ACAMS CAMS (Certified Anti-Money Laundering Specialist (the 6th edition)) Practice Test 33

Question 320

Before a high-risk decision, the team documents this situation: A bank buys adverse-media data but cannot explain which persons its records actually match. What should it check to distinguish the likely explanations?

  1. Compare customer identifiers, update times, and source-of-truth rules
  2. Compare unique identifiers, source dates, and actual subject context
  3. Check issuing-source validation, document security features, and fraud markers
  4. Examine liveness telemetry, identity documents, and capture-device signals

Explanation

Correct Answer

B:

Resolution identifies whether a media record belongs to the customer and remains relevant. Its value comes from checking the relevant parties and records implicated here; a bank independently records KYC changes in three tools but does not synchronize customer… calls for different evidence.

Incorrect Answers

A:

Compared with the stated facts about a bank buys adverse-media data but cannot explain which persons its records actually…, reconciliation reveals which system has reliable authoritative customer data. It might establish facts where a bank independently records KYC changes in three tools but does not synchronize customer risk…, but those records would not test the observed pattern: a bank buys adverse-media data but cannot explain which persons its records actually match.

C:

When testing the contrasting pattern of a bank buys adverse-media data but cannot explain which persons its records actually…, remember that independent authentication adds value beyond extracting characters from a photograph. It seeks evidence about an e-KYC provider verifies an image of an identity document but never validates its issuer or…; the allegation under review instead involves a bank buys adverse-media data but cannot explain which persons its records actually match.

D:

These inputs help distinguish genuine live enrollment from a spoofed presentation; the observed record here instead involves a bank buys adverse-media data but cannot explain which persons its records actually…. That review would be useful if a remote account applicant uses a high-quality printed face photograph to defeat a simple selfie…, but it would not resolve the central uncertainty in a bank buys adverse-media data but cannot explain which persons its records actually match.

Question 321

To establish whether a material financial-crime risk exists, the reviewer considers this situation: An online betting account is funded by several payment cards and withdraws winnings to a different name. What should be verified?

  1. Link cards, account holder, wagering history, and withdrawal beneficiaries
  2. Join device, funding-source, and beneficiary identifiers across transfers
  3. Examine governance keys, fee flows, custody, and operational decision rights
  4. Determine applicable Travel Rule scope and counterparty-provider status
  5. Use blockchain tracing to examine upstream exposure and exchange counterparties

Explanation

Correct Answer

A:

Payment and betting evidence together reveal inconsistent ownership or disguised transfers. The inquiry is proportionate to the particular uncertainty in an online betting account is funded by several payment cards and withdraws winnings to a different name, rather than the separate problem of a digital-wallet provider allows unverified subaccounts to transfer balances repeatedly….

Incorrect Answers

B:

The relevant alternative mechanism is different from an online betting account is funded by several payment cards and withdraws winnings…: Network reconstruction makes repeated internal balance transfers traceable. It seeks evidence about a digital-wallet provider allows unverified subaccounts to transfer balances repeatedly between…; the allegation under review instead involves an online betting account is funded by several payment cards and withdraws winnings to a different….

C:

Compared with the stated facts about an online betting account is funded by several payment cards and withdraws winnings…, control and service functions are more informative than labels about decentralization. That review would be useful if a token project describes its protocol as decentralized but a company retains privileged controls…, but it would not resolve the central uncertainty in an online betting account is funded by several payment cards and withdraws winnings to a different….

D:

This is not the central mechanism when an online betting account is funded by several payment cards and withdraws winnings…; jurisdiction, transfer type, and regulated intermediary relationships establish relevant obligations. The inquiry is suited to a virtual-asset provider fails to exchange required originator and beneficiary information with…; the requested evidence must instead address an online betting account is funded by several payment cards and withdraws winnings to a different….

E:

When testing the contrasting pattern of an online betting account is funded by several payment cards and withdraws winnings…, remember that wallet flow analysis helps place the transfer in context rather than treating a risk score as proof. It might establish facts where a virtual-asset exchange receives coins from a mixer shortly before conversion into fiat and…, but those records would not test the observed pattern: an online betting account is funded by several payment cards and withdraws winnings to a different….

Question 322

An institution needs corroboration of a suspected weakness: A US branch relies on European transaction reporting rules to set its US suspicious-activity filing triggers. Which targeted evidence would best clarify the facts?

