ACAMS CAMS (Certified Anti-Money Laundering Specialist (the 6th edition)) Practice Test 24

Question 230

Before a high-risk decision, the team documents this situation: A virtual-asset provider fails to exchange required originator and beneficiary information with another covered provider. What should it check to distinguish the likely explanations?

  1. Match payees to claims, insured assets, and settlement authorizations
  2. Join device, funding-source, and beneficiary identifiers across transfers
  3. Compare chip purchases, gaming activity, and redemption records
  4. Determine applicable Travel Rule scope and counterparty-provider status

Explanation

Correct Answer

D:

Jurisdiction, transfer type, and regulated intermediary relationships establish relevant obligations. Its value comes from checking the relevant parties and records implicated here; a motor-insurance intermediary sends claim payments to accounts not linked to insured… calls for different evidence.

Incorrect Answers

A:

Compared with the stated facts about a virtual-asset provider fails to exchange required originator and beneficiary…, documentation should establish the legitimate basis for each third-party payment. The inquiry is suited to a motor-insurance intermediary sends claim payments to accounts not linked to insured persons or…; the requested evidence must instead address a virtual-asset provider fails to exchange required originator and beneficiary information with….

B:

This is not the central mechanism when a virtual-asset provider fails to exchange required originator and beneficiary…; network reconstruction makes repeated internal balance transfers traceable. It might establish facts where a digital-wallet provider allows unverified subaccounts to transfer balances repeatedly between…, but those records would not test the observed pattern: a virtual-asset provider fails to exchange required originator and beneficiary information with….

C:

When testing the contrasting pattern of a virtual-asset provider fails to exchange required originator and beneficiary…, remember that gaming behavior distinguishes ordinary entertainment from exchange-only use. This would divert the fact-finding effort toward a casino patron exchanges large cash amounts for chips and redeems them shortly afterward without… without resolving the key question raised by a virtual-asset provider fails to exchange required originator and beneficiary information with….

Question 231

The following exception is referred to the investigative desk: A vendor's watchlist feed stops updating for four days while payment processing continues. What should analysts verify first?

  1. Check original publication dates, outcomes, and subsequent reporting
  2. Review alert precision, unresolved queues, and seeded-list recall
  3. Inspect article subject, credibility, recency, and customer identifiers
  4. Check feed ingestion logs, effective dates, and published list updates

Explanation

Correct Answer

D:

A timing audit identifies which changes failed to enter production. Its value comes from checking the relevant parties and records implicated here; a news-screening tool presents a decade-old allegation as breaking information about a… calls for different evidence.

Incorrect Answers

A:

A chronology determines relevance, reliability, and whether accusations were resolved; the observed record here instead involves a vendor's watchlist feed stops updating for four days while payment processing…. The inquiry is suited to a news-screening tool presents a decade-old allegation as breaking information about a current…; the requested evidence must instead address a vendor's watchlist feed stops updating for four days while payment processing continues.

B:

Against the reported situation in which a vendor's watchlist feed stops updating for four days while payment processing…, both detection effectiveness and analyst capacity matter when tuning sensitivity. It might establish facts where a fuzzy sanctions matcher produces overwhelming false hits and analysts cannot clear them within…, but those records would not test the observed pattern: a vendor's watchlist feed stops updating for four days while payment processing continues.

C:

The relevant alternative mechanism is different from a vendor's watchlist feed stops updating for four days while payment processing…: Human or validated automated resolution is needed before treating media as relevant. This would divert the fact-finding effort toward an automated KYC tool increases a customer's risk score on every adverse-media mention without… without resolving the key question raised by a vendor's watchlist feed stops updating for four days while payment processing continues.

Question 232

An investigator is instructed not to rely on labels alone: Two private banks exchange a customer's full personal file without verifying a recognized sharing permission. Which substantive check is needed?

  1. Map record categories, transfer purposes, and local data-protection rules
  2. Review product, customer, purpose, and available enhanced controls
  3. Confirm applicable legal permission, purpose limitation, and recipient controls
  4. Check the forum's legal authority, purpose, and disclosure safeguards

Explanation

Correct Answer

C:

A lawful basis and safeguards are necessary before identifiable records move between firms. The inquiry is proportionate to the particular uncertainty in two private banks exchange a customer's full personal file without verifying a recognized sharing…, rather than the separate problem of a bank centralizes all customer data in one country despite incompatible transfer….

Incorrect Answers

A:

The analysis identifies permitted processing and required safeguards; the observed record here instead involves two private banks exchange a customer's full personal file without verifying a…. It might establish facts where a bank centralizes all customer data in one country despite incompatible transfer restrictions in…, but those records would not test the observed pattern: two private banks exchange a customer's full personal file without verifying a recognized sharing….

