ACAMS CAMS (Certified Anti-Money Laundering Specialist (the 6th edition)) Practice Test 51

Question 500

An institution must translate its risk findings into practical safeguards: A bank closes an account under investigation without considering an authorized law-enforcement request to keep it open. Which action fits?

  1. Build controlled cross-risk referrals into scoring and investigations
  2. Complete identity and beneficial ownership controls before appropriate onboarding
  3. Run risk-based ongoing PEP screening and reassessment
  4. Trigger targeted CDD refresh and transaction review for behavior changes
  5. Escalate account exit through legal and AFC governance before closure

Explanation

Correct Answer

E:

Coordinated decision-making balances customer risk with valid investigative requirements. The control is aligned with the actual failure in a bank closes an account under investigation without considering an authorized law-enforcement request…; safeguards designed for a fraud team sees mule-account patterns that the AML team never incorporates into customer… would not close that gap.

Incorrect Answers

A:

Compared with the stated facts about a bank closes an account under investigation without considering an authorized…, sharing validated indicators improves awareness without treating every fraud alert as proven laundering. This safeguard targets a fraud team sees mule-account patterns that the AML team never incorporates into customer risk…; it does not directly remediate the process failure in a bank closes an account under investigation without considering an authorized law-enforcement….

B:

This is not the central mechanism when a bank closes an account under investigation without considering an authorized…; any permitted reliance arrangement should preserve accountability and accessible records. That measure could be appropriate where a corporate client uses a trusted introducer but the bank has not verified its actual controlling…, but the described weakness is a bank closes an account under investigation without considering an authorized law-enforcement….

C:

When testing the contrasting pattern of a bank closes an account under investigation without considering an authorized…, remember that monitoring should detect new roles and prompt enhanced measures when warranted. The intervention addresses a different exposure: a bank screens PEPs only during initial account opening; the present case concerns a bank closes an account under investigation without considering an authorized law-enforcement….

D:

A linked process investigates anomalies rather than automatically treating them as crime; the observed record here instead involves a bank closes an account under investigation without considering an authorized…. Its controls focus on a customer profile lists salary income but transactions show unusually large commercial receipts, which would leave the observed problem of a bank closes an account under investigation without considering an authorized law-enforcement… unresolved.

Question 501

A risk owner seeks a focused response rather than blanket customer exclusion: An institution rates all foreign transactions high-risk without considering destination, customer, or purpose. Which option is best?

  1. Rebuild the model with distinct inherent, control, and residual components
  2. Use evidence-based geographical and product risk factors
  3. Publish controlled definitions and local procedure mappings
  4. Issue implementable procedures linked to the PEP policy and standards
  5. Define measurable prohibitions, limits, and escalation triggers in the RAS
  6. Introduce event-triggered enterprise risk reassessments

Explanation

Correct Answer

B:

Risk scoring should reflect actual typologies and legal obligations, not a blanket foreign label. For the supported action of use evidence-based geographical and product risk factors in this risk mitigation review involving an institution rates all foreign transactions high-risk without considering destination,…, 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:

Against the reported situation in which an institution rates all foreign transactions high-risk without considering…, 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 an institution rates all foreign transactions high-risk without considering destination, customer,… unresolved.

C:

Compared with the stated facts about an institution rates all foreign transactions high-risk without considering…, the governance framework should allow lawful local variation while retaining core minimums. This safeguard targets two branches define 'high-risk customer' differently despite a central group standard; it does not directly remediate the process failure in an institution rates all foreign transactions high-risk without considering destination, customer,….

D:

This is not the central mechanism when an institution rates all foreign transactions high-risk without considering…; workflows should identify checks, approvals, systems, and required records. That measure could be appropriate where a policy requires EDD for foreign PEPs but staff cannot find the corresponding review steps, but the described weakness is an institution rates all foreign transactions high-risk without considering destination, customer,….

E:

When testing the contrasting pattern of an institution rates all foreign transactions high-risk without considering…, remember that specific tolerances translate board intent into customer and product decisions. The intervention addresses a different exposure: a bank's risk appetite says 'zero financial crime' but gives no measurable boundaries for high-risk…; the present case concerns an institution rates all foreign transactions high-risk without considering destination, customer,….

F:

Major changes should produce timely updates to controls and board information; the observed record here instead involves an institution rates all foreign transactions high-risk without considering…. Its controls focus on a firm expands into a high-risk remittance corridor but leaves enterprise risk scores unchanged for…, which would leave the observed problem of an institution rates all foreign transactions high-risk without considering destination, customer,… unresolved.

