ACAMS CAMS (Certified Anti-Money Laundering Specialist (the 6th edition)) Practice Test 41

Question 400

An unusual pattern requires validation: A data warehouse silently drops payment records that fail a new schema validation rule. Which records most directly address the stated exposure?

  1. Trace exit events against open cases, holds, and retention schedules
  2. Map onboarding, screening, monitoring, investigation, and exit workflows
  3. Reconcile source payment counts and values with ingested records
  4. Review fraud incidence, device risk, and biometric exception rates

Explanation

Correct Answer

C:

Completeness controls identify missing transactions beyond ordinary alert statistics. The inquiry is proportionate to the particular uncertainty in a data warehouse silently drops payment records that fail a new schema validation rule, rather than the separate problem of an institution introduces an exit-control process that deletes customers before outstanding….

Incorrect Answers

A:

This is not the central mechanism when a data warehouse silently drops payment records that fail a new schema validation rule; control dependencies determine whether information must be preserved before closure. It might establish facts where an institution introduces an exit-control process that deletes customers before outstanding…, but those records would not test the observed pattern: a data warehouse silently drops payment records that fail a new schema validation rule.

B:

When testing the contrasting pattern of a data warehouse silently drops payment records that fail a new schema validation rule, remember that 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 data warehouse silently drops payment records that fail a new schema validation rule.

D:

Against the reported situation in which a data warehouse silently drops payment records that fail a new schema validation rule, 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 data warehouse silently drops payment records that fail a new schema validation rule.

Question 401

Staff have identified a repeatable risk pattern: A warehouse operator routes illicit cash proceeds into retail deposits while claiming ordinary shop sales. What would most directly improve control?

  1. Use proportionate EDD and targeted beneficiary monitoring
  2. Escalate extortion-linked transfers through financial-crime investigations
  3. Apply cash-intensive-business due diligence and tailored cash monitoring
  4. Escalate trafficking indicators and monitor linked payroll accounts

Explanation

Correct Answer

C:

For the supported action of apply cash-intensive-business due diligence and tailored cash monitoring in this risk mitigation review involving a warehouse operator routes illicit cash proceeds into retail deposits while claiming ordinary…, expected turnover, seasonality, and cash volumes should define targeted triggers for deviations. Targeting the exposed workflow is more effective than deploying a measure intended for a nonprofit sends numerous low-value remittances to a facilitator in a conflict zone after….

Incorrect Answers

A:

The relevant alternative mechanism is different from a warehouse operator routes illicit cash proceeds into retail deposits while claiming…: Risk review should address channel and geography without automatically excluding legitimate aid. That would be a coherent mitigation for a nonprofit sends numerous low-value remittances to a facilitator in a conflict zone after a…, whereas the immediate gap concerns a warehouse operator routes illicit cash proceeds into retail deposits while claiming ordinary shop….

B:

Compared with the stated facts about a warehouse operator routes illicit cash proceeds into retail deposits while claiming…, a targeted case review preserves evidence and considers reporting under the governing jurisdiction. This safeguard targets a technology company pays regular 'recovery fees' to accounts linked to a regional extortion group; it does not directly remediate the process failure in a warehouse operator routes illicit cash proceeds into retail deposits while claiming ordinary shop….

D:

When testing the contrasting pattern of a warehouse operator routes illicit cash proceeds into retail deposits while claiming…, remember that relationship-level analysis can connect suspicious revenue flows with abusive recruitment practices. The intervention addresses a different exposure: an account receives payments from employers implicated in withholding migrant workers' wages and…; the present case concerns a warehouse operator routes illicit cash proceeds into retail deposits while claiming ordinary shop….

Question 402

An institution must translate its risk findings into practical safeguards: A branch sales manager closes alerts that implicate the manager's own high-value clients. Which action fits?

  1. Rebuild the model with distinct inherent, control, and residual components
  2. Separate first-line risk ownership from second-line challenge and adjudication
  3. Require time-limited exceptions with committee reporting and exit criteria
  4. Calibrate due diligence depth and monitoring to documented risk

Explanation

Correct Answer

B:

Clear decision rights preserve business responsibility while preventing conflicts. For the supported action of separate first-line risk ownership from second-line challenge and adjudication in this risk mitigation review involving a branch sales manager closes alerts that implicate the manager's own high-value clients, the mechanism directly mitigates the stated exposure rather than a related but separate problem such as a bank calculates inherent country risk after deducting the effectiveness of its screening….

