CAMS Questions and Answers

Policies are broad guidelines. Procedures are detailed instructions for specific processes. Only 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.

Policies are detailed instructions for specific processes. Procedures are an overarching framework. Neither policies nor 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.

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

Allowing clients lo transact anonymity-enhanced tokens

Onboardlng of clients who are residents abroad. Including those with politically exposed person (PEP) status

Enabling transfer of tokens from one blockchain to another

Offering services to VASPs established in jurisdictions that are not FATF compliant

Operating a network of crypto ATMs charging high fees

Lack of adequate IP address tracking capabilities

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

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

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

Allocating resources equally across all customer segments to ensure fairness

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.

cross-border purchases

purchases in the name of a natural person

paying true market price for a property

non-financed purchases

A relationship manager advocates for overriding the results of the company's client risk rating model that resulted in a client's high-risk rating.

An If employee shares information about a firm's risk management framework with employees of other firms at an industry convention.

An investigator does not complete the automated transaction monitoring system alerts assigned to them before the time required by company procedures.

A relationship manager makes an exception to company policy and proceeds with onboarding a customer without documenting a passport for customer identification

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.

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

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

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

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

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.

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

Allowing fixed income securities to mature

Using brokerage accounts like deposit accounts

Engaging in transactions involving nominees or third parties

Guaranteeing 100% accuracy in regulatory compliance across all jurisdictions

Improving customer satisfaction by offering personalized recommendations

Reducing identity theft effectively

Providing reliable customer authentication to enhance trust

Decreasing the time required for customer authentication

List-based

Secondary

Country-based

Sectoral

Suggest the FI needs to implement a risk-based approach for EDD.

Suggest the management team select the clients that are chosen for EDD.

Suggest the management team ask the regulator for advice on EDD measures.

Suggest EDD for 50% of the clients is appropriate.

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.

Investment advisor

Relationship manager

Operations manager

Compliance officer

imposes economic sanctions on jurisdictions with lax AML controls to force them to strengthen their controls.

conducts on-site inspections of financial institutions in jurisdictions with lax AML controls to identify deficiencies and recommend improvements.

publishes annual reports ranking all member jurisdictions based on their self-assessment of AML controls.

conducts a peer review process whereby member countries assess the AML controls of other jurisdictions and provide recommendations for improvement.

collecting complete customer information.

ongoing screening of customers.

suspicious activity and sanctions reporting.

evaluating the effectiveness of compliance controls.

Forming a trust on behalf of a customer with a complex setup and acting as a nominee director

Auditing a firm that provides payroll software to large corporate customers

Preparing financial statements for a listed or a privately owned firm

Providing tax advice to an international customer hoping to move their assets out of their home country

Assisting an offshore corporation from a jurisdiction with no available beneficial owner information to buy property in the UK

Adaptable to new AFC typologies through continuous model training

Completely unbiased and without error through continuous model training

More consistent and reliable detection outcomes

Transparent and easy to explain algorithms for regulator and compliance purposes

Inform local LEA and regulator of the request for awareness

Close the client's accounts immediately to avoid any undue risk

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

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

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

The institution has observed an increase in customer demand for large-denomination banknotes.

The institution maintains a sequentially numbered log of the monetary instruments it sells.

The institution has observed a reduced settlement time in the transaction services that support the rapid movement or remittance of funds.

The institution has observed an increase in the adoption of its digital products and services.

Helping overcome data protection and information sharing limitations

Enhancing the quality of reporting and additional informational input

Helping to alleviate the financial cost burden on law enforcement

Helping to design common approaches and identify desired deliverables

Offering flexibility, agility, and opportunities to adjust to the ML/TF threat environment

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

In-person training sessions

Comprehensive curriculum delivered by senior management

Comprehensive content with engaging delivery methods

Generalized content designed to apply to a broad audience

applying uniform controls to all customers, regardless of their risk profile

allocating resources and implementing controls based on the level of identified risks

prioritizing regulatory compliance over customer experience and operational efficiency

relying on automated systems to detect and mitigate AFC risks

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

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

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

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

governance arrangements

complexity of the products

results of the last audit

financial status of the business

Close the client's account by informing the client of the subpoena.