Question 502

Staff have identified a repeatable risk pattern: A notary receives large third-party escrow deposits with no connection to the declared asset transfer. What would most directly improve control?

  1. Flag short-period related-party resales and unexplained price changes
  2. Verify underlying principals where nominee arrangements are present
  3. Refresh trust-party CDD after material distribution or deed changes
  4. Monitor unexplained escrow inflows and beneficiary changes

Explanation

Correct Answer

D:

Controls should challenge third-party funding unrelated to the underlying agreement. The control is aligned with the actual failure in a notary receives large third-party escrow deposits with no connection to the declared asset transfer; safeguards designed for a land developer rapidly sells the same parcel among related entities at escalating prices would not close that gap.

Incorrect Answers

A:

The relevant alternative mechanism is different from a notary receives large third-party escrow deposits with no connection to the…: Transaction monitoring should identify concentrated linked-party real-estate movement. Its controls focus on a land developer rapidly sells the same parcel among related entities at escalating prices, which would leave the observed problem of a notary receives large third-party escrow deposits with no connection to the declared asset… unresolved.

B:

Compared with the stated facts about a notary receives large third-party escrow deposits with no connection to the…, eDD should trace effective control rather than accept the nominee's identification alone. That would be a coherent mitigation for a nominee director signs transactions on instruction from an undisclosed offshore client, whereas the immediate gap concerns a notary receives large third-party escrow deposits with no connection to the declared asset….

C:

This is not the central mechanism when a notary receives large third-party escrow deposits with no connection to the…; risk controls should follow changes to beneficiaries and powers throughout the relationship. This safeguard targets a trustee directs distributions to beneficiaries omitted from a family's original trust…; it does not directly remediate the process failure in a notary receives large third-party escrow deposits with no connection to the declared asset….

Question 503

A risk owner seeks a focused response rather than blanket customer exclusion: An accountant certifies revenue for a client despite bank receipts that sharply diverge from tax filings. Which option is best?

  1. Review third-party vehicle funding and rapid resale patterns
  2. Apply enhanced revenue plausibility checks for inconsistent statements
  3. Apply proportionate crowdfunding organizer and beneficiary due diligence
  4. Apply related-entity network due diligence before onboarding
  5. Refresh trust-party CDD after material distribution or deed changes

Explanation

Correct Answer

B:

The review should reconcile actual operations to declared income before granting services. The mechanism directly mitigates the stated exposure rather than a related but separate problem such as a luxury-car broker accepts repeated deposits from unrelated companies and resells vehicles….

Incorrect Answers

A:

Against the reported situation in which an accountant certifies revenue for a client despite bank receipts that sharply…, targeted monitoring should cover ownership changes and improbable commercial incentives. Its controls focus on a luxury-car broker accepts repeated deposits from unrelated companies and resells vehicles almost…, which would leave the observed problem of an accountant certifies revenue for a client despite bank receipts that sharply diverge from tax… unresolved.

C:

Compared with the stated facts about an accountant certifies revenue for a client despite bank receipts that sharply…, controls should identify who receives the funds while preserving legitimate fundraising. This safeguard targets a nonprofit fundraiser channels emergency donations through an opaque crowdfunding account and…; it does not directly remediate the process failure in an accountant certifies revenue for a client despite bank receipts that sharply diverge from tax….

D:

This is not the central mechanism when an accountant certifies revenue for a client despite bank receipts that sharply…; 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 an accountant certifies revenue for a client despite bank receipts that sharply diverge from tax….

E:

When testing the contrasting pattern of an accountant certifies revenue for a client despite bank receipts that sharply…, remember that risk controls should follow changes to beneficiaries and powers throughout the relationship. The intervention addresses a different exposure: a trustee directs distributions to beneficiaries omitted from a family's original trust…; the present case concerns an accountant certifies revenue for a client despite bank receipts that sharply diverge from tax….

Question 504

A business unit asks compliance for an actionable response to the following: A payment app adds facial recognition to every minor account-profile change despite low observed fraud exposure. Which control is most suitable?

  1. Apply contextual verification triggers to higher-risk account events
  2. Implement ingestion exception alerts and controlled replay of rejected data
  3. Adopt governed common data definitions and lineage rules
  4. Apply documented quality and identity checks to external data feeds

Explanation

Correct Answer

A:

Controls should be commensurate with exposure and inclusive of users who cannot use biometrics. Targeting the exposed workflow is more effective than deploying a measure intended for a data warehouse silently drops payment records that fail a new schema validation rule.