Incorrect Answers

A:

Compared with the stated facts about a branch sales manager closes alerts that implicate the manager's own high-value…, transparent separation supports consistent risk decisions and meaningful comparison. Its controls focus on a bank calculates inherent country risk after deducting the effectiveness of its screening controls, which would leave the observed problem of a branch sales manager closes alerts that implicate the manager's own high-value clients unresolved.

C:

When testing the contrasting pattern of a branch sales manager closes alerts that implicate the manager's own high-value…, remember that governed exceptions preserve accountability and prevent permanent unmanaged deviations. This safeguard targets a bank repeatedly grants exceptions for the same high-risk product without reporting them to its…; it does not directly remediate the process failure in a branch sales manager closes alerts that implicate the manager's own high-value clients.

D:

Control effort should grow with exposure while meeting legal minimums for all customers; the observed record here instead involves a branch sales manager closes alerts that implicate the manager's own high-value…. That measure could be appropriate where a small nonprofit receives the same level of documentation demands as a complex offshore corporate…, but the described weakness is a branch sales manager closes alerts that implicate the manager's own high-value clients.

Question 403

The institution wants to reduce this specific exposure: An international bank rejects all payments from a high-risk country without assessing customer or activity differences. What is the most appropriate control design?

  1. Build typology-focused collaboration with controlled escalation paths
  2. Apply targeted enhanced due diligence within stated risk appetite
  3. Broaden lawful partnership participation or structured engagement
  4. Develop feedback channels for lawful, actionable typology exchange

Explanation

Correct Answer

B:

A proportionate approach balances financial-crime exposure with legitimate economic access. The control is aligned with the actual failure in an international bank rejects all payments from a high-risk country without assessing customer or…; safeguards designed for a banking consortium wants to share scam indicators but only discusses names instead of… would not close that gap.

Incorrect Answers

A:

The relevant alternative mechanism is different from an international bank rejects all payments from a high-risk country without assessing…: The design should turn common patterns into actionable internal monitoring updates. That would be a coherent mitigation for a banking consortium wants to share scam indicators but only discusses names instead of…, whereas the immediate gap concerns an international bank rejects all payments from a high-risk country without assessing customer or….

C:

This is not the central mechanism when an international bank rejects all payments from a high-risk country without assessing…; wider sector input can improve typology visibility without indiscriminate data access. That measure could be appropriate where a bank's public-private partnership excludes smaller payment firms that experience the same scam…, but the described weakness is an international bank rejects all payments from a high-risk country without assessing customer or….

D:

When testing the contrasting pattern of an international bank rejects all payments from a high-risk country without assessing…, remember that partnership governance should refine indicators and explain their practical use. The intervention addresses a different exposure: a joint anti-fraud initiative shares broad typology reports but never provides feedback on…; the present case concerns an international bank rejects all payments from a high-risk country without assessing customer or….

Question 404

An auditor describes an unresolved weakness: A compliance officer assumes a FATF public-listing announcement requires identical account termination everywhere. Which remediation addresses the actual failure?

  1. Escalate foreign requests to legal and authorized liaison channels
  2. Map UN measures into the applicable sanctions-screening rulebook
  3. Translate official high-risk country notices into proportionate controls
  4. Maintain a legal obligations inventory alongside industry guidance

Explanation

Correct Answer

C:

Risk response should reflect specific measures rather than automatic blanket exits. For the supported action of translate official high-risk country notices into proportionate controls in this risk mitigation review involving a compliance officer assumes a FATF public-listing announcement requires identical account…, its scope matches this process, while the alternative would mainly address a fraud analyst sends customer data to overseas police on an informal personal email request.

Incorrect Answers

A:

When testing the contrasting pattern of a compliance officer assumes a FATF public-listing announcement requires identical…, remember that formal processes support lawful international assistance and preserve evidence integrity. Its controls focus on a fraud analyst sends customer data to overseas police on an informal personal email request, which would leave the observed problem of a compliance officer assumes a FATF public-listing announcement requires identical account… unresolved.