  1. Verify the subsidiary's competent FIU and applicable reporting duties
  2. Identify US BSA/FinCEN obligations for the relevant activity
  3. Review product, customer, purpose, and available enhanced controls
  4. Compare governing AML retention law with data-protection requirements

Explanation

Correct Answer

B:

The responsible regulator and statutory trigger determine when and how to file. The proposed review can distinguish the competing explanations in this case without substituting the unrelated checks needed for a local compliance team automatically applies US suspicious-activity deadlines to an EU….

Incorrect Answers

A:

Against the reported situation in which a US branch relies on European transaction reporting rules to set its US…, the local legal entity and facts determine who receives information and when. It seeks evidence about a local compliance team automatically applies US suspicious-activity deadlines to an EU subsidiary; the allegation under review instead involves a US branch relies on European transaction reporting rules to set its US suspicious-activity filing….

C:

Compared with the stated facts about a US branch relies on European transaction reporting rules to set its US…, the feasibility of mitigation should be documented before broad access decisions. The inquiry is suited to an international bank rejects all payments from a high-risk country without assessing customer or…; the requested evidence must instead address a US branch relies on European transaction reporting rules to set its US suspicious-activity filing….

D:

This is not the central mechanism when a US branch relies on European transaction reporting rules to set its US…; legal analysis determines which retention and deletion rules apply to each category. It might establish facts where a cross-border institution applies domestic data retention periods to client records governed by a…, but those records would not test the observed pattern: a US branch relies on European transaction reporting rules to set its US suspicious-activity filing….

Question 323

The following exception is referred to the investigative desk: An MSB withdraws from an entire remittance corridor after isolated suspicious cases without analyzing the wider portfolio. What should analysts verify first?

  1. Compare risk-acceptance conditions with monitoring and account activity
  2. Review the exact statement, case status, and local confidentiality rules
  3. Assess what ordinary documentation is needed and how to request it
  4. Review the escalation matrix, contractual obligations, and decision records
  5. Segment customer risks and assess feasible enhanced monitoring

Explanation

Correct Answer

E:

Evidence should identify whether risks are concentrated in particular users or patterns. This evidence request tests the disputed part of an MSB withdraws from an entire remittance corridor after isolated suspicious cases without analyzing…; the other inquiry would be better suited to a customer is retained despite repeated unresolved suspicious transactions because revenue….

Incorrect Answers

A:

The review shows whether the conditions attached to retention were met; the observed record here instead involves an MSB withdraws from an entire remittance corridor after isolated suspicious cases…. It seeks evidence about a customer is retained despite repeated unresolved suspicious transactions because revenue targets…; the allegation under review instead involves an MSB withdraws from an entire remittance corridor after isolated suspicious cases without….

B:

Against the reported situation in which an MSB withdraws from an entire remittance corridor after isolated suspicious cases…, the content of disclosure determines potential legal and investigative consequences. That review would be useful if a customer asks why a transfer is held; an analyst says it is because a suspicious-activity report…, but it would not resolve the central uncertainty in an MSB withdraws from an entire remittance corridor after isolated suspicious cases without….

C:

The relevant alternative mechanism is different from an MSB withdraws from an entire remittance corridor after isolated suspicious cases…: A neutral evidence request can support inquiry without unnecessary allegations. The inquiry is suited to an investigator requests business documents through a customer-facing team using an accusatory…; the requested evidence must instead address an MSB withdraws from an entire remittance corridor after isolated suspicious cases without….

D:

Compared with the stated facts about an MSB withdraws from an entire remittance corridor after isolated suspicious cases…, a clear authority trail shows who can terminate and on what basis. It might establish facts where a bank decides to exit a high-risk customer while two divisions disagree about who has approval…, but those records would not test the observed pattern: an MSB withdraws from an entire remittance corridor after isolated suspicious cases without….

Question 324

A relationship review has surfaced this activity: A privacy team deletes records under an automated schedule without considering mandatory AML retention holds. Which information source would be most decisive for verification?

  1. Match legal retention periods and holds to the data lifecycle configuration
  2. Compare adviser observations with customer profile and payment history
  3. Review customer correspondence, missing evidence, and approval exceptions
  4. Review organizational reporting, remuneration, and override rights

Explanation

Correct Answer

A:

The comparison identifies records at risk of premature destruction or unlawful retention. The information sought bears directly on the reported facts, whereas a wealth adviser notices unexpected offshore transfers but believes only the monitoring… would need a separate inquiry.

Incorrect Answers

B:

When testing the contrasting pattern of a privacy team deletes records under an automated schedule without considering…, remember that the relationship context may make otherwise routine transactions unusual. That review would be useful if a wealth adviser notices unexpected offshore transfers but believes only the monitoring system can…, but it would not resolve the central uncertainty in a privacy team deletes records under an automated schedule without considering mandatory AML….

