ACAMS CAMS (Certified Anti-Money Laundering Specialist (the 6th edition)) Practice Test 39

Question 380

A case owner must prepare a defensible decision after the following observation: Several esports betting accounts trade bets against each other and cash out through the same device network. Which examination best resolves the key uncertainty?

  1. Trace redemption counterparties and funds entering bank accounts
  2. Analyze device fingerprints, opposing wagers, and account connections
  3. Examine governance keys, fee flows, custody, and operational decision rights
  4. Investigate address ownership and available counterparty risk signals

Explanation

Correct Answer

B:

Network evidence is needed to distinguish collusion from independent bets. For the supported action of analyze device fingerprints, opposing wagers, and account connections in this verification review involving several esports betting accounts trade bets against each other and cash out through the same…, the information sought bears directly on the reported facts, whereas a virtual-asset custodian processes large stablecoin redemptions through offshore issuers… would need a separate inquiry.

Incorrect Answers

A:

The relevant alternative mechanism is different from several esports betting accounts trade bets against each other and cash out through…: The off-chain settlement path is needed alongside blockchain history to understand beneficiaries. The inquiry is suited to a virtual-asset custodian processes large stablecoin redemptions through offshore issuers with weak…; the requested evidence must instead address several esports betting accounts trade bets against each other and cash out through the same device….

C:

This is not the central mechanism when several esports betting accounts trade bets against each other and cash out through…; control and service functions are more informative than labels about decentralization. This would divert the fact-finding effort toward a token project describes its protocol as decentralized but a company retains privileged controls… without resolving the key question raised by several esports betting accounts trade bets against each other and cash out through the same device….

D:

When testing the contrasting pattern of several esports betting accounts trade bets against each other and cash out through…, remember that on-chain behavior and customer explanations help assess the exposure without presuming all self-custody is illicit. It seeks evidence about a trading platform repeatedly sends virtual assets to an unhosted address controlled by an…; the allegation under review instead involves several esports betting accounts trade bets against each other and cash out through the same device….

Question 381

An unusual pattern requires validation: An investigator closes a case as not suspicious without recording why multiple cash transfers were consistent with the customer profile. Which records most directly address the stated exposure?

  1. Review supporting documents, transaction timeline, and closure reasoning
  2. Authenticate requester and identify whether 314(a) or 314(b) applies
  3. Compare risk-acceptance conditions with monitoring and account activity
  4. Preserve the staff statement and review related deposit activity
  5. Evaluate available identity methods and actual customer risk factors

Explanation

Correct Answer

A:

Documented evidence permits independent challenge of the investigator's judgment. Its value comes from checking the relevant parties and records implicated here; a bank treats a voluntary interbank information request as an automatic section 314(a)… calls for different evidence.

Incorrect Answers

B:

When testing the contrasting pattern of an investigator closes a case as not suspicious without recording why multiple cash…, remember that the distinction determines whether a compulsory search or permitted exchange is involved. The inquiry is suited to a bank treats a voluntary interbank information request as an automatic section 314(a) government…; the requested evidence must instead address an investigator closes a case as not suspicious without recording why multiple cash transfers were….

C:

The review shows whether the conditions attached to retention were met; the observed record here instead involves an investigator closes a case as not suspicious without recording why multiple cash…. It might establish facts where a customer is retained despite repeated unresolved suspicious transactions because revenue targets…, but those records would not test the observed pattern: an investigator closes a case as not suspicious without recording why multiple cash transfers were….

D:

Against the reported situation in which an investigator closes a case as not suspicious without recording why multiple cash…, independent transaction evidence helps evaluate the concern without prejudgment. This would divert the fact-finding effort toward an employee reports a customer attempting to suppress questions about repeated third-party cash… without resolving the key question raised by an investigator closes a case as not suspicious without recording why multiple cash transfers were….

E:

The relevant alternative mechanism is different from an investigator closes a case as not suspicious without recording why multiple cash…: A nuanced assessment distinguishes documentation barriers from suspicious conduct. It seeks evidence about a bank terminates all accounts belonging to refugees because identity documents differ from its…; the allegation under review instead involves an investigator closes a case as not suspicious without recording why multiple cash transfers were….