B:

Institutions should implement binding local restrictions and escalation procedures; the observed record here instead involves a compliance officer assumes a FATF public-listing announcement requires identical…. That would be a coherent mitigation for a payments team assumes every UN Security Council sanctions resolution becomes locally enforceable…, whereas the immediate gap concerns a compliance officer assumes a FATF public-listing announcement requires identical account….

D:

The relevant alternative mechanism is different from a compliance officer assumes a FATF public-listing announcement requires identical…: The program can use good practice while ensuring minimum mandatory duties are satisfied. That measure could be appropriate where a bank uses an industry association's voluntary principles as its only legal compliance standard, but the described weakness is a compliance officer assumes a FATF public-listing announcement requires identical account….

Question 405

A business unit asks compliance for an actionable response to the following: A brokerage customer buys securities through several entities and quickly sells them back to connected counterparties. Which control is most suitable?

  1. Monitor connected-party round trips and non-economic trading
  2. Build commodity and permit-based reviews for high-risk counterparties
  3. Escalate trafficking indicators and monitor linked payroll accounts
  4. Apply cash-intensive-business due diligence and tailored cash monitoring

Explanation

Correct Answer

A:

Scenario logic should detect repeated offsetting trades among linked entities. The control is aligned with the actual failure in a brokerage customer buys securities through several entities and quickly sells them back to connected…; safeguards designed for a recycling firm receives international transfers inconsistent with its permits and… would not close that gap.

Incorrect Answers

B:

The relevant alternative mechanism is different from a brokerage customer buys securities through several entities and quickly sells them…: EDD should investigate the actual trade and licensing, not simply the payment amounts. Its controls focus on a recycling firm receives international transfers inconsistent with its permits and declared scrap…, which would leave the observed problem of a brokerage customer buys securities through several entities and quickly sells them back to… unresolved.

C:

Compared with the stated facts about a brokerage customer buys securities through several entities and quickly sells them…, relationship-level analysis can connect suspicious revenue flows with abusive recruitment practices. That would be a coherent mitigation for an account receives payments from employers implicated in withholding migrant workers' wages and…, whereas the immediate gap concerns a brokerage customer buys securities through several entities and quickly sells them back to….

D:

This is not the central mechanism when a brokerage customer buys securities through several entities and quickly sells them…; expected turnover, seasonality, and cash volumes should define targeted triggers for deviations. This safeguard targets a warehouse operator routes illicit cash proceeds into retail deposits while claiming ordinary shop…; it does not directly remediate the process failure in a brokerage customer buys securities through several entities and quickly sells them back to….

Question 406

Following the discovery that a fraud analyst sends customer data to overseas police on an informal personal email request., which risk-based intervention most directly addresses the problem?

  1. Integrate goods, destination, and end-use controls with name screening
  2. Integrate regional findings into jurisdiction and sector risk assessments
  3. Maintain a legal obligations inventory alongside industry guidance
  4. Escalate foreign requests to legal and authorized liaison channels
  5. Use risk-tuned matching and documented match-resolution workflows
  6. Use NGO typology research as intelligence, not as binding regulation

Explanation

Correct Answer

D:

Formal processes support lawful international assistance and preserve evidence integrity. Targeting the exposed workflow is more effective than deploying a measure intended for a branch screens sanctioned party names but overlooks a UN embargo relating to a category….

Incorrect Answers

A:

When testing the contrasting pattern of a fraud analyst sends customer data to overseas police on an informal personal email…, remember that trade due diligence should reflect the measures applicable to the underlying goods. That measure could be appropriate where a branch screens sanctioned party names but overlooks a UN embargo relating to a category of…, but the described weakness is a fraud analyst sends customer data to overseas police on an informal personal email request.

B:

Policies should reflect local implementation weaknesses and emerging typologies; the observed record here instead involves a fraud analyst sends customer data to overseas police on an informal personal email…. The intervention addresses a different exposure: a bank ignores guidance from the regional FATF-style body serving one of its markets; the present case concerns a fraud analyst sends customer data to overseas police on an informal personal email request.

C:

Against the reported situation in which a fraud analyst sends customer data to overseas police on an informal personal email…, the program can use good practice while ensuring minimum mandatory duties are satisfied. Its controls focus on a bank uses an industry association's voluntary principles as its only legal compliance standard, which would leave the observed problem of a fraud analyst sends customer data to overseas police on an informal personal email request unresolved.