B:

Against the reported situation in which two private banks exchange a customer's full personal file without verifying a…, the feasibility of mitigation should be documented before broad access decisions. This would divert the fact-finding effort toward an international bank rejects all payments from a high-risk country without assessing customer or… without resolving the key question raised by two private banks exchange a customer's full personal file without verifying a recognized sharing….

D:

Compared with the stated facts about two private banks exchange a customer's full personal file without verifying a…, valid sharing depends on scope, participant roles, and protections. That review would be useful if banks and investigators create a public-private forum but share raw customer data without a…, but it would not resolve the central uncertainty in two private banks exchange a customer's full personal file without verifying a recognized sharing….

Question 233

An investigator is instructed not to rely on labels alone: A board approves restricted correspondent banking but sales continues to onboard nested-payment intermediaries. Which substantive check is needed?

  1. Compare onboarded correspondent services with board-approved boundaries
  2. Review model design ownership and audit team responsibilities
  3. Map new corridor activity and customer segments to risk factors
  4. Compare branch decision criteria against approved enterprise standards

Explanation

Correct Answer

A:

The review pinpoints deals approved outside intended risk tolerances. The inquiry is proportionate to the particular uncertainty in a board approves restricted correspondent banking but sales continues to onboard nested-payment…, rather than the separate problem of internal audit designs the transaction monitoring rules it must later assess.

Incorrect Answers

B:

Against the reported situation in which a board approves restricted correspondent banking but sales continues to onboard…, the division of duties identifies self-review threats to independent assurance. It seeks evidence about internal audit designs the transaction monitoring rules it must later assess; the allegation under review instead involves a board approves restricted correspondent banking but sales continues to onboard nested-payment….

C:

The relevant alternative mechanism is different from a board approves restricted correspondent banking but sales continues to onboard…: The analysis identifies changed business conditions requiring fresh assessment. That review would be useful if a firm expands into a high-risk remittance corridor but leaves enterprise risk scores unchanged for…, but it would not resolve the central uncertainty in a board approves restricted correspondent banking but sales continues to onboard nested-payment….

D:

Compared with the stated facts about a board approves restricted correspondent banking but sales continues to onboard…, a consistent taxonomy is necessary for comparable customer treatment. The inquiry is suited to two branches define 'high-risk customer' differently despite a central group standard; the requested evidence must instead address a board approves restricted correspondent banking but sales continues to onboard nested-payment….

Question 234

A relationship review has surfaced this activity: A cross-border analytics team seeks risk insights without moving identifiable customer files between subsidiaries. Which information source would be most decisive for verification?

  1. Segment case queues by risk, age, and investigative outcome
  2. Evaluate permitted aggregation, pseudonymization, and local processing constraints
  3. Document data inputs, legal obligations, throughput, and vendor limitations
  4. Quantify unmonitored value, failure likelihood, and possible harm

Explanation

Correct Answer

B:

The legal and technical analysis determines what information can be exchanged. Its value comes from checking the relevant parties and records implicated here; an AML analytics unit reports record throughput but growing unresolved high-risk alerts… calls for different evidence.

Incorrect Answers

A:

This is not the central mechanism when a cross-border analytics team seeks risk insights without moving identifiable…; quality metrics must reveal exposure from delayed priority cases. It might establish facts where an AML analytics unit reports record throughput but growing unresolved high-risk alerts remain…, but those records would not test the observed pattern: a cross-border analytics team seeks risk insights without moving identifiable customer files….

C:

A requirements assessment makes tool choice measurable and relevant; the observed record here instead involves a cross-border analytics team seeks risk insights without moving identifiable…. It seeks evidence about a bank selects a screening vendor based on advertised accuracy without checking payment-system…; the allegation under review instead involves a cross-border analytics team seeks risk insights without moving identifiable customer files….

D:

Against the reported situation in which a cross-border analytics team seeks risk insights without moving identifiable…, a risk-based business case starts with exposure and achievable mitigation. That review would be useful if a bank invests in a complex AI tool while high-risk payment streams still bypass basic transaction…, but it would not resolve the central uncertainty in a cross-border analytics team seeks risk insights without moving identifiable customer files….

Question 235

A case owner must prepare a defensible decision after the following observation: A bank closes an account under investigation without considering an authorized law-enforcement request to keep it open. Which examination best resolves the key uncertainty?

