ACAMS CAMS (Certified Anti-Money Laundering Specialist (the 6th edition)) Practice Test 52

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….

Question 511

After a risk-assessment update notes that a payments engine screens only the recipient name while ignoring originator and intermediary information in incoming messages., which safeguard most closely responds to the root cause?

  1. Configure field-complete payment screening with message-specific mappings
  2. Use explainable event screening with review and escalation safeguards
  3. Include beneficial-owner and ownership-change events in batch screening
  4. Calibrate fuzzy rules with documented false-negative safeguards

Explanation

Correct Answer

A:

Sanctions controls should cover relevant originator, intermediary, and beneficiary attributes. The control is aligned with the actual failure in a payments engine screens only the recipient name while ignoring originator and intermediary information…; safeguards designed for an automated KYC tool increases a customer's risk score on every adverse-media mention… would not close that gap.

Incorrect Answers

B:

This is not the central mechanism when a payments engine screens only the recipient name while ignoring originator and…; automation should prioritize changes while preserving evidence-based decisions. Its controls focus on an automated KYC tool increases a customer's risk score on every adverse-media mention without…, which would leave the observed problem of a payments engine screens only the recipient name while ignoring originator and intermediary… unresolved.

C:

When testing the contrasting pattern of a payments engine screens only the recipient name while ignoring originator and…, remember that risk controls should respond when individuals behind a legal person change. That would be a coherent mitigation for a daily sanctions batch screens active customers but excludes recently changed beneficial owners, whereas the immediate gap concerns a payments engine screens only the recipient name while ignoring originator and intermediary….

D:

Optimization should improve usable signal without ignoring legally relevant variants; the observed record here instead involves a payments engine screens only the recipient name while ignoring originator and…. This safeguard targets a fuzzy sanctions matcher produces overwhelming false hits and analysts cannot clear them within…; it does not directly remediate the process failure in a payments engine screens only the recipient name while ignoring originator and intermediary….

Question 512

An auditor describes an unresolved weakness: A new customer is a PEP whose funds arrive from a closely held firm with undisclosed controllers. Which remediation addresses the actual failure?

  1. Write concise, factual SAR narratives using evidenced timelines
  2. Create separate intake, authorization, and disclosure procedures
  3. Open a documented relationship-level unusual-activity investigation
  4. Use monitored clocks and defined decision owners for reportable cases
  5. Create cross-risk escalation for data and control outages
  6. Obtain appropriate approvals and enhanced source-of-wealth review

Explanation

Correct Answer

F:

Governance should address both political influence and unexplained wealth accumulation. For the supported action of obtain appropriate approvals and enhanced source-of-wealth review in this risk mitigation review involving a new customer is a PEP whose funds arrive from a closely held firm with undisclosed…, 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:

When testing the contrasting pattern of a new customer is a PEP whose funds arrive from a closely held firm with undisclosed…, remember that objective descriptions help intelligence authorities assess the case without speculation. That would be a coherent mitigation for an AML team files a report that lists transaction values but fails to explain the suspected pattern…, whereas the immediate gap concerns a new customer is a PEP whose funds arrive from a closely held firm with undisclosed controllers.

B:

A controlled approach avoids accidental statutory noncompliance or unauthorized sharing; the observed record here instead involves a new customer is a PEP whose funds arrive from a closely held firm with undisclosed…. This safeguard targets a bank treats a voluntary interbank information request as an automatic section 314(a) government…; it does not directly remediate the process failure in a new customer is a PEP whose funds arrive from a closely held firm with undisclosed controllers.

C:

Against the reported situation in which a new customer is a PEP whose funds arrive from a closely held firm with undisclosed…, a holistic review should compare the pattern to expected behavior and reporting thresholds. That measure could be appropriate where a retail customer receives a series of unrelated inbound transfers and sends almost all funds…, but the described weakness is a new customer is a PEP whose funds arrive from a closely held firm with undisclosed controllers.