E:

Compared with the stated facts about a fraud analyst sends customer data to overseas police on an informal personal email…, a reliable process combines screening sensitivity with trained review of identifying details. This safeguard targets a sanctions analyst releases a possible listed-person match because the customer name has different…; it does not directly remediate the process failure in a fraud analyst sends customer data to overseas police on an informal personal email request.

F:

This is not the central mechanism when a fraud analyst sends customer data to overseas police on an informal personal email…; aFC teams should triangulate third-party insights with official obligations. That measure could be appropriate where a nonprofit training group claims authority to impose national AML penalties because it publishes…, but the described weakness is a fraud analyst sends customer data to overseas police on an informal personal email request.

Question 407

An AFC owner is assigned to remediate this finding: A bank selects a screening vendor based on advertised accuracy without checking payment-system integration or regulatory coverage. What change best targets the underlying vulnerability?

  1. Use controlled federated or aggregated analysis where lawful and effective
  2. Require approved data-minimization and contractual privacy controls
  3. Conduct scenario-based proof-of-concept and integration assessment
  4. Allocate capacity by risk and introduce high-severity service levels
  5. Prioritize data completeness and essential coverage before optional analytics

Explanation

Correct Answer

C:

Selection should validate detection, operations, data protection, and maintainability before commitment. This intervention operates at the point where the reported weakness arises; a cross-border analytics team seeks risk insights without moving identifiable customer… presents a different failure mode.

Incorrect Answers

A:

Data can sometimes be analyzed locally while sharing limited insights rather than raw records; the observed record here instead involves a bank selects a screening vendor based on advertised accuracy without checking…. The intervention addresses a different exposure: a cross-border analytics team seeks risk insights without moving identifiable customer files…; the present case concerns a bank selects a screening vendor based on advertised accuracy without checking payment-system….

B:

Against the reported situation in which a bank selects a screening vendor based on advertised accuracy without checking…, privacy-preserving architecture should limit secondary use and protect investigatory records. Its controls focus on an investigation platform copies unmasked sensitive customer records into a vendor's…, which would leave the observed problem of a bank selects a screening vendor based on advertised accuracy without checking payment-system… unresolved.

D:

Compared with the stated facts about a bank selects a screening vendor based on advertised accuracy without checking…, operational governance should align resources to potential harm rather than headline throughput. This safeguard targets an AML analytics unit reports record throughput but growing unresolved high-risk alerts remain…; it does not directly remediate the process failure in a bank selects a screening vendor based on advertised accuracy without checking payment-system….

E:

This is not the central mechanism when a bank selects a screening vendor based on advertised accuracy without checking…; resource allocation should first close material surveillance blind spots. That measure could be appropriate where a bank invests in a complex AI tool while high-risk payment streams still bypass basic transaction…, but the described weakness is a bank selects a screening vendor based on advertised accuracy without checking payment-system….

Question 408

Following the discovery that a joint anti-fraud initiative shares broad typology reports but never provides feedback on actionable indicators., which risk-based intervention most directly addresses the problem?

  1. Build a sanctions legal inventory and regime-specific escalation paths
  2. Develop feedback channels for lawful, actionable typology exchange
  3. Implement a jurisdiction-specific records lifecycle schedule
  4. Design lawful data-sharing architecture with purpose and access limits

Explanation

Correct Answer

B:

Partnership governance should refine indicators and explain their practical use. The mechanism directly mitigates the stated exposure rather than a related but separate problem such as a regional payments company deploys one global sanctions rule without checking local….

Incorrect Answers

A:

When testing the contrasting pattern of a joint anti-fraud initiative shares broad typology reports but never provides…, remember that group controls can be consistent without ignoring country-specific prohibitions. Its controls focus on a regional payments company deploys one global sanctions rule without checking local territorial…, which would leave the observed problem of a joint anti-fraud initiative shares broad typology reports but never provides feedback on… unresolved.

C:

Against the reported situation in which a joint anti-fraud initiative shares broad typology reports but never provides…, retention schedules should satisfy mandatory periods while limiting unnecessary persistence. This safeguard targets a cross-border institution applies domestic data retention periods to client records governed by a…; it does not directly remediate the process failure in a joint anti-fraud initiative shares broad typology reports but never provides feedback on….

