ACAMS CAMS (Certified Anti-Money Laundering Specialist (the 6th edition)) Practice Test 21

Question 200

A compliance team studies the following event: A group's sanctions policy covers customers but has no controls for vendors or trade payments. Which finding most closely matches the event?

  1. Enterprise risk assessment change-management failure
  2. Risk appetite not embedded in customer acceptance
  3. Incomplete program risk coverage across operations
  4. Third-line assurance independence weakness

Explanation

Correct Answer

C:

An effective AFC program should address relevant exposures beyond a single customer onboarding channel. Unlike a matter involving a firm expands into a high-risk remittance corridor but leaves enterprise risk scores…, this case turns on the pattern described in the referral.

Incorrect Answers

A:

When testing the contrasting pattern of a group's sanctions policy covers customers but has no controls for vendors or trade…, remember that material new geographies and products alter inherent exposure even between scheduled assessment cycles. This would change the core risk being assessed from a group's sanctions policy covers customers but has no controls for vendors or trade payments to a firm expands into a high-risk remittance corridor but leaves enterprise risk scores unchanged for….

B:

An approved restriction has little effect unless screening and approval workflows enforce it; the observed record here instead involves a group's sanctions policy covers customers but has no controls for vendors or trade…. The alternative requires the facts represented by a board approves restricted correspondent banking but sales continues to onboard nested-payment…; the principal facts instead show a group's sanctions policy covers customers but has no controls for vendors or trade payments.

D:

The relevant alternative mechanism is different from a group's sanctions policy covers customers but has no controls for vendors or trade…: Internal audit must be able to evaluate controls objectively rather than audit its own operational design. A case of internal audit designs the transaction monitoring rules it must later assess would support that classification; here the relevant evidence is a group's sanctions policy covers customers but has no controls for vendors or trade payments.

Question 201

After receiving a referral that internal audit designs the transaction monitoring rules it must later assess., what inquiry should the AFC team prioritize to substantiate the issue?

  1. Map new corridor activity and customer segments to risk factors
  2. Compare onboarded correspondent services with board-approved boundaries
  3. Review model design ownership and audit team responsibilities
  4. Map products, third parties, and payment flows to compliance controls

Explanation

Correct Answer

C:

The division of duties identifies self-review threats to independent assurance. Its value comes from checking the relevant parties and records implicated here; a firm expands into a high-risk remittance corridor but leaves enterprise risk scores… calls for different evidence.

Incorrect Answers

A:

Compared with the stated facts about internal audit designs the transaction monitoring rules it must later assess, the analysis identifies changed business conditions requiring fresh assessment. It seeks evidence about a firm expands into a high-risk remittance corridor but leaves enterprise risk scores unchanged for…; the allegation under review instead involves internal audit designs the transaction monitoring rules it must later assess.

B:

This is not the central mechanism when internal audit designs the transaction monitoring rules it must later assess; the review pinpoints deals approved outside intended risk tolerances. That review would be useful if a board approves restricted correspondent banking but sales continues to onboard nested-payment…, but it would not resolve the central uncertainty in internal audit designs the transaction monitoring rules it must later assess.

D:

An exposure inventory reveals which activity and legal regimes are outside current scope; the observed record here instead involves internal audit designs the transaction monitoring rules it must later assess. It might establish facts where a group's sanctions policy covers customers but has no controls for vendors or trade payments, but those records would not test the observed pattern: internal audit designs the transaction monitoring rules it must later assess.

Question 202

An investigator has to check this lead: A bank calculates inherent country risk after deducting the effectiveness of its screening controls. What evidence-gathering step would most directly test the concern?

  1. Separate raw exposure factors from evidence of control performance
  2. Check alert ownership, override permissions, and review logs
  3. Compare the statement with thresholds, prohibited activities, and exceptions
  4. Review model design ownership and audit team responsibilities

Explanation

Correct Answer

A:

The calculation must make visible what risk exists and what safeguards reduce it. The information sought bears directly on the reported facts, whereas a branch sales manager closes alerts that implicate the manager's own high-value clients would need a separate inquiry.