Incorrect Answers

B:

The relevant alternative mechanism is different from a payment app adds facial recognition to every minor account-profile change despite…: A dependable pipeline must surface and recover failed records before exposure persists. That measure could be appropriate where a data warehouse silently drops payment records that fail a new schema validation rule, but the described weakness is a payment app adds facial recognition to every minor account-profile change despite low observed….

C:

Compared with the stated facts about a payment app adds facial recognition to every minor account-profile change despite…, systems must preserve meaning when customer records are combined. The intervention addresses a different exposure: different businesses label the same beneficial-owner field as shareholder, controller, or principal…; the present case concerns a payment app adds facial recognition to every minor account-profile change despite low observed….

D:

This is not the central mechanism when a payment app adds facial recognition to every minor account-profile change despite…; automated enrichment should not turn name similarity into an unsupported adverse conclusion. Its controls focus on a bank buys adverse-media data but cannot explain which persons its records actually match, which would leave the observed problem of a payment app adds facial recognition to every minor account-profile change despite low observed… unresolved.

Question 505

A control-design team faces this gap: A bank centralizes all customer data in one country despite incompatible transfer restrictions in another. Which tailored safeguard should it prioritize?

  1. Use a documented permitted sharing mechanism with data minimization
  2. Create peer-referral validation and documented escalation rules
  3. Develop feedback channels for lawful, actionable typology exchange
  4. Design lawful data-sharing architecture with purpose and access limits

Explanation

Correct Answer

D:

Technical solutions should support AML work without overriding binding privacy requirements. The control is aligned with the actual failure in a bank centralizes all customer data in one country despite incompatible transfer restrictions in another; safeguards designed for two private banks exchange a customer's full personal file without verifying a recognized… would not close that gap.

Incorrect Answers

A:

This is not the central mechanism when a bank centralizes all customer data in one country despite incompatible transfer…; the institution should share only relevant information under authorized procedures. Its controls focus on two private banks exchange a customer's full personal file without verifying a recognized sharing…, which would leave the observed problem of a bank centralizes all customer data in one country despite incompatible transfer restrictions in… unresolved.

B:

When testing the contrasting pattern of a bank centralizes all customer data in one country despite incompatible transfer…, remember that review should weigh reliability and context before a proportionate decision. That would be a coherent mitigation for an institution receives a peer alert about a suspicious account and immediately exits the client…, whereas the immediate gap concerns a bank centralizes all customer data in one country despite incompatible transfer restrictions in….

C:

Partnership governance should refine indicators and explain their practical use; the observed record here instead involves a bank centralizes all customer data in one country despite incompatible transfer…. This safeguard targets a joint anti-fraud initiative shares broad typology reports but never provides feedback on…; it does not directly remediate the process failure in a bank centralizes all customer data in one country despite incompatible transfer restrictions in….

Question 506

A control-design team faces this gap: A property investor funds down payments with loans from companies that immediately receive matching offshore deposits. Which tailored safeguard should it prioritize?

  1. Apply cash-intensive-business due diligence and tailored cash monitoring
  2. Escalate remediation with board-owned milestones and evidence
  3. Use risk intelligence to prioritize exposed sectors and businesses
  4. Screen beneficiaries and review end-use controls for grants
  5. Build commodity and permit-based reviews for high-risk counterparties
  6. Review related-party loan agreements and provenance before completion

Explanation

Correct Answer

F:

Loan documents alone are insufficient without corroborating economic capacity and beneficial ownership. For the supported action of review related-party loan agreements and provenance before completion in this risk mitigation review involving a property investor funds down payments with loans from companies that immediately receive…, the mechanism directly mitigates the stated exposure rather than a related but separate problem such as a warehouse operator routes illicit cash proceeds into retail deposits while claiming….

Incorrect Answers

A:

This is not the central mechanism when a property investor funds down payments with loans from companies that immediately…; expected turnover, seasonality, and cash volumes should define targeted triggers for deviations. That measure could be appropriate where a warehouse operator routes illicit cash proceeds into retail deposits while claiming ordinary shop…, but the described weakness is a property investor funds down payments with loans from companies that immediately receive matching….