Question 382

To establish whether a material financial-crime risk exists, the reviewer considers this situation: An institution introduces an exit-control process that deletes customers before outstanding investigations are resolved. What should be verified?

  1. Trace exit events against open cases, holds, and retention schedules
  2. Inspect timestamp formats, source-system offsets, and parsing failures
  3. Reconcile source payment counts and values with ingested records
  4. Examine field definitions, lineage, and actual source values

Explanation

Correct Answer

A:

Control dependencies determine whether information must be preserved before closure. The inquiry is proportionate to the particular uncertainty in an institution introduces an exit-control process that deletes customers before outstanding…, rather than the separate problem of a monitoring engine receives transaction dates as free-form strings and misorders transfers….

Incorrect Answers

B:

The relevant alternative mechanism is different from an institution introduces an exit-control process that deletes customers before…: Technical evidence identifies whether time conversion changed the actual order of events. It seeks evidence about a monitoring engine receives transaction dates as free-form strings and misorders transfers across…; the allegation under review instead involves an institution introduces an exit-control process that deletes customers before outstanding….

C:

Compared with the stated facts about an institution introduces an exit-control process that deletes customers before…, completeness controls identify missing transactions beyond ordinary alert statistics. That review would be useful if a data warehouse silently drops payment records that fail a new schema validation rule, but it would not resolve the central uncertainty in an institution introduces an exit-control process that deletes customers before outstanding….

D:

This is not the central mechanism when an institution introduces an exit-control process that deletes customers before…; metadata review establishes whether records describe the same legal concept. The inquiry is suited to different businesses label the same beneficial-owner field as shareholder, controller, or principal…; the requested evidence must instead address an institution introduces an exit-control process that deletes customers before outstanding….

Question 383

A relationship review has surfaced this activity: A new customer is a PEP whose funds arrive from a closely held firm with undisclosed controllers. Which information source would be most decisive for verification?

  1. Check changes in public appointments and ongoing customer records
  2. Trace fraud referrals to account relationships and AML case updates
  3. Compare entity, product, jurisdiction, and sanctions-risk inventories
  4. Identify the beneficial ownership event and timing of monitoring triggers
  5. Connect the PEP, firm controllers, and actual account funding
  6. Inspect vendor ownership, personnel access, and conflicting engagements

Explanation

Correct Answer

E:

Tracing relationships and incoming payments tests the asserted economic basis. For the supported action of connect the pep, firm controllers, and actual account funding in this verification review involving a new customer is a PEP whose funds arrive from a closely held firm with undisclosed…, the information sought bears directly on the reported facts, whereas a bank screens PEPs only during initial account opening would need a separate inquiry.

Incorrect Answers

A:

This is not the central mechanism when a new customer is a PEP whose funds arrive from a closely held firm with undisclosed…; event evidence determines whether the relationship gained new exposure. It might establish facts where a bank screens PEPs only during initial account opening, but those records would not test the observed pattern: a new customer is a PEP whose funds arrive from a closely held firm with undisclosed controllers.

B:

When testing the contrasting pattern of a new customer is a PEP whose funds arrive from a closely held firm with undisclosed…, remember that a linked customer view establishes whether relevant signals reached appropriate teams. This would divert the fact-finding effort toward a fraud team sees mule-account patterns that the AML team never incorporates into customer risk… without resolving the key question raised by a new customer is a PEP whose funds arrive from a closely held firm with undisclosed controllers.

C:

The exercise reveals uncovered activities and related control owners; the observed record here instead involves a new customer is a PEP whose funds arrive from a closely held firm with undisclosed…. It seeks evidence about a high-risk subsidiary is included in the enterprise risk assessment but not in the…; the allegation under review instead involves a new customer is a PEP whose funds arrive from a closely held firm with undisclosed controllers.

D:

Against the reported situation in which a new customer is a PEP whose funds arrive from a closely held firm with undisclosed…, a change history establishes whether the bank detected the event promptly. That review would be useful if a risk team updates KYC at account opening but not after a complex customer changes ownership, but it would not resolve the central uncertainty in a new customer is a PEP whose funds arrive from a closely held firm with undisclosed controllers.

