ACAMS CAMS (Certified Anti-Money Laundering Specialist (the 6th edition)) Practice Test 13

Question 120

An AFC alert contains these facts: A token project describes its protocol as decentralized but a company retains privileged controls over customer funds. Which conclusion is most appropriate as a working hypothesis?

  1. E-commerce collusive transaction laundering
  2. Online gambling third-party payment risk
  3. Stored-value layering through weak identity linkage
  4. Potential VASP activity despite a DeFi label
  5. Casino chip conversion laundering risk

Explanation

Correct Answer

D:

Functional control over financial services may create regulated-service obligations despite marketing terminology. The specific risk is grounded in a token project describes its protocol as decentralized but a company retains privileged controls over…, not in the alternative scenario of a marketplace pays seller proceeds to newly added bank accounts after bursts of fabricated….

Incorrect Answers

A:

Compared with the stated facts about a token project describes its protocol as decentralized but a company retains…, fake trades can create a false sales narrative for moving value to connected sellers. The prerequisite pattern differs: a marketplace pays seller proceeds to newly added bank accounts after bursts of fabricated purchase…. The question instead describes a token project describes its protocol as decentralized but a company retains privileged controls….

B:

This is not the central mechanism when a token project describes its protocol as decentralized but a company retains…; multiple funders and changed beneficiaries undermine verification of whose value is being transferred. This would change the core risk being assessed from a token project describes its protocol as decentralized but a company retains privileged controls… to an online betting account is funded by several payment cards and withdraws winnings to a different….

C:

When testing the contrasting pattern of a token project describes its protocol as decentralized but a company retains…, remember that transfers through anonymous wallets can obscure originators and ultimate recipients. The alternative requires the facts represented by a digital-wallet provider allows unverified subaccounts to transfer balances repeatedly between…; the principal facts instead show a token project describes its protocol as decentralized but a company retains privileged controls….

E:

Against the reported situation in which a token project describes its protocol as decentralized but a company retains…, minimal wagering followed by redemption suggests the establishment may be used to convert the form of cash. A case of a casino patron exchanges large cash amounts for chips and redeems them shortly afterward without… would support that classification; here the relevant evidence is a token project describes its protocol as decentralized but a company retains privileged controls….

Question 121

An AFC specialist is reviewing this situation: A high-risk subsidiary is included in the enterprise risk assessment but not in the sanctions-specific risk assessment. What is the most precise risk interpretation?

  1. Combined dual-use trade and geographic high-risk scenario
  2. Ongoing screening and EDD lifecycle gap
  3. Inconsistent risk assessment coverage by financial-crime risk type
  4. Expected-activity profile no longer matches actual use

Explanation

Correct Answer

C:

An enterprise view alone may not characterize distinct sanctions exposure and controls. The key factual distinction is between a high-risk subsidiary is included in the enterprise risk assessment but not in the sanctions-specific… and the alternative pattern in which a trade client purchases dual-use machinery through several intermediary companies near a….

Incorrect Answers

A:

Goods, destination, and opaque counterparties create overlapping sanctions and proliferation concerns; the observed record here instead involves a high-risk subsidiary is included in the enterprise risk assessment but not in the…. A case of a trade client purchases dual-use machinery through several intermediary companies near a conflict… would support that classification; here the relevant evidence is a high-risk subsidiary is included in the enterprise risk assessment but not in the….

B:

Against the reported situation in which a high-risk subsidiary is included in the enterprise risk assessment but not in the…, public office and close-associate status may arise after customer acceptance. The prerequisite pattern differs: a bank screens PEPs only during initial account opening. The question instead describes a high-risk subsidiary is included in the enterprise risk assessment but not in the….

D:

Compared with the stated facts about a high-risk subsidiary is included in the enterprise risk assessment but not in the…, monitoring depends on current knowledge of purpose and expected activity. The alternative requires the facts represented by a customer profile lists salary income but transactions show unusually large commercial receipts; the principal facts instead show a high-risk subsidiary is included in the enterprise risk assessment but not in the….

Question 122

During an investigative triage meeting, staff describe a case: A board receives annual compliance training identical to the material used for new customer-service employees. What is the most defensible characterization?

