulatory horizon scanning

Regularly contacting the regulator to inquire about updates and future developments

Relying on information and insights from peers and working groups

An RAS defines the amount and type of risk an organization is willing to take to achieve its objectives and should be communicated clearly to all stakeholders with corresponding controls implemented

An RAS is a detailed plan for managing operational risks and does not cover strategic or financial risks

An RAS is a formal document meant for regulatory compliance that does not influence day-to-day risk management practices within the organization

An RAS is used to outline the risk tolerance limits to external stakeholders and does not need to be communicated within the organization

National Risk Assessment

Regulatory guidance or publications

Government or state-run newspapers

Guidance issued by international bodies

Policies and procedures developed by other banks

fraudulent identities involving stolen or manufactured identification.

suspicious behavior involving a transaction that occurs at an unusual time of day.

hidden beneficial owners.

transaction patterns involving transactions that exceed a certain dollar amount.

anomalies involving a transaction that occurs in a location far away from the customer's usual spending patterns.

Use of wire transfers

Loitering

Instructions or involvement from third parties

Amended letters of credit without reasonable justification

Non-standard settlement arrangements

Engage in the PPP without strict data sharing protocols, allowing for open and unrestricted flow of information between the bank, FIUs, and other financial institutions

Rely solely on the intelligence provided by government agencies through the PPP because they have the most comprehensive data on suspicious activities

Establish a clear framework within the PPP that outlines data privacy protections and ensures that information sharing complies with legal and regulatory requirements in all jurisdictions involved

Prioritize the bank’s internal data sources over external intelligence from PPPs, as internal data is easier to control and does not present data privacy challenges

allows Financial Intelligence Units (FlUs) to enact sanctions against perpetrators of financial crime

promotes financial transparency and protects the integrity of the financial systems

needs to be approved by the Financial Intelligence Unit (FIU) before sharing between financial institutions

helps financial institutions to be more effective in fighting crime with data analysis

Establishing risk controls

Assessing risk controls

Ongoing risk monitoring

Conducting a risk assessment

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

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

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

OFAC sanctions automatically expire after five years unless renewed by Congress

A customer engages an attorney to consult on the issuance of the policy.

A customer transfers the policy to another insurance company unaffiliated with the original policy issuer.

Payments are regularly received from third parties that have no apparent relationship with the policy holder.

A customer names an apparently unrelated third party as a beneficiary.

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

Assessing whether internal staff members can provide training on the tools

Assessing the cost of implementation and cost of maintaining the tools

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

Using brokerage accounts like deposit accounts

Receiving securities into an existing brokerage account following the death of a spouse

Allowing fixed income securities to mature

Engaging in transactions involving nominees or third parties

FIs may disclose customer information to any third party

FIs may provide information about their internal compliance programs to law enforcement agencies without any limitations

FIs are required to report all transactions involving foreign entities to FinCEN so that FinCEN can share this information with other financial institutions

FIs may share information about suspected money laundering activities with other FIs to aid in identifying and reporting suspicious transactions

Periodic review of suspicious activity reports (SARs) filed with FinCEN to determine whether any should be withdrawn.

Periodic and ad hoc cooperation with the legal team to appropriately investigate and monitor the transactions of subjects of subpoenas or government inquiries.

Periodic review of client profiles to ensure that the most up-to-date information is on file for high-risk clients in line with the bank’s internal policies and procedures.

Periodic review of the transaction monitoring scenarios and their productivity to ensure that appropriate AML typologies are reflected.

up to date and reflects all relevant regulatory developments

signed off by the board of directors and regulators

approved by the clients and third parties

clearly communicated and understood by staff

to force developing nations to adopt liberal or substantive democracies.

to support governments and regimes in the peaceful resolution of conflict.

to punish governments for having weak financial crime controls.

to deter non-democratic and non-constitutional changes within countries.

to support the protection of human rights.

A customer changes multiple high-denomination notes to low-denomination notes.

A customer conducts cash transactions using multiple branches of the MSB on the same day.

A customer has a family link to the destination of a money transfer

A customer sends and receives money transfers in equal amounts at or about the same time.

A customer only wants to deal with a particular employee in the MSB.