B:

When testing the contrasting pattern of a property investor funds down payments with loans from companies that immediately…, remember that documented accountability and credible control improvements are needed to restore counterparty confidence. The intervention addresses a different exposure: a bank loses correspondent relationships after repeated failures to remediate reported AML…; the present case concerns a property investor funds down payments with loans from companies that immediately receive matching….

C:

Sectoral typologies should inform enhanced review and proportionate control placement; the observed record here instead involves a property investor funds down payments with loans from companies that immediately…. Its controls focus on an illicit trade network infiltrates local payment channels and distorts competition with…, which would leave the observed problem of a property investor funds down payments with loans from companies that immediately receive matching… unresolved.

D:

Against the reported situation in which a property investor funds down payments with loans from companies that immediately…, a risk-based charity program should assess recipients, geography, and diversion vulnerabilities rather than rely on donor amounts. That would be a coherent mitigation for a charity receives small lawful donations and a trustee secretly diverts the proceeds to a…, whereas the immediate gap concerns a property investor funds down payments with loans from companies that immediately receive matching….

E:

The relevant alternative mechanism is different from a property investor funds down payments with loans from companies that immediately…: EDD should investigate the actual trade and licensing, not simply the payment amounts. This safeguard targets a recycling firm receives international transfers inconsistent with its permits and declared scrap…; it does not directly remediate the process failure in a property investor funds down payments with loans from companies that immediately receive matching….

Question 507

An auditor describes an unresolved weakness: A bank treats a voluntary interbank information request as an automatic section 314(a) government search. Which remediation addresses the actual failure?

  1. Create controlled RFI templates and investigator-review procedures
  2. Use targeted mitigation and documented risk appetite decisions
  3. Use legally approved neutral responses and restrict SAR access
  4. Create separate intake, authorization, and disclosure procedures

Explanation

Correct Answer

D:

A controlled approach avoids accidental statutory noncompliance or unauthorized sharing. Its scope matches this process, while the alternative would mainly address an investigator requests business documents through a customer-facing team using an….

Incorrect Answers

A:

When testing the contrasting pattern of a bank treats a voluntary interbank information request as an automatic section…, remember that the process should seek relevant information while avoiding prohibited disclosures. This safeguard targets an investigator requests business documents through a customer-facing team using an accusatory…; it does not directly remediate the process failure in a bank treats a voluntary interbank information request as an automatic section 314(a) government….

B:

A proportionate strategy can avoid excluding legitimate remittances unnecessarily; the observed record here instead involves a bank treats a voluntary interbank information request as an automatic section…. That measure could be appropriate where an MSB withdraws from an entire remittance corridor after isolated suspicious cases without…, but the described weakness is a bank treats a voluntary interbank information request as an automatic section 314(a) government….

C:

Against the reported situation in which a bank treats a voluntary interbank information request as an automatic section…, communications should address service questions without revealing protected reports. The intervention addresses a different exposure: a customer asks why a transfer is held; an analyst says it is because a suspicious-activity report…; the present case concerns a bank treats a voluntary interbank information request as an automatic section 314(a) government….

Question 508

An auditor describes an unresolved weakness: A procurement officer is offered consultancy fees tied to awarding a government infrastructure contract. Which remediation addresses the actual failure?

  1. Require conflict-of-interest review and independent approval
  2. Escalate trafficking indicators and monitor linked payroll accounts
  3. Monitor connected-party round trips and non-economic trading
  4. Introduce capacity-based triage and statutory-deadline controls
  5. Review related-party loan agreements and provenance before completion
  6. Use proportionate EDD and targeted beneficiary monitoring

Explanation

Correct Answer

A:

Controls over third-party intermediaries reduce the risk of disguised inducements and self-dealing. This intervention operates at the point where the reported weakness arises; an account receives payments from employers implicated in withholding migrant workers'… presents a different failure mode.

Incorrect Answers

B:

Relationship-level analysis can connect suspicious revenue flows with abusive recruitment practices; the observed record here instead involves a procurement officer is offered consultancy fees tied to awarding a government…. 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 procurement officer is offered consultancy fees tied to awarding a government infrastructure….

C:

Against the reported situation in which a procurement officer is offered consultancy fees tied to awarding a government…, scenario logic should detect repeated offsetting trades among linked entities. This safeguard targets a brokerage customer buys securities through several entities and quickly sells them back to…; it does not directly remediate the process failure in a procurement officer is offered consultancy fees tied to awarding a government infrastructure….