  1. Uncoordinated data privacy and AML record governance
  2. Unclear functional ownership inside the AFC operating model
  3. Insufficient governance-level AFC education
  4. Cybersecurity and AML investigation integration gap

Explanation

Correct Answer

C:

Directors need oversight, risk appetite, and escalation knowledge rather than only introductory transaction examples. The distinguishing facts concern a board receives annual compliance training identical to the material used for new customer-service…; the competing interpretation would require evidence of a privacy team deletes records under an automated schedule without considering mandatory….

Incorrect Answers

A:

Compared with the stated facts about a board receives annual compliance training identical to the material used for new…, retention obligations and active investigations may require legally justified preservation despite ordinary deletion rules. The alternative requires the facts represented by a privacy team deletes records under an automated schedule without considering mandatory AML…; the principal facts instead show a board receives annual compliance training identical to the material used for new customer-service….

B:

This is not the central mechanism when a board receives annual compliance training identical to the material used for new…; investigation capacity alone does not cover governance, prevention, monitoring, and program maintenance. That mechanism is illustrated by a financial crime team has investigators but no ownership of data quality, training, or sanctions…, not by the stated activity involving a board receives annual compliance training identical to the material used for new customer-service….

D:

Account takeover can generate fraud proceeds and money-mule transfers visible across systems; the observed record here instead involves a board receives annual compliance training identical to the material used for new…. For the alternative option of cybersecurity and aml investigation integration gap in this risk interpretation review involving a board receives annual compliance training identical to the material used for new…, the prerequisite pattern differs: a cybersecurity team detects a compromised customer login but the AFC team never reviews the…. The question instead describes a board receives annual compliance training identical to the material used for new customer-service….

Question 123

The financial-crime unit receives this referral: A small nonprofit receives the same level of documentation demands as a complex offshore corporate group. Which risk is the referral primarily illustrating?

  1. Enterprise risk assessment change-management failure
  2. Risk appetite statement too vague to operationalize
  3. Inconsistent policy-to-standard translation
  4. Risk-based approach replaced by uniform control intensity

Explanation

Correct Answer

D:

Equivalent checks for materially different exposures can waste capacity and impair inclusion. The distinguishing facts concern a small nonprofit receives the same level of documentation demands as a complex offshore corporate group; the competing interpretation would require evidence of a firm expands into a high-risk remittance corridor but leaves enterprise risk scores….

Incorrect Answers

A:

This is not the central mechanism when a small nonprofit receives the same level of documentation demands as a complex…; material new geographies and products alter inherent exposure even between scheduled assessment cycles. A case of a firm expands into a high-risk remittance corridor but leaves enterprise risk scores unchanged for… would support that classification; here the relevant evidence is a small nonprofit receives the same level of documentation demands as a complex offshore corporate….

B:

When testing the contrasting pattern of a small nonprofit receives the same level of documentation demands as a complex…, remember that a slogan does not identify acceptable exposures, decision triggers, or escalation tolerances. The prerequisite pattern differs: a bank's risk appetite says 'zero financial crime' but gives no measurable boundaries for high-risk…. The question instead describes a small nonprofit receives the same level of documentation demands as a complex offshore corporate….

C:

Common minimum requirements can fail where local procedures apply incompatible definitions; the observed record here instead involves a small nonprofit receives the same level of documentation demands as a complex…. This would change the core risk being assessed from a small nonprofit receives the same level of documentation demands as a complex offshore corporate… to two branches define 'high-risk customer' differently despite a central group standard.

Question 124

A control gap has come to light: An insurance broker proposes many single-premium policies purchased by entities with the same hidden controller. What is the central financial-crime risk behind it?

  1. Concentrated ownership behind distributed insurance placements
  2. Securities allocation and third-party funding risk
  3. Receivables financing based on fictitious trade
  4. Unhosted-wallet counterparty opacity

Explanation

Correct Answer

A:

Separate policyholders may conceal a common source of funds and correlated exposure. The key factual distinction is between an insurance broker proposes many single-premium policies purchased by entities with the same hidden… and the alternative pattern in which a securities intermediary receives funding through unrelated customer accounts before a….

Incorrect Answers

B:

When testing the contrasting pattern of an insurance broker proposes many single-premium policies purchased by entities with…, remember that unrelated payments can conceal beneficial subscribers and enable value transfer between clients. This would change the core risk being assessed from an insurance broker proposes many single-premium policies purchased by entities with the same… to a securities intermediary receives funding through unrelated customer accounts before a bulk share….