C:

A timeline shows whether the front office bypassed required checks; the observed record here instead involves a privacy team deletes records under an automated schedule without considering…. The inquiry is suited to a relationship manager promises a high-risk client instant onboarding despite missing beneficial…; the requested evidence must instead address a privacy team deletes records under an automated schedule without considering mandatory AML….

D:

Against the reported situation in which a privacy team deletes records under an automated schedule without considering…, the structure reveals whether commercial pressure can suppress compliance decisions. It might establish facts where a growing bank moves AFC analysts into a sales reporting chain without clear conflict safeguards, but those records would not test the observed pattern: a privacy team deletes records under an automated schedule without considering mandatory AML….

Question 325

An investigator has to check this lead: An internal team equates a jurisdiction's technical compliance with effective AML outcomes. What evidence-gathering step would most directly test the concern?

  1. Review product classification and prohibited-activity language
  2. Compare identifiers, birth details, addresses, and applicable listing information
  3. Review national reporting legislation and FIU submission guidance
  4. Review mutual evaluation findings on effectiveness and immediate outcomes
  5. Confirm the body's legal mandate and the relevant published report

Explanation

Correct Answer

D:

FATF methodology assesses both conformity with standards and results in practice. For the supported action of review mutual evaluation findings on effectiveness and immediate outcomes in this verification review involving an internal team equates a jurisdiction's technical compliance with effective AML outcomes, the information sought bears directly on the reported facts, whereas a branch screens sanctioned party names but overlooks a UN embargo relating to a category… would need a separate inquiry.

Incorrect Answers

A:

The relevant alternative mechanism is different from an internal team equates a jurisdiction's technical compliance with effective AML…: A goods-based restriction needs more than an exact name match to assess applicability. That review would be useful if a branch screens sanctioned party names but overlooks a UN embargo relating to a category of…, but it would not resolve the central uncertainty in an internal team equates a jurisdiction's technical compliance with effective AML outcomes.

B:

Compared with the stated facts about an internal team equates a jurisdiction's technical compliance with effective AML…, a documented false-positive decision requires identity evidence rather than typographic assumptions. The inquiry is suited to a sanctions analyst releases a possible listed-person match because the customer name has different…; the requested evidence must instead address an internal team equates a jurisdiction's technical compliance with effective AML outcomes.

C:

This is not the central mechanism when an internal team equates a jurisdiction's technical compliance with effective AML…; the legal trigger and permitted communication process establish institutional responsibilities. It might establish facts where a bank asks its financial intelligence unit to approve every suspicious-activity decision in advance, but those records would not test the observed pattern: an internal team equates a jurisdiction's technical compliance with effective AML outcomes.

E:

Evidence of its role separates research credibility from legal authority; the observed record here instead involves an internal team equates a jurisdiction's technical compliance with effective AML…. It seeks evidence about a nonprofit training group claims authority to impose national AML penalties because it publishes…; the allegation under review instead involves an internal team equates a jurisdiction's technical compliance with effective AML outcomes.

Question 326

Before a high-risk decision, the team documents this situation: A bank uses the number of written AML policies as proof that residual risk is low. What should it check to distinguish the likely explanations?

  1. Review risk ratings, customer characteristics, and due diligence burdens
  2. Inspect documentation for detailed workflows, owners, and checkpoints
  3. Check alert ownership, override permissions, and review logs
  4. Inspect sample outcomes, testing findings, staffing, and data coverage

Explanation

Correct Answer

D:

Operational evidence gives a defensible basis for measuring risk reduction. This evidence request tests the disputed part of a bank uses the number of written AML policies as proof that residual risk is low; the other inquiry would be better suited to a small nonprofit receives the same level of documentation demands as a complex offshore….

Incorrect Answers

A:

Compared with the stated facts about a bank uses the number of written AML policies as proof that residual risk is low, the evidence shows whether safeguards differentiate actual exposure. It might establish facts where a small nonprofit receives the same level of documentation demands as a complex offshore corporate…, but those records would not test the observed pattern: a bank uses the number of written AML policies as proof that residual risk is low.

B:

This is not the central mechanism when a bank uses the number of written AML policies as proof that residual risk is low; missing operational instructions can explain inconsistent application of approved standards. This would divert the fact-finding effort toward a policy requires EDD for foreign PEPs but staff cannot find the corresponding review steps without resolving the key question raised by a bank uses the number of written AML policies as proof that residual risk is low.