  1. Compare customer occupation, account history, and payment counterparties
  2. Trace fraud referrals to account relationships and AML case updates
  3. Check changes in public appointments and ongoing customer records
  4. Review trust deeds, voting powers, and natural-person beneficiaries
  5. Review agency correspondence, exit rationale, and legal restrictions

Explanation

Correct Answer

E:

The institution must establish whether it has a binding or lawful basis to preserve the relationship. For the supported action of review agency correspondence, exit rationale, and legal restrictions in this verification review involving a bank closes an account under investigation without considering an authorized law-enforcement…, its value comes from checking the relevant parties and records implicated here; a customer profile lists salary income but transactions show unusually large commercial… calls for different evidence.

Incorrect Answers

A:

The relevant alternative mechanism is different from a bank closes an account under investigation without considering an authorized…: The discrepancy determines whether refreshed CDD or investigation is required. This would divert the fact-finding effort toward a customer profile lists salary income but transactions show unusually large commercial receipts without resolving the key question raised by a bank closes an account under investigation without considering an authorized law-enforcement….

B:

Compared with the stated facts about a bank closes an account under investigation without considering an authorized…, a linked customer view establishes whether relevant signals reached appropriate teams. It seeks evidence about a fraud team sees mule-account patterns that the AML team never incorporates into customer risk…; the allegation under review instead involves a bank closes an account under investigation without considering an authorized law-enforcement….

C:

This is not the central mechanism when a bank closes an account under investigation without considering an authorized…; event evidence determines whether the relationship gained new exposure. That review would be useful if a bank screens PEPs only during initial account opening, but it would not resolve the central uncertainty in a bank closes an account under investigation without considering an authorized law-enforcement….

D:

When testing the contrasting pattern of a bank closes an account under investigation without considering an authorized…, remember that substantive control information resolves who ultimately directs the group. The inquiry is suited to a complex group uses three layers of offshore holdings with trustee powers to redirect profits; the requested evidence must instead address a bank closes an account under investigation without considering an authorized law-enforcement….

Question 236

After receiving a referral that banks and investigators create a public-private forum but share raw customer data without a permitted legal basis., what inquiry should the AFC team prioritize to substantiate the issue?

  1. Check EU legal acts, entry-into-force provisions, and national implementation schedules
  2. Confirm applicable legal permission, purpose limitation, and recipient controls
  3. Identify shareable behavioral indicators and legal constraints
  4. Check the forum's legal authority, purpose, and disclosure safeguards

Explanation

Correct Answer

D:

Valid sharing depends on scope, participant roles, and protections. The proposed review can distinguish the competing explanations in this case without substituting the unrelated checks needed for an EU financial group assumes a policy written before the 2024 AML regulatory package will….

Incorrect Answers

A:

Compared with the stated facts about banks and investigators create a public-private forum but share raw customer data…, the timing and scope of obligations matter more than the publication date alone. This would divert the fact-finding effort toward an EU financial group assumes a policy written before the 2024 AML regulatory package will remain… without resolving the key question raised by banks and investigators create a public-private forum but share raw customer data without a….

B:

This is not the central mechanism when banks and investigators create a public-private forum but share raw customer data…; a lawful basis and safeguards are necessary before identifiable records move between firms. It seeks evidence about two private banks exchange a customer's full personal file without verifying a recognized sharing…; the allegation under review instead involves banks and investigators create a public-private forum but share raw customer data without a….

C:

When testing the contrasting pattern of banks and investigators create a public-private forum but share raw customer data…, remember that pattern-level information can improve detection while reducing unnecessary personal disclosure. That review would be useful if a banking consortium wants to share scam indicators but only discusses names instead of…, but it would not resolve the central uncertainty in banks and investigators create a public-private forum but share raw customer data without a….

Question 237

A relationship review has surfaced this activity: A procurement officer is offered consultancy fees tied to awarding a government infrastructure contract. Which information source would be most decisive for verification?

  1. Compare case dates with applicable filing triggers and deadlines
  2. Compare invoice prices with commodities, quantities, and market benchmarks
  3. Examine payroll, worker complaints, and business ownership links
  4. Review correspondent termination notices and control findings
  5. Inspect the consultancy scope, beneficial owner, and approval trail
  6. Compare pricing, cash patterns, and known predicate-crime intelligence

Explanation

Correct Answer

E:

The economic purpose and links to decision-makers help determine whether the fee masks an improper benefit. The inquiry is proportionate to the particular uncertainty in a procurement officer is offered consultancy fees tied to awarding a government infrastructure contract, rather than the separate problem of a suspicious-activity backlog grows until analysts miss required reporting deadlines.