F:

Compared with the stated facts about a new customer is a PEP whose funds arrive from a closely held firm with undisclosed…, due diligence should establish who can change sensitive configurations and why. It might establish facts where a technology supplier with access to screening rules also sells services to a…, but those records would not test the observed pattern: a new customer is a PEP whose funds arrive from a closely held firm with undisclosed controllers.

Question 384

An investigator is instructed not to rely on labels alone: A brokerage customer buys securities through several entities and quickly sells them back to connected counterparties. Which substantive check is needed?

  1. Examine payroll, worker complaints, and business ownership links
  2. Compare case dates with applicable filing triggers and deadlines
  3. Map beneficial owners and order-to-settlement counterparties
  4. Compare pricing, cash patterns, and known predicate-crime intelligence

Explanation

Correct Answer

C:

Ownership links and matched trade flows can reveal whether circularity is intentional. This evidence request tests the disputed part of a brokerage customer buys securities through several entities and quickly sells them back to connected…; the other inquiry would be better suited to an account receives payments from employers implicated in withholding migrant workers'….

Incorrect Answers

A:

A coherent evidence trail distinguishes ordinary labor contracting from exploitation proceeds; the observed record here instead involves a brokerage customer buys securities through several entities and quickly sells them…. That review would be useful if an account receives payments from employers implicated in withholding migrant workers' wages and…, but it would not resolve the central uncertainty in a brokerage customer buys securities through several entities and quickly sells them back to….

B:

Against the reported situation in which a brokerage customer buys securities through several entities and quickly sells them…, 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 brokerage customer buys securities through several entities and quickly sells them back to….

D:

Compared with the stated facts about a brokerage customer buys securities through several entities and quickly sells them…, multiple indicators clarify whether unusual trading practices are connected to criminal financing. This would divert the fact-finding effort toward an illicit trade network infiltrates local payment channels and distorts competition with… without resolving the key question raised by a brokerage customer buys securities through several entities and quickly sells them back to….

Question 385

An institution needs corroboration of a suspected weakness: Several mule accounts appear independent until network software links them to a single device and recipient. Which targeted evidence would best clarify the facts?

  1. Reconcile each stated relationship with source-case evidence
  2. Review training data, explanations, bias, and known typology capture
  3. Reconstruct customer-to-beneficiary totals and event sequences
  4. Examine shared devices, beneficiary accounts, timing, and counterparty links

Explanation

Correct Answer

D:

Multiple independent attributes help distinguish a meaningful network from incidental similarity. The proposed review can distinguish the competing explanations in this case without substituting the unrelated checks needed for a case system auto-generates suspicious-activity narratives using AI that sometimes invents….

Incorrect Answers

A:

Against the reported situation in which several mule accounts appear independent until network software links them to a…, investigators should validate generated conclusions before using them in formal filings. This would divert the fact-finding effort toward a case system auto-generates suspicious-activity narratives using AI that sometimes invents account… without resolving the key question raised by several mule accounts appear independent until network software links them to a single device and….

B:

The relevant alternative mechanism is different from several mule accounts appear independent until network software links them to a…: Assessment should cover outcomes as well as the apparent sophistication of the model. It seeks evidence about a bank replaces every rules-based alert with a machine-learning score without evaluating…; the allegation under review instead involves several mule accounts appear independent until network software links them to a single device and….

C:

Compared with the stated facts about several mule accounts appear independent until network software links them to a…, linking activity reveals patterns that isolated transactions cannot show. That review would be useful if a transaction-monitoring rule detects individual large transfers but misses repeated low-value…, but it would not resolve the central uncertainty in several mule accounts appear independent until network software links them to a single device and….

Question 386

A relationship review has surfaced this activity: A firm's US manager sends data requested under an informal private-sector network as if it were a FinCEN 314(a) search. Which information source would be most decisive for verification?

  1. Measure partner feedback, actionable leads, and observed case outcomes
  2. Compare governing AML retention law with data-protection requirements
  3. Verify the request channel and applicable FinCEN participation rules
  4. Map entity, currency, participant, and transaction nexus to relevant regimes

Explanation

Correct Answer

C:

The origin of the request determines legal responsibilities, confidentiality, and permitted use. The information sought bears directly on the reported facts, whereas a joint anti-fraud initiative shares broad typology reports but never provides feedback on… would need a separate inquiry.