C:

When testing the contrasting pattern of a bank uses the number of written AML policies as proof that residual risk is low, remember that these records establish whether commercial interests bypassed a second-line decision. It seeks evidence about a branch sales manager closes alerts that implicate the manager's own high-value clients; the allegation under review instead involves a bank uses the number of written AML policies as proof that residual risk is low.

Question 327

An institution needs corroboration of a suspected weakness: A remote account applicant uses a high-quality printed face photograph to defeat a simple selfie comparison. Which targeted evidence would best clarify the facts?

  1. Compare identity-failure reasons, risk segments, and onboarding abandonment
  2. Compare customer identifiers, update times, and source-of-truth rules
  3. Map onboarding, screening, monitoring, investigation, and exit workflows
  4. Examine liveness telemetry, identity documents, and capture-device signals
  5. Review fraud incidence, device risk, and biometric exception rates
  6. Compare unique identifiers, source dates, and actual subject context

Explanation

Correct Answer

D:

These inputs help distinguish genuine live enrollment from a spoofed presentation. Its value comes from checking the relevant parties and records implicated here; digital onboarding requests identical extensive checks from simple low-risk applicants and… calls for different evidence.

Incorrect Answers

A:

Against the reported situation in which a remote account applicant uses a high-quality printed face photograph to defeat a…, segmented data distinguishes genuine control needs from avoidable customer burden. The inquiry is suited to digital onboarding requests identical extensive checks from simple low-risk applicants and…; the requested evidence must instead address a remote account applicant uses a high-quality printed face photograph to defeat a simple selfie….

B:

The relevant alternative mechanism is different from a remote account applicant uses a high-quality printed face photograph to defeat a…: Reconciliation reveals which system has reliable authoritative customer data. It might establish facts where a bank independently records KYC changes in three tools but does not synchronize customer risk…, but those records would not test the observed pattern: a remote account applicant uses a high-quality printed face photograph to defeat a simple selfie….

C:

Compared with the stated facts about a remote account applicant uses a high-quality printed face photograph to defeat a…, a lifecycle map reveals missing controls rather than assuming one product covers all stages. This would divert the fact-finding effort toward a fintech buys a transaction-monitoring platform without any process for verifying customers at… without resolving the key question raised by a remote account applicant uses a high-quality printed face photograph to defeat a simple selfie….

E:

When testing the contrasting pattern of a remote account applicant uses a high-quality printed face photograph to defeat a…, remember that evidence determines where additional verification creates measurable value. That review would be useful if a payment app adds facial recognition to every minor account-profile change despite low observed…, but it would not resolve the central uncertainty in a remote account applicant uses a high-quality printed face photograph to defeat a simple selfie….

F:

Resolution identifies whether a media record belongs to the customer and remains relevant; the observed record here instead involves a remote account applicant uses a high-quality printed face photograph to defeat a…. The inquiry is suited to a bank buys adverse-media data but cannot explain which persons its records actually match; the requested evidence must instead address a remote account applicant uses a high-quality printed face photograph to defeat a simple selfie….

Question 328

A relationship review has surfaced this activity: A regional bank sees sudden cash deposits at several branches by couriers working for one merchant. Which information source would be most decisive for verification?

  1. Check end-user declarations, product specifications, and routing changes
  2. Verify the partner's governance and documented program beneficiaries
  3. Assess continuing influence, associates, and post-office commercial roles
  4. Consolidate branch deposits by merchant and common depositor identity

Explanation

Correct Answer

D:

Network-wide aggregation exposes behavior that individual branch limits would miss. This evidence request tests the disputed part of a regional bank sees sudden cash deposits at several branches by couriers working for one merchant; the other inquiry would be better suited to a licensed firearms wholesaler ships dual-use components to newly created intermediaries….

Incorrect Answers

A:

This is not the central mechanism when a regional bank sees sudden cash deposits at several branches by couriers working for…; technical product identity and final use help distinguish legitimate distribution from evasion. It might establish facts where a licensed firearms wholesaler ships dual-use components to newly created intermediaries with…, but those records would not test the observed pattern: a regional bank sees sudden cash deposits at several branches by couriers working for one merchant.

B:

When testing the contrasting pattern of a regional bank sees sudden cash deposits at several branches by couriers working for…, remember that the recipient's capacity and end-use evidence matter more than geographic assumptions alone. This would divert the fact-finding effort toward a relief organization routes grants to an unverified local partner in an active conflict area without resolving the key question raised by a regional bank sees sudden cash deposits at several branches by couriers working for one merchant.