Incorrect Answers

A:

This is not the central mechanism when a procurement officer is offered consultancy fees tied to awarding a government…; a timeline distinguishes late identification, delayed investigation, and reporting-process failures. The inquiry is suited to a suspicious-activity backlog grows until analysts miss required reporting deadlines; the requested evidence must instead address a procurement officer is offered consultancy fees tied to awarding a government infrastructure….

B:

When testing the contrasting pattern of a procurement officer is offered consultancy fees tied to awarding a government…, remember that a pricing reconciliation probes whether the declared trade economics support the value transferred. It might establish facts where a shell importer repeatedly overstates invoice values and sends the difference overseas through…, but those records would not test the observed pattern: a procurement officer is offered consultancy fees tied to awarding a government infrastructure….

C:

A coherent evidence trail distinguishes ordinary labor contracting from exploitation proceeds; the observed record here instead involves a procurement officer is offered consultancy fees tied to awarding a government…. This would divert the fact-finding effort toward an account receives payments from employers implicated in withholding migrant workers' wages and… without resolving the key question raised by a procurement officer is offered consultancy fees tied to awarding a government infrastructure….

D:

Against the reported situation in which a procurement officer is offered consultancy fees tied to awarding a government…, these documents connect relationship losses to identified AML deficiencies rather than ordinary pricing decisions. It seeks evidence about a bank loses correspondent relationships after repeated failures to remediate reported AML…; the allegation under review instead involves a procurement officer is offered consultancy fees tied to awarding a government infrastructure….

F:

Compared with the stated facts about a procurement officer is offered consultancy fees tied to awarding a government…, multiple indicators clarify whether unusual trading practices are connected to criminal financing. The inquiry is suited to an illicit trade network infiltrates local payment channels and distorts competition with…; the requested evidence must instead address a procurement officer is offered consultancy fees tied to awarding a government infrastructure….

Question 238

To establish whether a material financial-crime risk exists, the reviewer considers this situation: A bank appoints an AML officer but does not test policies or train relationship staff. What should be verified?

  1. Separate raw exposure factors from evidence of control performance
  2. Compare onboarded correspondent services with board-approved boundaries
  3. Map new corridor activity and customer segments to risk factors
  4. Inspect training completion, audit plans, and control operation records
  5. Trace regulatory correspondence and escalation distribution lists
  6. Review model design ownership and audit team responsibilities

Explanation

Correct Answer

D:

Multiple evidence types distinguish an implemented program from a nominal appointment. The proposed review can distinguish the competing explanations in this case without substituting the unrelated checks needed for a bank calculates inherent country risk after deducting the effectiveness of its screening….

Incorrect Answers

A:

Against the reported situation in which a bank appoints an AML officer but does not test policies or train relationship staff, the calculation must make visible what risk exists and what safeguards reduce it. This would divert the fact-finding effort toward a bank calculates inherent country risk after deducting the effectiveness of its screening controls without resolving the key question raised by a bank appoints an AML officer but does not test policies or train relationship staff.

B:

The relevant alternative mechanism is different from a bank appoints an AML officer but does not test policies or train relationship staff: The review pinpoints deals approved outside intended risk tolerances. It seeks evidence about a board approves restricted correspondent banking but sales continues to onboard nested-payment…; the allegation under review instead involves a bank appoints an AML officer but does not test policies or train relationship staff.

C:

Compared with the stated facts about a bank appoints an AML officer but does not test policies or train relationship staff, the analysis identifies changed business conditions requiring fresh assessment. That review would be useful if a firm expands into a high-risk remittance corridor but leaves enterprise risk scores unchanged for…, but it would not resolve the central uncertainty in a bank appoints an AML officer but does not test policies or train relationship staff.

E:

When testing the contrasting pattern of a bank appoints an AML officer but does not test policies or train relationship staff, remember that the evidence shows whether material reporting matters reached responsible AFC leadership. It might establish facts where a bank's reporting officer is excluded from material regulatory communication about suspicious…, but those records would not test the observed pattern: a bank appoints an AML officer but does not test policies or train relationship staff.

F:

The division of duties identifies self-review threats to independent assurance; the observed record here instead involves a bank appoints an AML officer but does not test policies or train relationship staff. This would divert the fact-finding effort toward internal audit designs the transaction monitoring rules it must later assess without resolving the key question raised by a bank appoints an AML officer but does not test policies or train relationship staff.

Question 239

The following exception is referred to the investigative desk: An institution rates all foreign transactions high-risk without considering destination, customer, or purpose. What should analysts verify first?