Incorrect Answers

B:

Compared with the stated facts about a bank calculates inherent country risk after deducting the effectiveness of its…, these records establish whether commercial interests bypassed a second-line decision. That review would be useful if a branch sales manager closes alerts that implicate the manager's own high-value clients, but it would not resolve the central uncertainty in a bank calculates inherent country risk after deducting the effectiveness of its screening controls.

C:

This is not the central mechanism when a bank calculates inherent country risk after deducting the effectiveness of its…; operational criteria show whether employees can apply the board's intended boundaries. The inquiry is suited to a bank's risk appetite says 'zero financial crime' but gives no measurable boundaries for high-risk…; the requested evidence must instead address a bank calculates inherent country risk after deducting the effectiveness of its screening controls.

D:

When testing the contrasting pattern of a bank calculates inherent country risk after deducting the effectiveness of its…, remember that the division of duties identifies self-review threats to independent assurance. It might establish facts where internal audit designs the transaction monitoring rules it must later assess, but those records would not test the observed pattern: a bank calculates inherent country risk after deducting the effectiveness of its screening controls.

Question 203

An investigator has to check this lead: A US firm assumes every person on an OFAC sanctions list can be screened by exact spelling alone. What evidence-gathering step would most directly test the concern?

  1. Check the forum's legal authority, purpose, and disclosure safeguards
  2. Map entity, currency, participant, and transaction nexus to relevant regimes
  3. Review designation details and relevant OFAC ownership guidance
  4. Review product, customer, purpose, and available enhanced controls

Explanation

Correct Answer

C:

The firm's legal analysis must determine actual blocked property and prohibited dealings. The inquiry is proportionate to the particular uncertainty in a US firm assumes every person on an OFAC sanctions list can be screened by exact spelling alone, rather than the separate problem of banks and investigators create a public-private forum but share raw customer data without a….

Incorrect Answers

A:

The relevant alternative mechanism is different from a US firm assumes every person on an OFAC sanctions list can be screened by exact…: Valid sharing depends on scope, participant roles, and protections. It might establish facts where banks and investigators create a public-private forum but share raw customer data without a…, but those records would not test the observed pattern: a US firm assumes every person on an OFAC sanctions list can be screened by exact spelling alone.

B:

Compared with the stated facts about a US firm assumes every person on an OFAC sanctions list can be screened by exact…, a defensible applicability assessment precedes decisions about blocking or rejection. This would divert the fact-finding effort toward a regional payments company deploys one global sanctions rule without checking local territorial… without resolving the key question raised by a US firm assumes every person on an OFAC sanctions list can be screened by exact spelling alone.

D:

When testing the contrasting pattern of a US firm assumes every person on an OFAC sanctions list can be screened by exact…, remember that the feasibility of mitigation should be documented before broad access decisions. That review would be useful if an international bank rejects all payments from a high-risk country without assessing customer or…, but it would not resolve the central uncertainty in a US firm assumes every person on an OFAC sanctions list can be screened by exact spelling alone.

Question 204

A case owner must prepare a defensible decision after the following observation: A precious-metals dealer receives repeated third-party deposits without links to purchased bullion. Which examination best resolves the key uncertainty?

  1. Verify asset ownership, acquisition history, and independent valuations
  2. Cross-check bills of lading, invoices, and route declarations
  3. Map family ties, contract payments, and beneficial interests
  4. Match depositors to buyers, invoices, and delivery receipts

Explanation

Correct Answer

D:

The absence of an identifiable buyer or actual bullion movement tests the trade rationale. The inquiry is proportionate to the particular uncertainty in a precious-metals dealer receives repeated third-party deposits without links to purchased bullion, rather than the separate problem of a private-banking client pledges opaque offshore holdings as collateral for unusually large….

Incorrect Answers

A:

The relevant alternative mechanism is different from a precious-metals dealer receives repeated third-party deposits without links to…: Evidence of how the wealth was accumulated differs from tracing a single repayment source. It seeks evidence about a private-banking client pledges opaque offshore holdings as collateral for unusually large credit…; the allegation under review instead involves a precious-metals dealer receives repeated third-party deposits without links to purchased bullion.