D:

The relevant alternative mechanism is different from a joint anti-fraud initiative shares broad typology reports but never provides…: Technical solutions should support AML work without overriding binding privacy requirements. That measure could be appropriate where a bank centralizes all customer data in one country despite incompatible transfer restrictions in…, but the described weakness is a joint anti-fraud initiative shares broad typology reports but never provides feedback on….

Question 409

An institution must translate its risk findings into practical safeguards: A tax adviser creates repeated artificial loss-making entities whose transfers fund personal luxury purchases. Which action fits?

  1. Require substance testing for high-value professional-fee payments
  2. Escalate sham-entity indicators and analyze beneficiary spending
  3. Apply related-entity network due diligence before onboarding
  4. Verify underlying principals where nominee arrangements are present

Explanation

Correct Answer

B:

Risk-based scrutiny should connect the tax scheme to subsequent movements of value. The control is aligned with the actual failure in a tax adviser creates repeated artificial loss-making entities whose transfers fund personal luxury…; safeguards designed for a professional service provider invoices an offshore entity for vague advisory work… would not close that gap.

Incorrect Answers

A:

Compared with the stated facts about a tax adviser creates repeated artificial loss-making entities whose transfers fund…, control teams should assess economic purpose rather than relying on an invoice heading. That would be a coherent mitigation for a professional service provider invoices an offshore entity for vague advisory work followed by…, whereas the immediate gap concerns a tax adviser creates repeated artificial loss-making entities whose transfers fund personal luxury….

C:

When testing the contrasting pattern of a tax adviser creates repeated artificial loss-making entities whose transfers fund…, remember that identification of common control helps prevent fragmented risk treatment across customers. That measure could be appropriate where a company-service provider registers dozens of firms sharing directors, addresses, and inactive…, but the described weakness is a tax adviser creates repeated artificial loss-making entities whose transfers fund personal luxury….

D:

EDD should trace effective control rather than accept the nominee's identification alone; the observed record here instead involves a tax adviser creates repeated artificial loss-making entities whose transfers fund…. The intervention addresses a different exposure: a nominee director signs transactions on instruction from an undisclosed offshore client; the present case concerns a tax adviser creates repeated artificial loss-making entities whose transfers fund personal luxury….

Question 410

A control-design team faces this gap: A trade client purchases dual-use machinery through several intermediary companies near a conflict region. Which tailored safeguard should it prioritize?

  1. Write concise, factual SAR narratives using evidenced timelines
  2. Apply specialized trade EDD and sanctions escalation before settlement
  3. Apply time-bound conditions with escalation for breaches
  4. Open a documented relationship-level unusual-activity investigation

Explanation

Correct Answer

B:

Tailored checks should address the nature of the goods and end-use route. For the supported action of apply specialized trade edd and sanctions escalation before settlement in this risk mitigation review involving a trade client purchases dual-use machinery through several intermediary companies near a…, its scope matches this process, while the alternative would mainly address an AML team files a report that lists transaction values but fails to explain the suspected….

Incorrect Answers

A:

This is not the central mechanism when a trade client purchases dual-use machinery through several intermediary companies…; objective descriptions help intelligence authorities assess the case without speculation. That measure could be appropriate where an AML team files a report that lists transaction values but fails to explain the suspected pattern…, but the described weakness is a trade client purchases dual-use machinery through several intermediary companies near a conflict….

C:

Risk owners should track exceptions and act when agreed mitigation fails; the observed record here instead involves a trade client purchases dual-use machinery through several intermediary companies…. Its controls focus on a customer is retained despite repeated unresolved suspicious transactions because revenue targets…, which would leave the observed problem of a trade client purchases dual-use machinery through several intermediary companies near a conflict… unresolved.

D:

Against the reported situation in which a trade client purchases dual-use machinery through several intermediary companies…, a holistic review should compare the pattern to expected behavior and reporting thresholds. That would be a coherent mitigation for a retail customer receives a series of unrelated inbound transfers and sends almost all funds…, whereas the immediate gap concerns a trade client purchases dual-use machinery through several intermediary companies near a conflict….

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