  1. Check alert ownership, override permissions, and review logs
  2. Compare the statement with thresholds, prohibited activities, and exceptions
  3. Inspect sample outcomes, testing findings, staffing, and data coverage
  4. Segment transactions by corridor, beneficiary, purpose, and sector
  5. Compare branch decision criteria against approved enterprise standards
  6. Map new corridor activity and customer segments to risk factors

Explanation

Correct Answer

D:

Meaningful differentiation separates higher-exposure flows from routine legitimate activity. For the supported action of segment transactions by corridor, beneficiary, purpose, and sector in this verification review involving an institution rates all foreign transactions high-risk without considering destination,…, its value comes from checking the relevant parties and records implicated here; a branch sales manager closes alerts that implicate the manager's own high-value clients calls for different evidence.

Incorrect Answers

A:

These records establish whether commercial interests bypassed a second-line decision; the observed record here instead involves an institution rates all foreign transactions high-risk without considering…. The inquiry is suited to a branch sales manager closes alerts that implicate the manager's own high-value clients; the requested evidence must instead address an institution rates all foreign transactions high-risk without considering destination, customer,….

B:

Against the reported situation in which an institution rates all foreign transactions high-risk without considering…, operational criteria show whether employees can apply the board's intended boundaries. It might establish facts where a bank's risk appetite says 'zero financial crime' but gives no measurable boundaries for high-risk…, but those records would not test the observed pattern: an institution rates all foreign transactions high-risk without considering destination, customer,….

C:

The relevant alternative mechanism is different from an institution rates all foreign transactions high-risk without considering…: Operational evidence gives a defensible basis for measuring risk reduction. This would divert the fact-finding effort toward a bank uses the number of written AML policies as proof that residual risk is low without resolving the key question raised by an institution rates all foreign transactions high-risk without considering destination, customer,….

E:

This is not the central mechanism when an institution rates all foreign transactions high-risk without considering…; a consistent taxonomy is necessary for comparable customer treatment. That review would be useful if two branches define 'high-risk customer' differently despite a central group standard, but it would not resolve the central uncertainty in an institution rates all foreign transactions high-risk without considering destination, customer,….

F:

When testing the contrasting pattern of an institution rates all foreign transactions high-risk without considering…, remember that the analysis identifies changed business conditions requiring fresh assessment. The inquiry is suited to a firm expands into a high-risk remittance corridor but leaves enterprise risk scores unchanged for…; the requested evidence must instead address an institution rates all foreign transactions high-risk without considering destination, customer,….

Question 240

After receiving a referral that tellers attend generic AML training but cannot identify an emerging local romance-scam mule pattern., what inquiry should the AFC team prioritize to substantiate the issue?

  1. Map RACI responsibilities to control activities and process interfaces
  2. Review customer correspondence, missing evidence, and approval exceptions
  3. Review organizational reporting, remuneration, and override rights
  4. Review teller case referrals, typology coverage, and knowledge gaps
  5. Match legal retention periods and holds to the data lifecycle configuration

Explanation

Correct Answer

D:

Job-based evidence shows what practical detection skills are missing. The proposed review can distinguish the competing explanations in this case without substituting the unrelated checks needed for a financial crime team has investigators but no ownership of data quality, training, or….

Incorrect Answers

A:

Compared with the stated facts about tellers attend generic AML training but cannot identify an emerging local…, the assessment identifies unowned tasks and overlapping decision rights. This would divert the fact-finding effort toward a financial crime team has investigators but no ownership of data quality, training, or sanctions… without resolving the key question raised by tellers attend generic AML training but cannot identify an emerging local romance-scam mule pattern.

B:

This is not the central mechanism when tellers attend generic AML training but cannot identify an emerging local…; a timeline shows whether the front office bypassed required checks. It seeks evidence about a relationship manager promises a high-risk client instant onboarding despite missing beneficial…; the allegation under review instead involves tellers attend generic AML training but cannot identify an emerging local romance-scam mule pattern.

C:

When testing the contrasting pattern of tellers attend generic AML training but cannot identify an emerging local…, remember that the structure reveals whether commercial pressure can suppress compliance decisions. That review would be useful if a growing bank moves AFC analysts into a sales reporting chain without clear conflict safeguards, but it would not resolve the central uncertainty in tellers attend generic AML training but cannot identify an emerging local romance-scam mule pattern.

E:

Against the reported situation in which tellers attend generic AML training but cannot identify an emerging local…, the comparison identifies records at risk of premature destruction or unlawful retention. It might establish facts where a privacy team deletes records under an automated schedule without considering mandatory AML…, but those records would not test the observed pattern: tellers attend generic AML training but cannot identify an emerging local romance-scam mule pattern.

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