B:

Compared with the stated facts about a precious-metals dealer receives repeated third-party deposits without links to…, underlying documents should describe the same shipment and legitimate commercial rationale. That review would be useful if a trading company requests a letter of credit with documents inconsistent on port, cargo, and…, but it would not resolve the central uncertainty in a precious-metals dealer receives repeated third-party deposits without links to purchased bullion.

C:

This is not the central mechanism when a precious-metals dealer receives repeated third-party deposits without links to…; relationship evidence determines whether the official's authority benefits connected entities. The inquiry is suited to a client's brother becomes a senior procurement official and a related company receives government…; the requested evidence must instead address a precious-metals dealer receives repeated third-party deposits without links to purchased bullion.

Question 205

After receiving a referral that a digital-wallet provider allows unverified subaccounts to transfer balances repeatedly between devices., what inquiry should the AFC team prioritize to substantiate the issue?

  1. Confirm debtor existence, delivery, and underlying receivable validity
  2. Reconcile investors, funding accounts, and ultimate share recipients
  3. Verify premium payer, source of funds, and surrender beneficiary
  4. Join device, funding-source, and beneficiary identifiers across transfers

Explanation

Correct Answer

D:

Network reconstruction makes repeated internal balance transfers traceable. For the supported action of join device, funding-source, and beneficiary identifiers across transfers in this verification review involving a digital-wallet provider allows unverified subaccounts to transfer balances repeatedly…, the proposed review can distinguish the competing explanations in this case without substituting the unrelated checks needed for a factoring company finances invoices issued to counterparties with no verified trading….

Incorrect Answers

A:

Compared with the stated facts about a digital-wallet provider allows unverified subaccounts to transfer balances…, independent evidence of the commercial obligation distinguishes genuine financing from fabricated paper. This would divert the fact-finding effort toward a factoring company finances invoices issued to counterparties with no verified trading history without resolving the key question raised by a digital-wallet provider allows unverified subaccounts to transfer balances repeatedly between….

B:

This is not the central mechanism when a digital-wallet provider allows unverified subaccounts to transfer balances…; a complete audit trail can reveal concealed allocation beneficiaries. It seeks evidence about a securities intermediary receives funding through unrelated customer accounts before a bulk share…; the allegation under review instead involves a digital-wallet provider allows unverified subaccounts to transfer balances repeatedly between….

C:

When testing the contrasting pattern of a digital-wallet provider allows unverified subaccounts to transfer balances…, remember that tracing both entry and exit reveals whether the policy is being used as a value-transfer vehicle. That review would be useful if a customer buys a large life policy using a third party and requests early surrender despite steep…, but it would not resolve the central uncertainty in a digital-wallet provider allows unverified subaccounts to transfer balances repeatedly between….

Question 206

A relationship review has surfaced this activity: A compliance officer assumes a FATF public-listing announcement requires identical account termination everywhere. Which information source would be most decisive for verification?

  1. Check the precise FATF statement and domestic supervisory measures
  2. Identify the requesting authority, legal basis, and scope of records
  3. Check the resolution and the local implementing regulations
  4. Review national reporting legislation and FIU submission guidance

Explanation

Correct Answer

A:

The text distinguishes increased monitoring from calls for countermeasures and local legal effects. This evidence request tests the disputed part of a compliance officer assumes a FATF public-listing announcement requires identical account termination…; the other inquiry would be better suited to a bank treats a regulatory examination request as a criminal search warrant.

Incorrect Answers

B:

When testing the contrasting pattern of a compliance officer assumes a FATF public-listing announcement requires identical…, remember that the precise powers and confidentiality duties govern the institution's response. It might establish facts where a bank treats a regulatory examination request as a criminal search warrant, but those records would not test the observed pattern: a compliance officer assumes a FATF public-listing announcement requires identical account….