Incorrect Answers

A:

This is not the central mechanism when a firm's US manager sends data requested under an informal private-sector network as…; outcome evidence distinguishes a working network from a discussion forum. This would divert the fact-finding effort toward a joint anti-fraud initiative shares broad typology reports but never provides feedback on… without resolving the key question raised by a firm's US manager sends data requested under an informal private-sector network as if it were a….

B:

When testing the contrasting pattern of a firm's US manager sends data requested under an informal private-sector network as…, remember that 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 a firm's US manager sends data requested under an informal private-sector network as if it were a….

D:

Against the reported situation in which a firm's US manager sends data requested under an informal private-sector network as…, a defensible applicability assessment precedes decisions about blocking or rejection. The inquiry is suited to a regional payments company deploys one global sanctions rule without checking local territorial…; the requested evidence must instead address a firm's US manager sends data requested under an informal private-sector network as if it were a….

Question 387

To establish whether a material financial-crime risk exists, the reviewer considers this situation: A data scientist deploys a revised monitoring model without documenting validation or independent challenge. What should be verified?

  1. Obtain development evidence, performance tests, and model approval records
  2. Inspect model decision reasons, override logs, and match identifiers
  3. Review training data, explanations, bias, and known typology capture
  4. Reconcile each stated relationship with source-case evidence

Explanation

Correct Answer

A:

Independent review establishes what changed and which risks arise. For the supported action of obtain development evidence, performance tests, and model approval records in this verification review involving a data scientist deploys a revised monitoring model without documenting validation or…, its value comes from checking the relevant parties and records implicated here; an institution uses AI to prioritize sanctions cases but lets the system permanently clear… calls for different evidence.

Incorrect Answers

B:

The relevant alternative mechanism is different from a data scientist deploys a revised monitoring model without documenting validation or…: A traceable record is necessary to assess whether clearance was defensible. The inquiry is suited to an institution uses AI to prioritize sanctions cases but lets the system permanently clear…; the requested evidence must instead address a data scientist deploys a revised monitoring model without documenting validation or independent….

C:

Compared with the stated facts about a data scientist deploys a revised monitoring model without documenting validation or…, assessment should cover outcomes as well as the apparent sophistication of the model. It might establish facts where a bank replaces every rules-based alert with a machine-learning score without evaluating…, but those records would not test the observed pattern: a data scientist deploys a revised monitoring model without documenting validation or independent….

D:

This is not the central mechanism when a data scientist deploys a revised monitoring model without documenting validation or…; investigators should validate generated conclusions before using them in formal filings. This would divert the fact-finding effort toward a case system auto-generates suspicious-activity narratives using AI that sometimes invents account… without resolving the key question raised by a data scientist deploys a revised monitoring model without documenting validation or independent….

Question 388

An investigator is instructed not to rely on labels alone: A country identifies high exposure to trade-based laundering in free trade zones; a bank uses only residency to rate corporate clients. Which substantive check is needed?

  1. Examine research methods, data limitations, and corroborating studies
  2. Read the primary sanctions regulation and competent authority FAQ
  3. Collect shipping-route, counterparty, and free-zone activity data
  4. Extract root causes and compare with branch reporting controls
  5. Match the FIU indicators to the bank's customer and trade data

Explanation

Correct Answer

C:

Operational geography reveals exposures hidden by incorporation data. The proposed review can distinguish the competing explanations in this case without substituting the unrelated checks needed for a bank repeats industry research claims about laundering indicators without checking….

Incorrect Answers

A:

Quality assessment prevents unsupported claims from driving disproportionate controls; the observed record here instead involves a country identifies high exposure to trade-based laundering in free trade zones; a…. The inquiry is suited to a bank repeats industry research claims about laundering indicators without checking methodology or…; the requested evidence must instead address a country identifies high exposure to trade-based laundering in free trade zones; a bank uses only….

B:

Against the reported situation in which a country identifies high exposure to trade-based laundering in free trade zones; a…, legal text and official interpretive statements control the obligation. It might establish facts where a trade team assumes a private sanctions-screening vendor's advisory is binding legal interpretation, but those records would not test the observed pattern: a country identifies high exposure to trade-based laundering in free trade zones; a bank uses only….