D:

The relevant alternative mechanism is different from a procurement officer is offered consultancy fees tied to awarding a government…: Escalation owners and exception tracking help prevent queues from exceeding legal reporting windows. That measure could be appropriate where a suspicious-activity backlog grows until analysts miss required reporting deadlines, but the described weakness is a procurement officer is offered consultancy fees tied to awarding a government infrastructure….

E:

Compared with the stated facts about a procurement officer is offered consultancy fees tied to awarding a government…, loan documents alone are insufficient without corroborating economic capacity and beneficial ownership. The intervention addresses a different exposure: a property investor funds down payments with loans from companies that immediately receive matching…; the present case concerns a procurement officer is offered consultancy fees tied to awarding a government infrastructure….

F:

This is not the central mechanism when a procurement officer is offered consultancy fees tied to awarding a government…; risk review should address channel and geography without automatically excluding legitimate aid. Its controls focus on a nonprofit sends numerous low-value remittances to a facilitator in a conflict zone after a…, which would leave the observed problem of a procurement officer is offered consultancy fees tied to awarding a government infrastructure… unresolved.

Question 509

An institution must translate its risk findings into practical safeguards: Several esports betting accounts trade bets against each other and cash out through the same device network. Which action fits?

  1. Require linked-party checks for unusually clustered policy sales
  2. Monitor coordinated betting and linked-account withdrawals
  3. Due-diligence issuers and redemption counterparties using a risk-based approach
  4. Build interoperable counterparty-information exchange and exception handling

Explanation

Correct Answer

B:

Controls should combine gameplay patterns with identity and payment relationships. The mechanism directly mitigates the stated exposure rather than a related but separate problem such as an insurance broker proposes many single-premium policies purchased by entities with the….

Incorrect Answers

A:

Compared with the stated facts about several esports betting accounts trade bets against each other and cash out through…, monitoring should recognize shared controllers and intermediaries across multiple contracts. Its controls focus on an insurance broker proposes many single-premium policies purchased by entities with the same…, which would leave the observed problem of several esports betting accounts trade bets against each other and cash out through the same device… unresolved.

C:

When testing the contrasting pattern of several esports betting accounts trade bets against each other and cash out through…, remember that controls should cover fiat rails and reserve-linked payments, not merely token transfers. This safeguard targets a virtual-asset custodian processes large stablecoin redemptions through offshore issuers with weak…; it does not directly remediate the process failure in several esports betting accounts trade bets against each other and cash out through the same device….

D:

A process should obtain and transmit required data where local rules apply, with controlled failures; the observed record here instead involves several esports betting accounts trade bets against each other and cash out through…. That measure could be appropriate where a virtual-asset provider fails to exchange required originator and beneficiary information with…, but the described weakness is several esports betting accounts trade bets against each other and cash out through the same device….

Question 510

An auditor describes an unresolved weakness: A cross-border analytics team seeks risk insights without moving identifiable customer files between subsidiaries. Which remediation addresses the actual failure?

  1. Allocate capacity by risk and introduce high-severity service levels
  2. Conduct scenario-based proof-of-concept and integration assessment
  3. Use controlled federated or aggregated analysis where lawful and effective
  4. Introduce fail-safe escalation and monitored resilience procedures

Explanation

Correct Answer

C:

Data can sometimes be analyzed locally while sharing limited insights rather than raw records. Targeting the exposed workflow is more effective than deploying a measure intended for an AML analytics unit reports record throughput but growing unresolved high-risk alerts….

Incorrect Answers

A:

When testing the contrasting pattern of a cross-border analytics team seeks risk insights without moving identifiable…, remember that operational governance should align resources to potential harm rather than headline throughput. That would be a coherent mitigation for an AML analytics unit reports record throughput but growing unresolved high-risk alerts remain…, whereas the immediate gap concerns a cross-border analytics team seeks risk insights without moving identifiable customer files….

B:

Selection should validate detection, operations, data protection, and maintainability before commitment; the observed record here instead involves a cross-border analytics team seeks risk insights without moving identifiable…. This safeguard targets a bank selects a screening vendor based on advertised accuracy without checking payment-system…; it does not directly remediate the process failure in a cross-border analytics team seeks risk insights without moving identifiable customer files….

D:

The relevant alternative mechanism is different from a cross-border analytics team seeks risk insights without moving identifiable…: The design should respond to outages according to legal and operational risk. The intervention addresses a different exposure: a monitoring system change goes live with no fallback when its external API becomes unavailable; the present case concerns a cross-border analytics team seeks risk insights without moving identifiable customer files….

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