C:

Legal applicability depends on jurisdiction, listed persons, exemptions, and operative prohibitions; the observed record here instead involves a compliance officer assumes a FATF public-listing announcement requires identical…. This would divert the fact-finding effort toward a payments team assumes every UN Security Council sanctions resolution becomes locally enforceable… without resolving the key question raised by a compliance officer assumes a FATF public-listing announcement requires identical account….

D:

Against the reported situation in which a compliance officer assumes a FATF public-listing announcement requires identical…, the legal trigger and permitted communication process establish institutional responsibilities. It seeks evidence about a bank asks its financial intelligence unit to approve every suspicious-activity decision in advance; the allegation under review instead involves a compliance officer assumes a FATF public-listing announcement requires identical account….

Question 207

To establish whether a material financial-crime risk exists, the reviewer considers this situation: A bookkeeping firm pools client receipts in its own account and remits them without customer-level detail. What should be verified?

  1. Reconcile escrow instructions, counterparties, and contractual purpose
  2. Compare IMO identifiers, ownership, AIS gaps, and port-call records
  3. Trace instructions, underlying client identity, and payment origin
  4. Obtain underlying client ledgers and segregated payment records

Explanation

Correct Answer

D:

Records linking each receipt and transfer to the real client restore traceability. The inquiry is proportionate to the particular uncertainty in a bookkeeping firm pools client receipts in its own account and remits them without customer-level detail, rather than the separate problem of a notary receives large third-party escrow deposits with no connection to the declared….

Incorrect Answers

A:

Against the reported situation in which a bookkeeping firm pools client receipts in its own account and remits them without…, a clear legal transaction should explain each payer, payee, and amount. It seeks evidence about a notary receives large third-party escrow deposits with no connection to the declared asset…; the allegation under review instead involves a bookkeeping firm pools client receipts in its own account and remits them without customer-level….

B:

The relevant alternative mechanism is different from a bookkeeping firm pools client receipts in its own account and remits them without…: Persistent vessel identity and movement evidence can expose misleading trade documentation. That review would be useful if a shipping broker uses frequent last-minute vessel name and flag changes during sanctioned-region…, but it would not resolve the central uncertainty in a bookkeeping firm pools client receipts in its own account and remits them without customer-level….

C:

Compared with the stated facts about a bookkeeping firm pools client receipts in its own account and remits them without…, the lawyer's account name does not by itself establish who purchased the asset. The inquiry is suited to an overseas investor uses a lawyer's client account to settle a property purchase without naming…; the requested evidence must instead address a bookkeeping firm pools client receipts in its own account and remits them without customer-level….

Question 208

Before a high-risk decision, the team documents this situation: A securities intermediary receives funding through unrelated customer accounts before a bulk share allocation. What should it check to distinguish the likely explanations?

  1. Aggregate transfers by sender, beneficiary, device, and agent location
  2. Identify controlling persons across entities and premium funding accounts
  3. Validate order fulfillment, customer relationships, and payout changes
  4. Reconcile investors, funding accounts, and ultimate share recipients

Explanation

Correct Answer

D:

A complete audit trail can reveal concealed allocation beneficiaries. The information sought bears directly on the reported facts, whereas a money remitter's agent repeatedly breaks large customer transfers into many nearby… would need a separate inquiry.

Incorrect Answers

A:

Compared with the stated facts about a securities intermediary receives funding through unrelated customer accounts before…, cross-agent links can expose deliberate fragmentation of a single funding stream. That review would be useful if a money remitter's agent repeatedly breaks large customer transfers into many nearby transactions, but it would not resolve the central uncertainty in a securities intermediary receives funding through unrelated customer accounts before a bulk share….

B:

This is not the central mechanism when a securities intermediary receives funding through unrelated customer accounts before…; ownership mapping exposes aggregation that individual policy reviews miss. The inquiry is suited to an insurance broker proposes many single-premium policies purchased by entities with the same…; the requested evidence must instead address a securities intermediary receives funding through unrelated customer accounts before a bulk share….

C:

When testing the contrasting pattern of a securities intermediary receives funding through unrelated customer accounts before…, remember that delivery records and linked accounts help identify sham marketplace transactions. It might establish facts where a marketplace pays seller proceeds to newly added bank accounts after bursts of fabricated purchase…, but those records would not test the observed pattern: a securities intermediary receives funding through unrelated customer accounts before a bulk share….