C:

False invoices can convert unsupported payment claims into apparently legitimate credit proceeds; the observed record here instead involves an insurance broker proposes many single-premium policies purchased by entities with…. The alternative requires the facts represented by a factoring company finances invoices issued to counterparties with no verified trading history; the principal facts instead show an insurance broker proposes many single-premium policies purchased by entities with the same….

D:

Against the reported situation in which an insurance broker proposes many single-premium policies purchased by entities with…, the lack of an intermediary may limit available customer information and increase source/destination uncertainty. That mechanism is illustrated by a trading platform repeatedly sends virtual assets to an unhosted address controlled by an…, not by the stated activity involving an insurance broker proposes many single-premium policies purchased by entities with the same….

Question 125

This unusual pattern is reported in a financial institution: Two supervisors request overlapping transaction samples from a cross-border banking group with inconsistent definitions. Which exposure is most directly indicated?

  1. Failure to use official typology alerts in risk assessment
  2. Unaddressed supervisory lessons-learned risk
  3. Misalignment between national threat findings and product risk
  4. Cross-jurisdiction supervisory coordination challenge

Explanation

Correct Answer

D:

Parallel examinations can produce conflicting requests unless the group reconciles terms and responsibilities. For the supported action of cross-jurisdiction supervisory coordination challenge in this risk interpretation review involving two supervisors request overlapping transaction samples from a cross-border banking group with…, this classification follows the described behavior; the different example of a regional FIU report identifies a new invoice-manipulation scheme involving the bank's… would raise a different primary exposure.

Incorrect Answers

A:

Against the reported situation in which two supervisors request overlapping transaction samples from a cross-border banking…, public FIU intelligence can identify emerging methods that change the institution's exposure. The alternative requires the facts represented by a regional FIU report identifies a new invoice-manipulation scheme involving the bank's trade…; the principal facts instead show two supervisors request overlapping transaction samples from a cross-border banking group with….

B:

The relevant alternative mechanism is different from two supervisors request overlapping transaction samples from a cross-border banking…: Enforcement publications can reveal control weaknesses relevant to institutions beyond the named offender. That mechanism is illustrated by a supervisor publishes an enforcement case about missed cash reporting by small branches, not by the stated activity involving two supervisors request overlapping transaction samples from a cross-border banking group with….

C:

Compared with the stated facts about two supervisors request overlapping transaction samples from a cross-border banking…, national assessments may identify trade or correspondent risks even where consumer business is limited. A case of a bank ignores a national proliferation-financing threat assessment because it has little retail… would support that classification; here the relevant evidence is two supervisors request overlapping transaction samples from a cross-border banking group with….

Question 126

An AFC specialist is reviewing this situation: A warehouse operator routes illicit cash proceeds into retail deposits while claiming ordinary shop sales. What is the most precise risk interpretation?

  1. Placement of criminal proceeds
  2. Environmental-crime predicate risk
  3. Regulatory and enforcement risk from late escalation
  4. Extortion-derived criminal proceeds

Explanation

Correct Answer

A:

Illicit receipts are first presented as legitimate business turnover, making the banking entry point the key laundering stage. The distinguishing facts concern a warehouse operator routes illicit cash proceeds into retail deposits while claiming ordinary shop sales; the competing interpretation would require evidence of a recycling firm receives international transfers inconsistent with its permits and….

Incorrect Answers

B:

Against the reported situation in which a warehouse operator routes illicit cash proceeds into retail deposits while claiming…, illegal waste disposal or trafficking can generate proceeds disguised as routine commodities revenue. A case of a recycling firm receives international transfers inconsistent with its permits and declared scrap… would support that classification; here the relevant evidence is a warehouse operator routes illicit cash proceeds into retail deposits while claiming ordinary shop….

C:

The relevant alternative mechanism is different from a warehouse operator routes illicit cash proceeds into retail deposits while claiming…: Failure to investigate and report within governing requirements can result in supervisory action and compliance exposure. For the alternative option of regulatory and enforcement risk from late escalation in this risk interpretation review involving a warehouse operator routes illicit cash proceeds into retail deposits while claiming ordinary…, the prerequisite pattern differs: a suspicious-activity backlog grows until analysts miss required reporting deadlines. The question instead describes a warehouse operator routes illicit cash proceeds into retail deposits while claiming ordinary shop….

D:

Compared with the stated facts about a warehouse operator routes illicit cash proceeds into retail deposits while claiming…, payments demanded under threat constitute potential proceeds of a predicate offence regardless of accounting labels. This would change the core risk being assessed from a warehouse operator routes illicit cash proceeds into retail deposits while claiming ordinary shop… to a technology company pays regular 'recovery fees' to accounts linked to a regional extortion group.