Perform a transaction review and respond fully to the subpoena.

File a suspicious activity report (SAR), including the receipt of the subpoena in the SAR narrative.

Adjust the client's risk score and close the case.

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.

generative copilots.

small language models.

privacy coins.

crypto-mixers.

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

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

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

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

KYC analyst

Senior management

Relationship manager

Enhanced due diligence compliance officer

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

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

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

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

Challenge-response

Fingerprint

Security token

Passphrase

Introduction of new products or services

Mergers or acquisitions

Restructuring of the FI's risk and compliance functions

Use of new technologies for delivering existing products

Changes in the individuals overseeing the FI's product lines and sales strategies

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.

Paying premium several years in advance and terminating early for a refund

Natural persons having more than one insurance policy

High-premium life insurances that provide high payouts

Regularly switching policies and accepting penalties

Beneficiary payouts to elderly people

A customer receives funds from a popular decentralized mixer

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

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

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

Private bankers should receive training on AML procedures.

All employees should receive refresher AML training.

The board should review and approve a revised AML policy to change customer due diligence requirements in private banking.

The legal department should conduct a review to assess potential legal consequences.

Cryptoassets can be transferred across borders quickly, but the volatility of their value still makes them less attractive for money laundering compared to traditional assets

Mandatory reporting requirements have been implemented for certain types of crypto transactions, but gaps in regulation and enforcement still leave room for money laundering activities.

The transparency of blockchain technology helps law enforcement trace transactions, but it can also provide criminals with ways to obscure their financial activities through complex layering techniques.

The pseudonymous nature of transactions allows criminals to hide their identities while transferring large sums of money globally, making it difficult to trace the ultimate beneficial owner.

Submit a referral to file a suspicious activity report (SAR)

Evaluate the KYC review process to understand why the review did not occur as required and take corrective action as necessary

Contact the customer's relationship manager to suspend account access until the periodic KYC review is completed

Remove the customer from the bank's high-risk list

Prioritizing resources towards lower-risk areas to reduce workload

Regularly reassessing risks to adjust resource allocation

Allocating more resources to areas with higher financial crime risk

Providing equal resources to all departments to maintain consistency

Using a fixed resource allocation plan without adjustments

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

Using predefined rules to flag specific transaction patterns

Randomly flagging transactions for further investigation

Statistical tuning of monitoring scenarios to improve accuracy

Using advanced machine learning models to detect outliers

Setting transaction thresholds for automated alerts

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

Notify senior management and suggest account closure due to potential risks

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

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

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

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

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

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

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

Accountants being used as intermediaries to introduce criminals to financial institutions

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.

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

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

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

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

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

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

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

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

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

enacting legislation regarding the operations of financial institutions.

Be consistent with the head office audits

Be tailored to the higher of standards between the jurisdictions.

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

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

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.

Information security, data privacy, and cybersecurity

Foreign exchange control, and precious gemstone and metal dealing

Ombudsman and anti-competition authority

Electronic contract and biological signature acceptance

Consumer protection, financial inclusion, and environmental, social and governance

identification of the customer's occupation.

identification and verification of the customer's identity.

identification of the customer's work address.

identification of the beneficial owner.

verification of the customer's credit history.

[verification of the customer's income sources.

Inquiring about the source of wealth and source of funds

Asking to provide a list of immediate family members

Verifying the financial crime awareness of the client

Collecting necessary documents to verify the veracity of information

include sophisticated and automated controls that use the newest types of technology available (for example, artificial intelligence (Al) and machine learning).

be proportionate with regard to the size and nature of the firm, approved by senior management, and regularly reviewed

be completed by the business and validated by an external firm (for example, an auditing or consulting firm)

be created approved, and owned only by the First Line of Defense business team, and reviewed annually

An external audit highlights several deficiencies

The company is merging with or acquiring another entity

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

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

using shell companies or trusts for privacy, lax planning, or asset protection.

in the names of unrelated thud patties.

using the proceeds from selling a prior property or liquidating investments to make an all-cash purchase

using legal entities and intermediaries to protect the privacy of the purchasers.

using loans backed by cash or certificates of deposit.