Performing a comprehensive risk assessment to identify customer, transaction, and geographic risks

Focusing monitoring primarily on previously flagged customers while using standard controls for others

Choosing and applying effective controls that align with the identified risk levels

Determining detailed risk profiles for customers based on their activities and relationships

Allocating resources equally across all customer segments to ensure fairness

Companies operating in cash intense businesses not subject to licensing requirement

Companies operating hospitals and health-care services

Companies operating in cash intense businesses subject to licensing requirement

Companies producing pharmaceutical products and medical devices, companies active in the mining industry

Companies operating retail shops countrywide

Policies are detailed instructions for specific processes. Procedures are an overarching framework. Neither policies nor procedures are mandatory for knowledge and adherence

Policies are broad guidelines. Procedures are detailed Instructions for specific processes. Only procedures are mandatory for knowledge and adherence.

Policies are detailed instructions for specific processes Procedures are an overarching framework Both policies and procedures are mandatory for knowledge and adherence.

Policies define the principles of an organization and influence the drafting of procedures. Procedures are detailed instructions for specific processes.

Oversight of the Financial Intelligence Units in FATF Member countries

Providing a unique platform for information exchange regarding anti-money laundering efforts

Regulation of financial markets through directives and executive orders

Enhancement of international cooperation to foster anti-money laundering efforts via recommendations and guidance

Periodic and ad hoc cooperation with the legal team to appropriately investigate and monitor the transactions of subjects of subpoenas or government inquiries

Periodic review of client profiles to ensure that the most up-to-date information is on file for high-risk clients in line with the bank's internal policies and procedures

Periodic review of suspicious activity reports (SARs) filed with FinCEN to determine whether any should be withdrawn

Periodic review of the transaction monitoring scenarios and their productivity to ensure that appropriate AML typologies are reflected

triggers identifying static data changes and data based on client's behaviors in real time.

periodic refreshing at one-, three- and five-year cycles.

ability to prioritize better based on client data rather than driven by schedules alone.

classification of clients into categories of risk.

The agent requested a disposal of assets at a lower price than recently acquired.

The assets acquired through an auction were put in the name of an offshore company

The agent acted on behalf of an individual residing in a country which is on the EU's list of high-risk jurisdictions

The power of attorney was issued by a law firm in a different EU country from where the transaction took place.

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

approval by money-laundering reporting officer for the proposal.

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

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

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

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

These businesses are all cash intensive, increasing the risk of financial crime

KYC challenges arise because e-commerce platforms face global customers making customer due diligence complex and resource intensive

These businesses are highly regulated and therefore have no reason to be non-compliant as this would put them at risk of sanctions and fines

Criminals can make use of identify fraud to fulfill KYC processes for layering purposes

The settlement systems of these businesses are not sophisticated enough to cope with the high transaction volume

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.

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.

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.

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.

collecting complete customer information.

ongoing screening of customers.

suspicious activity and sanctions reporting.

evaluating the effectiveness of compliance controls.

governance arrangements

complexity of the products

results of the last audit

financial status of the business

A check returning a mortgage overpayment made in error

A payment made to a mixer platform

A regular standing order to a high-interest savings account

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

Escalate the matter to the institution's high-risk client committee, presenting the investigation findings and recommending offboarding while also acknowledging the relationship manager's concerns

Proceed with offboarding the customer unilaterally based on their investigation findings and anti-money laundering (AML) concerns

Attempt to persuade the relationship manager to agree with the offboarding recommendation by highlighting the potential reputational and regulatory risks associated with maintaining the relationship

Delay the offboarding decision and continue monitoring the customer's activities, waiting for further evidence to solidify the case for termination

Implementation of a blacklist of correspondent customers with previously detected and investigated suspicious activity

Enhancement of a customer acceptance policy to more clearly identify high-risk customers

Increased frequency of training provided to front office employees

Enhancement of customer identification procedures to appropriately identify trust, nominee, and fiduciary accounts

It reduces the overall cost of compliance programs.

It eliminates the need for periodic audits of low-risk customers.

It ensures focus on high-risk areas while maintaining operational efficiency.

It standardizes compliance processes across all regions.

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

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

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

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

the operational burden of dealing with potential matches.

the value of fines for non-compliance.

the experience of the team dealing with potential matches.

whether the data to be screened is reliable and verified.

Trade-based money laundering

Corruption

Illicit resource trade

Environmental crime

protect the rights of the citizens of the state target against their own government and improve financial stability in the region.

indicate that the use of military force is likely unless the state or non-state target complies with the government's

interests encourage non-governmental organizations to increase the provision of humanitarian and charitable aid to the target

alter the behavior of the state or non-state target that threatens the interests of that government or violates international norms

Consistency of approach

Periodic training of the function

Qualification of the team

Independent testing

Reduction in the number of false positives in long term

Complete automation of compliance processes

Elimination of the need for human oversight

Increased flexibility in adapting to changing financial crime risks

Enhanced ability to detect emerging patterns and anomalies

product risk.

credit risk.

geographic risk.

customer risk.

liquidity risk.