Question 127

A relationship team reports the following activity: A cybersecurity team detects a compromised customer login but the AFC team never reviews the resulting transfer chain. How should its principal financial-crime exposure be classified?

  1. Front-office and compliance handoff failure
  2. Frontline suspicious-activity referral failure
  3. Cybersecurity and AML investigation integration gap
  4. Unclear functional ownership inside the AFC operating model

Explanation

Correct Answer

C:

Account takeover can generate fraud proceeds and money-mule transfers visible across systems. The distinguishing facts concern a cybersecurity team detects a compromised customer login but the AFC team never reviews the resulting…; the competing interpretation would require evidence of a relationship manager promises a high-risk client instant onboarding despite missing….

Incorrect Answers

A:

The relevant alternative mechanism is different from a cybersecurity team detects a compromised customer login but the AFC team never…: Commercial incentives can conflict with mandatory due diligence when acceptance controls are unclear. The alternative requires the facts represented by a relationship manager promises a high-risk client instant onboarding despite missing beneficial…; the principal facts instead show a cybersecurity team detects a compromised customer login but the AFC team never reviews the….

B:

Compared with the stated facts about a cybersecurity team detects a compromised customer login but the AFC team never…, employees with direct relationship knowledge can identify concerns automated systems miss. That mechanism is illustrated by a wealth adviser notices unexpected offshore transfers but believes only the monitoring system can…, not by the stated activity involving a cybersecurity team detects a compromised customer login but the AFC team never reviews the….

D:

When testing the contrasting pattern of a cybersecurity team detects a compromised customer login but the AFC team never…, remember that investigation capacity alone does not cover governance, prevention, monitoring, and program maintenance. For the alternative option of unclear functional ownership inside the afc operating model in this risk interpretation review involving a cybersecurity team detects a compromised customer login but the AFC team never reviews the…, the prerequisite pattern differs: a financial crime team has investigators but no ownership of data quality, training, or sanctions…. The question instead describes a cybersecurity team detects a compromised customer login but the AFC team never reviews the….

Question 128

The financial-crime unit receives this referral: A bank opens a payable-through correspondent arrangement but cannot identify the foreign bank's downstream users. Which risk is the referral primarily illustrating?

  1. Correspondent banking downstream transparency risk
  2. High-value commodity trade laundering exposure
  3. Residual former-PEP and close-associate risk
  4. Foreign politically exposed person exposure

Explanation

Correct Answer

A:

Indirect customers can gain access to payment rails without adequate information about who is using them. This classification follows the described behavior; the different example of a precious-metals dealer receives repeated third-party deposits without links to purchased… would raise a different primary exposure.

Incorrect Answers

B:

When testing the contrasting pattern of a bank opens a payable-through correspondent arrangement but cannot identify the…, remember that portable valuable goods can convert funds into transferable value with limited transparency. The alternative requires the facts represented by a precious-metals dealer receives repeated third-party deposits without links to purchased bullion; the principal facts instead show a bank opens a payable-through correspondent arrangement but cannot identify the foreign bank's….

C:

Leaving office does not automatically eliminate influence or the potential to channel benefits through associates; the observed record here instead involves a bank opens a payable-through correspondent arrangement but cannot identify the…. That mechanism is illustrated by a former senior politician retains influence over a state-owned enterprise through close associates, not by the stated activity involving a bank opens a payable-through correspondent arrangement but cannot identify the foreign bank's….

D:

Against the reported situation in which a bank opens a payable-through correspondent arrangement but cannot identify the…, official power and opaque wealth sources create heightened corruption and misuse concerns requiring enhanced safeguards. A case of a newly appointed foreign minister wants accounts funded by an offshore trust with unexplained… would support that classification; here the relevant evidence is a bank opens a payable-through correspondent arrangement but cannot identify the foreign bank's….

Question 129

A senior reviewer is asked to classify this pattern: A bank appoints an AML officer but does not test policies or train relationship staff. Which interpretation is best supported?

  1. BSA officer or MLRO governance access gap
  2. Third-line assurance independence weakness
  3. First-line conflict in independent AML investigation
  4. Risk appetite statement too vague to operationalize
  5. Missing complementary pillars of a compliance program
  6. Risk appetite not embedded in customer acceptance

Explanation

Correct Answer

E:

Designating an officer is not a substitute for training, effective controls, or independent review. This classification follows the described behavior; the different example of a bank's reporting officer is excluded from material regulatory communication about… would raise a different primary exposure.