C:

Risk depends on current influence and relationships, not a fixed assumption of permanent exposure; the observed record here instead involves a regional bank sees sudden cash deposits at several branches by couriers working for…. It seeks evidence about a former senior politician retains influence over a state-owned enterprise through close associates; the allegation under review instead involves a regional bank sees sudden cash deposits at several branches by couriers working for one merchant.

Question 329

Before a high-risk decision, the team documents this situation: An investigation platform copies unmasked sensitive customer records into a vendor's general-purpose AI training environment. What should it check to distinguish the likely explanations?

  1. Review dependency mapping, timeout behavior, and recovery obligations
  2. Segment case queues by risk, age, and investigative outcome
  3. Document data inputs, legal obligations, throughput, and vendor limitations
  4. Inspect vendor processing terms, data flows, retention, and access controls

Explanation

Correct Answer

D:

The review identifies where confidential information travels and who can use it. The inquiry is proportionate to the particular uncertainty in an investigation platform copies unmasked sensitive customer records into a vendor's general-purpose AI…, rather than the separate problem of a monitoring system change goes live with no fallback when its external API becomes….

Incorrect Answers

A:

Compared with the stated facts about an investigation platform copies unmasked sensitive customer records into a vendor's…, system behavior during failure determines whether payments proceed unscreened. It seeks evidence about a monitoring system change goes live with no fallback when its external API becomes unavailable; the allegation under review instead involves an investigation platform copies unmasked sensitive customer records into a vendor's….

B:

This is not the central mechanism when an investigation platform copies unmasked sensitive customer records into a vendor's…; quality metrics must reveal exposure from delayed priority cases. That review would be useful if an AML analytics unit reports record throughput but growing unresolved high-risk alerts remain…, but it would not resolve the central uncertainty in an investigation platform copies unmasked sensitive customer records into a vendor's….

C:

When testing the contrasting pattern of an investigation platform copies unmasked sensitive customer records into a vendor's…, remember that a requirements assessment makes tool choice measurable and relevant. The inquiry is suited to a bank selects a screening vendor based on advertised accuracy without checking payment-system…; the requested evidence must instead address an investigation platform copies unmasked sensitive customer records into a vendor's….

Question 330

Before a high-risk decision, the team documents this situation: An EU financial group assumes a policy written before the 2024 AML regulatory package will remain sufficient unchanged. What should it check to distinguish the likely explanations?

  1. Identify missing sectors and data contributions along the payment route
  2. Check the forum's legal authority, purpose, and disclosure safeguards
  3. Review product, customer, purpose, and available enhanced controls
  4. Check EU legal acts, entry-into-force provisions, and national implementation schedules
  5. Compare governing AML retention law with data-protection requirements

Explanation

Correct Answer

D:

The timing and scope of obligations matter more than the publication date alone. For the supported action of check eu legal acts, entry-into-force provisions, and national implementation schedules in this verification review involving an EU financial group assumes a policy written before the 2024 AML regulatory package will…, the information sought bears directly on the reported facts, whereas a bank's public-private partnership excludes smaller payment firms that experience the same… would need a separate inquiry.

Incorrect Answers

A:

Compared with the stated facts about an EU financial group assumes a policy written before the 2024 AML regulatory package…, a gap analysis reveals whether crucial intermediaries are absent. That review would be useful if a bank's public-private partnership excludes smaller payment firms that experience the same scam…, but it would not resolve the central uncertainty in an EU financial group assumes a policy written before the 2024 AML regulatory package will remain….

B:

This is not the central mechanism when an EU financial group assumes a policy written before the 2024 AML regulatory package…; valid sharing depends on scope, participant roles, and protections. The inquiry is suited to banks and investigators create a public-private forum but share raw customer data without a…; the requested evidence must instead address an EU financial group assumes a policy written before the 2024 AML regulatory package will remain….

C:

When testing the contrasting pattern of an EU financial group assumes a policy written before the 2024 AML regulatory package…, remember that the feasibility of mitigation should be documented before broad access decisions. It might establish facts where an international bank rejects all payments from a high-risk country without assessing customer or…, but those records would not test the observed pattern: an EU financial group assumes a policy written before the 2024 AML regulatory package will remain….

E:

Against the reported situation in which an EU financial group assumes a policy written before the 2024 AML regulatory package…, legal analysis determines which retention and deletion rules apply to each category. It seeks evidence about a cross-border institution applies domestic data retention periods to client records governed by a…; the allegation under review instead involves an EU financial group assumes a policy written before the 2024 AML regulatory package will remain….

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