Question 209

After receiving a referral that a buyer purchases apartments through a chain of companies and pays above market value with unexplained funds., what inquiry should the AFC team prioritize to substantiate the issue?

  1. Identify ultimate owners and independently assess valuation and funding
  2. Review deliverables, engagement terms, and beneficial ownership
  3. Obtain controller identity and purpose of the corporate structure
  4. Reconcile escrow instructions, counterparties, and contractual purpose

Explanation

Correct Answer

A:

Knowing who controls the buyer and how price was funded addresses both concealment and value transfer. For the supported action of identify ultimate owners and independently assess valuation and funding in this verification review involving a buyer purchases apartments through a chain of companies and pays above market value with…, the information sought bears directly on the reported facts, whereas a professional service provider invoices an offshore entity for vague advisory work… would need a separate inquiry.

Incorrect Answers

B:

This is not the central mechanism when a buyer purchases apartments through a chain of companies and pays above market value…; a legitimate advisory relationship should produce supportable commercial output and known clients. That review would be useful if a professional service provider invoices an offshore entity for vague advisory work followed by…, but it would not resolve the central uncertainty in a buyer purchases apartments through a chain of companies and pays above market value with….

C:

When testing the contrasting pattern of a buyer purchases apartments through a chain of companies and pays above market value…, remember that client privilege assertions do not automatically remove applicable identification obligations. The inquiry is suited to a legal adviser forms companies for a client while refusing to disclose the person providing…; the requested evidence must instead address a buyer purchases apartments through a chain of companies and pays above market value with….

D:

A clear legal transaction should explain each payer, payee, and amount; the observed record here instead involves a buyer purchases apartments through a chain of companies and pays above market value…. It might establish facts where a notary receives large third-party escrow deposits with no connection to the declared asset…, but those records would not test the observed pattern: a buyer purchases apartments through a chain of companies and pays above market value with….

Question 210

A case owner must prepare a defensible decision after the following observation: A tax adviser creates repeated artificial loss-making entities whose transfers fund personal luxury purchases. Which examination best resolves the key uncertainty?

  1. Inspect underlying invoices, company substance, and asset beneficiaries
  2. Obtain controller identity and purpose of the corporate structure
  3. Trace instructions, underlying client identity, and payment origin
  4. Confirm provenance, independent valuation, and both parties' identities

Explanation

Correct Answer

A:

Substantive trading evidence helps distinguish genuine tax planning from fictitious offsets. For the supported action of inspect underlying invoices, company substance, and asset beneficiaries in this verification review involving a tax adviser creates repeated artificial loss-making entities whose transfers fund personal…, the proposed review can distinguish the competing explanations in this case without substituting the unrelated checks needed for a legal adviser forms companies for a client while refusing to disclose the person….

Incorrect Answers

B:

Compared with the stated facts about a tax adviser creates repeated artificial loss-making entities whose transfers fund…, client privilege assertions do not automatically remove applicable identification obligations. This would divert the fact-finding effort toward a legal adviser forms companies for a client while refusing to disclose the person providing… without resolving the key question raised by a tax adviser creates repeated artificial loss-making entities whose transfers fund personal luxury….

C:

This is not the central mechanism when a tax adviser creates repeated artificial loss-making entities whose transfers fund…; the lawyer's account name does not by itself establish who purchased the asset. It seeks evidence about an overseas investor uses a lawyer's client account to settle a property purchase without naming…; the allegation under review instead involves a tax adviser creates repeated artificial loss-making entities whose transfers fund personal luxury….

D:

When testing the contrasting pattern of a tax adviser creates repeated artificial loss-making entities whose transfers fund…, remember that understanding who funds and receives the object is necessary to assess the sale. That review would be useful if an art dealer receives payment for a sculpture from a different offshore buyer than the invoice…, but it would not resolve the central uncertainty in a tax adviser creates repeated artificial loss-making entities whose transfers fund personal luxury….

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