Incorrect Answers

A:

The designated compliance officer needs information and a credible route to senior oversight to fulfill duties; the observed record here instead involves a bank appoints an AML officer but does not test policies or train relationship staff. A case of a bank's reporting officer is excluded from material regulatory communication about suspicious… would support that classification; here the relevant evidence is a bank appoints an AML officer but does not test policies or train relationship staff.

B:

Against the reported situation in which a bank appoints an AML officer but does not test policies or train relationship staff, internal audit must be able to evaluate controls objectively rather than audit its own operational design. For the alternative option of third-line assurance independence weakness in this risk interpretation review involving a bank appoints an AML officer but does not test policies or train relationship staff, the prerequisite pattern differs: internal audit designs the transaction monitoring rules it must later assess. The question instead describes a bank appoints an AML officer but does not test policies or train relationship staff.

C:

The relevant alternative mechanism is different from a bank appoints an AML officer but does not test policies or train relationship staff: Business staff own transaction risk but should not independently override compliance investigation decisions. This would change the core risk being assessed from a bank appoints an AML officer but does not test policies or train relationship staff to a branch sales manager closes alerts that implicate the manager's own high-value clients.

D:

Compared with the stated facts about a bank appoints an AML officer but does not test policies or train relationship staff, a slogan does not identify acceptable exposures, decision triggers, or escalation tolerances. The alternative requires the facts represented by a bank's risk appetite says 'zero financial crime' but gives no measurable boundaries for high-risk…; the principal facts instead show a bank appoints an AML officer but does not test policies or train relationship staff.

F:

When testing the contrasting pattern of a bank appoints an AML officer but does not test policies or train relationship staff, remember that an approved restriction has little effect unless screening and approval workflows enforce it. A case of a board approves restricted correspondent banking but sales continues to onboard nested-payment… would support that classification; here the relevant evidence is a bank appoints an AML officer but does not test policies or train relationship staff.

Question 130

An analyst must explain this case to a risk committee: An AFC policy remains unchanged despite a regulator's new guidance on high-risk digital payments. What is the core risk mechanism?

  1. Inadequate regulatory horizon scanning
  2. Misleading AML management information mix
  3. Jurisdiction-dependent suspicious-activity reporting obligation
  4. Weak committee terms of reference
  5. Ineffective governance challenge and follow-through

Explanation

Correct Answer

A:

Material external changes should be assessed for their effects on existing risk controls. This classification follows the described behavior; the different example of a board pack reports alert volumes but omits false positives, overdue cases, and filing… would raise a different primary exposure.

Incorrect Answers

B:

Compared with the stated facts about an AFC policy remains unchanged despite a regulator's new guidance on high-risk…, raw workload counts do not show whether controls are effective or regulatory obligations are met. The alternative requires the facts represented by a board pack reports alert volumes but omits false positives, overdue cases, and filing timeliness; the principal facts instead show an AFC policy remains unchanged despite a regulator's new guidance on high-risk digital payments.

C:

This is not the central mechanism when an AFC policy remains unchanged despite a regulator's new guidance on high-risk…; reporting authority, triggering standard, timetable, and form depend on applicable law. That mechanism is illustrated by a compliance analyst assumes suspicious activity always must be reported to the same global office, not by the stated activity involving an AFC policy remains unchanged despite a regulator's new guidance on high-risk digital payments.

D:

When testing the contrasting pattern of an AFC policy remains unchanged despite a regulator's new guidance on high-risk…, remember that meetings alone do not establish delegated authority, quorum, escalation paths, or accountability. A case of a risk committee meets quarterly but has no formal mandate or named decision powers would support that classification; here the relevant evidence is an AFC policy remains unchanged despite a regulator's new guidance on high-risk digital payments.

E:

Oversight requires substantive decisions and monitoring of accepted or rejected exposures; the observed record here instead involves an AFC policy remains unchanged despite a regulator's new guidance on high-risk…. The prerequisite pattern differs: a board committee receives repeated high-risk onboarding exceptions without documented challenge or…. The question instead describes an AFC policy remains unchanged despite a regulator's new guidance on high-risk digital payments.

Certified Anti-Money Laundering Specialist (the 6th edition) (CAMS) Practice Tests