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

Perform a control and ownership assessment of the businesses involved, using the information available in the client files

Contact local law enforcement and request that they assist in the analysis and investigation

Review the information presented in the automated monitoring system's alert description and decline any future transactions

Contact the account manager and ask for the reasons behind the patterns of activity highlighted in the AML alerts

Use social media platforms to connect with the businesses and request details about the account activity

Enhanced due diligence (EDD)

Transaction monitoring

Customer risk assessment

Sanctions screening

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

Accounting

Model risk management

Technology solutions and IT security

Marketing

Fraud risk management

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

Establish an environment to foster trust amongst countries

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

Improve global cooperation between FIUs

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

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.

Cash-intensive businesses risks

Unknown third-party risks

Geographic risks

Anonymous transactions risks

Keep an account open upon verbal request

Produce documents and testimony without a subpoena

Seize privileged documents upon written request

Freeze an account in terms of a court order

Utilizing a flexible communication style that adapts to different customer situations during the termination process

Implementing a standardized procedure for customer termination that includes risk assessments and necessary documentation

Performing a final review of a customer's transaction history and records to address any unresolved issues prior to termination

Keeping records of the termination process, including the justification for the decision and any correspondence with the customer

Notifying the customer of the termination decision only after completing the termination process to prevent possible disputes

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

have never worked in previous assignments within the AMUCFT departments.

have no involvement with the organization's AML/CP T compliance staff.

have been screened by the board of directors before the audit starts

be sufficiently trained in AML to be able to provide an independent review.

International cooperation provides actionable information to use against criminals

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

Money laundering offenses are investigated and criminally prosecuted

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

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

Analyzing customer sentiment through feedback and surveys

Identifying individuals or entities linked to criminal activities or sanctions

Periodically monitoring regulatory updates and enforcement actions for associated entities

Scanning publicly available news articles and regulatory alerts

Monitoring changes in credit scores of individuals or entities

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

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

have written policies and procedures to maintain supporting documentation.

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

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

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

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

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

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

National Risk Assessment

Regulatory guidance or publications

Government or state-run newspapers

Guidance issued by international bodies

Policies and procedures developed by other banks

Establish policies and procedures to ensure due diligence activities are identical for all customers.

Establish policies and procedures to identify and verify customers, beneficial owners, and any individuals that can transact on behalf of their customers.

Establish policies and procedures for customer due diligence that vary based on risk.

Are prohibited from offering numbered accounts to customers, even if procedures are established to gather and maintain due diligence information.

Establish policies and procedures that encourage processing transactions while due diligence information is being established and verified.

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.

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

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.

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

increased reputation risk.

inclusion on the UN Consolidated List.

civil and criminal penalties

delisting of public filing status.

Organizations are required to demonstrate that customers have opted into information sharing before submitting suspicious activity reports to relevant financial intelligence units (FIUs)

Any customer that is the subject of a suspicious report filing has the right to request redaction of their personal data

FIUs should document purposes for which personal data included on suspicious activity reports may be shared with other agencies

Data privacy laws prohibit information sharing between financial institutions for the purposes of AML investigations in all jurisdictions

maintain compliance with the AFC and sanctions requirements of all countries where the F1 operates or has business relationships and to avoid penalties for violations in foreign jurisdictions.

ensure that sanctions regimes are applied selectively based on the regulatory standards of the countries where business activities occur, focusing primarily on aligned jurisdictions

compensate for the limited applicability of AFC and sanctions regulations on cross-border transactions and their reduced relevance for domestic operations in other jurisdictions.

ensure the F1 can manage business relationships in jurisdictions with stricter or more lenient regulations than their home country, allowing for operational flexibility

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

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

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

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

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

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

Money services business (MSB)

Multinational corporations

Individual foreign customers

Non-profit organizations with international operations

Ongoing monitoring

Risk assessment

Policies and procedures

Suspicious activity reporting

Customer due diligence