Make a note in the customer's account that the customer's gambling activities are frequently conducted below the reporting limit

Follow internal reporting procedures to escalate the activity as suspicious and report to appropriate authorities

Inform the customer their activity Is suspicious and request an explanation

Contact law enforcement to launch an Investigation into the customer's financial activities

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

remote verification of identity by third-party program managers.

heavy usage by senior political figures.

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

heightened risks of returned transactions.

Allow beneficial owners to provide proxies lot voting on corporate decisions

Obscure beneficial ownership

Allow domicile in the nominee's jurisdiction

Derail investigations

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

Directly prosecuting money launderers in court

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

Raising awareness about the issue of money laundering and its consequences

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

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

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

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

The residual risk would be eliminated entirely because the controls are sufficient to mitigate all potential risks

The residual risk would be significantly reduced due to the effectiveness of the controls in place

The residual risk would remain high due to the inherent nature of the private banking business

The residual risk would be moderately reduced, but further controls may be necessary to achieve an acceptable level

Narrow the media sources to avoid unrelated articles

Rely on manual filtering by investigators

Increase the frequency of updates to media sources

Adjust AI/ML models to focus on high-risk keywords/phrases from reputable media sources

Pre-populated templates for SAR filing

Integration of open-source tools to gather real-time intelligence

Automated case prioritization based on risk scoring

AI-powered dashboards summarizing flagged transactions

Accounting

Model risk management

Technology solutions and IT security

Marketing

Fraud risk management

It produces outputs that include a range of intermediate possibilities between "Yes" and "No"

It is an advanced analytics tool widely used to implement AFC controls

It allows for a greater number of exact matches, reducing the need for manual review

It is a new technique for enhancing the quality of alerts for review

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.

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.

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.

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.

The first line

The second line

Senior management

The third line

Surrendering a policy early to liquidate funds

Focusing excessively on the investment performance of an insurance product

Using a credit card to purchase an insurance policy

Using cryptocurrencies or other non-fiat currencies to fund an insurance policy

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

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

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

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

ML undermines the integrity and stability of financial systems and makes them vulnerable to illegal activity. This can erode investor confidence and hinder economic growth.

When a financial institution (FI) is found to be promoting ML or violating AFC regulations, this can lead to a loss of confidence in the institution and a loss of customers. Interestingly, this scenario might sidestep any legal consequences for the Fl.

When laundered funds flow into legitimate economies, they can be used for illegal purposes, such as funding terrorist activities or organized crime. This distorts resource allocation and undermines development.

Jurisdictions perceived as having insufficient ML measures might be identified as uncooperative or high-risk, potentially facing restricted access to international markets, though economic sanctions by other countries are an unlikely outcome.

to force developing nations to adopt liberal or substantive democracies.

to support governments and regimes in the peaceful resolution of conflict.

to punish governments for having weak financial crime controls.

to deter non-democratic and non-constitutional changes within countries.

to support the protection of human rights.

Consumer protection laws may intersect will) AML/CFT requirements when handling customer complaints or disputes, potentially affecting how FIs implement their compliance programs.

AML/CFT laws are the primary focus for FIs, and other regulations like data privacy and consumer protection may only indirectly influence their compliance obligations

Environmental, social, and governance (ESG) frameworks can influence a Fl's risk management strategies but are generally considered separate from core AML/CFT compliance requirements

Data privacy laws can restrict the sharing of customer information, while financial inclusion initiatives require FIs to avoid excessive de-risking that could exclude vulnerable populations.

Fully rely on central beneficial owner registry records in the high-risk third country to determine the ultimate beneficial owners of all customers

Apply tailored due diligence measures, based on the level of risk posed by each customer following risk assessment

Monitor every cross-border transaction in real time, flagging all for enhanced scrutiny due to the country risk level

Automatically apply enhanced customer due diligence measures to all customers in the high-risk third-country branch regardless of risk level

It is against international laws on data protection to access information from foreign countries

Sovereignty of nations means that information cannot be accessed from foreign countries

Any information related to money laundering can be received from any organization at any time regardless of jurisdiction

Countries that are members of the Egmont Group can request assistance for information from each other