D:

Compared with the stated facts about a country identifies high exposure to trade-based laundering in free trade zones; a…, the value of the case lies in identifying transferable failure mechanisms. It seeks evidence about a supervisor publishes an enforcement case about missed cash reporting by small branches; the allegation under review instead involves a country identifies high exposure to trade-based laundering in free trade zones; a bank uses only….

E:

This is not the central mechanism when a country identifies high exposure to trade-based laundering in free trade zones; a…; internal mapping determines whether the published pattern is actually present. That review would be useful if a regional FIU report identifies a new invoice-manipulation scheme involving the bank's trade…, but it would not resolve the central uncertainty in a country identifies high exposure to trade-based laundering in free trade zones; a bank uses only….

Question 389

An investigator is instructed not to rely on labels alone: A financial crime team has investigators but no ownership of data quality, training, or sanctions policy updates. Which substantive check is needed?

  1. Map RACI responsibilities to control activities and process interfaces
  2. Assess director decisions, emerging risks, and oversight responsibilities
  3. Compare adviser observations with customer profile and payment history
  4. Match legal retention periods and holds to the data lifecycle configuration

Explanation

Correct Answer

A:

The assessment identifies unowned tasks and overlapping decision rights. The proposed review can distinguish the competing explanations in this case without substituting the unrelated checks needed for a board receives annual compliance training identical to the material used for new….

Incorrect Answers

B:

Against the reported situation in which a financial crime team has investigators but no ownership of data quality, training,…, learning objectives should match the board's role in effective challenge. This would divert the fact-finding effort toward a board receives annual compliance training identical to the material used for new customer-service… without resolving the key question raised by a financial crime team has investigators but no ownership of data quality, training, or sanctions….

C:

The relevant alternative mechanism is different from a financial crime team has investigators but no ownership of data quality, training,…: The relationship context may make otherwise routine transactions unusual. It seeks evidence about a wealth adviser notices unexpected offshore transfers but believes only the monitoring system can…; the allegation under review instead involves a financial crime team has investigators but no ownership of data quality, training, or sanctions….

D:

Compared with the stated facts about a financial crime team has investigators but no ownership of data quality, training,…, the comparison identifies records at risk of premature destruction or unlawful retention. That review would be useful if a privacy team deletes records under an automated schedule without considering mandatory AML…, but it would not resolve the central uncertainty in a financial crime team has investigators but no ownership of data quality, training, or sanctions….

Question 390

A relationship review has surfaced this activity: A virtual-asset provider screens wallet transfers against sanctions lists but never links addresses to identified service operators. Which information source would be most decisive for verification?

  1. Review alert precision, unresolved queues, and seeded-list recall
  2. Compare date of birth, geography, employer, and source reliability
  3. Examine wallet clusters, counterparty attribution, and updated designation information
  4. Reconcile screened owner IDs against authoritative updated KYC records

Explanation

Correct Answer

C:

Attribution gives additional context to individual blockchain addresses. The proposed review can distinguish the competing explanations in this case without substituting the unrelated checks needed for a fuzzy sanctions matcher produces overwhelming false hits and analysts cannot clear them….

Incorrect Answers

A:

This is not the central mechanism when a virtual-asset provider screens wallet transfers against sanctions lists but never…; both detection effectiveness and analyst capacity matter when tuning sensitivity. The inquiry is suited to a fuzzy sanctions matcher produces overwhelming false hits and analysts cannot clear them within…; the requested evidence must instead address a virtual-asset provider screens wallet transfers against sanctions lists but never links addresses….

B:

When testing the contrasting pattern of a virtual-asset provider screens wallet transfers against sanctions lists but never…, remember that cross-checking distinctive attributes can distinguish unrelated individuals. It might establish facts where adverse media software flags a person because another individual with the same common name was…, but those records would not test the observed pattern: a virtual-asset provider screens wallet transfers against sanctions lists but never links addresses….

D:

Against the reported situation in which a virtual-asset provider screens wallet transfers against sanctions lists but never…, population testing reveals which controllers are missing from the screening feed. It seeks evidence about a daily sanctions batch screens active customers but excludes recently changed beneficial owners; the allegation under review instead involves a virtual-asset provider screens wallet transfers against sanctions lists but never links addresses….

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