D:

The relevant alternative mechanism is different from a new customer is a PEP whose funds arrive from a closely held firm with undisclosed…: Procedures should prevent internal debate from creating missed legal deadlines. The intervention addresses a different exposure: a transaction monitoring alert is escalated after the legal deadline because investigators dispute…; the present case concerns a new customer is a PEP whose funds arrive from a closely held firm with undisclosed controllers.

E:

Compared with the stated facts about a new customer is a PEP whose funds arrive from a closely held firm with undisclosed…, coordination ensures operational incidents trigger compensating AFC safeguards. Its controls focus on operational risk owns vendor outages but never shares payment-data disruptions with AML monitoring, which would leave the observed problem of a new customer is a PEP whose funds arrive from a closely held firm with undisclosed controllers unresolved.

Question 513

The institution wants to reduce this specific exposure: A relationship manager changes customer occupation data after repeated alerts without an audit trail. What is the most appropriate control design?

  1. Align enterprise and sanctions assessments while preserving distinct risk drivers
  2. Restrict material profile edits and require independent review
  3. Apply specialized trade EDD and sanctions escalation before settlement
  4. Require layered ownership mapping and enhanced relationship approval
  5. Build controlled cross-risk referrals into scoring and investigations

Explanation

Correct Answer

B:

Segregation and audit trails help prevent business staff from concealing anomalies. The mechanism directly mitigates the stated exposure rather than a related but separate problem such as a high-risk subsidiary is included in the enterprise risk assessment but not in the….

Incorrect Answers

A:

The relevant alternative mechanism is different from a relationship manager changes customer occupation data after repeated alerts without…: Common data improves consistency but specialized risks require tailored analysis. Its controls focus on a high-risk subsidiary is included in the enterprise risk assessment but not in the…, which would leave the observed problem of a relationship manager changes customer occupation data after repeated alerts without an audit trail unresolved.

C:

This is not the central mechanism when a relationship manager changes customer occupation data after repeated alerts without…; tailored checks should address the nature of the goods and end-use route. This safeguard targets a trade client purchases dual-use machinery through several intermediary companies near a conflict…; it does not directly remediate the process failure in a relationship manager changes customer occupation data after repeated alerts without an audit trail.

D:

When testing the contrasting pattern of a relationship manager changes customer occupation data after repeated alerts without…, remember that the bank should establish control before treating legal entities as transparent. That measure could be appropriate where a complex group uses three layers of offshore holdings with trustee powers to redirect profits, but the described weakness is a relationship manager changes customer occupation data after repeated alerts without an audit trail.

E:

Sharing validated indicators improves awareness without treating every fraud alert as proven laundering; the observed record here instead involves a relationship manager changes customer occupation data after repeated alerts without…. The intervention addresses a different exposure: a fraud team sees mule-account patterns that the AML team never incorporates into customer risk…; the present case concerns a relationship manager changes customer occupation data after repeated alerts without an audit trail.

Question 514

A control-design team faces this gap: An FIU receives information suggesting an overseas account is connected to local predicate crime. Which tailored safeguard should it prioritize?

  1. Update relevant trade-risk scenarios and investigator guidance
  2. Use designated FIU cooperation channels for intelligence requests
  3. Expand geographical risk assessment to trade corridors and zones
  4. Document evidence standards before using private typology research

Explanation

Correct Answer

B:

Authorized sharing supports analysis while controlling further use and confidentiality. For the supported action of use designated fiu cooperation channels for intelligence requests in this risk mitigation review involving an FIU receives information suggesting an overseas account is connected to local predicate…, its scope matches this process, while the alternative would mainly address a regional FIU report identifies a new invoice-manipulation scheme involving the bank's….

Incorrect Answers

A:

This is not the central mechanism when an FIU receives information suggesting an overseas account is connected to local…; controls should evolve with substantiated typologies rather than remain limited to historic cases. That measure could be appropriate where a regional FIU report identifies a new invoice-manipulation scheme involving the bank's trade…, but the described weakness is an FIU receives information suggesting an overseas account is connected to local predicate crime.

C:

Scoring should capture where value and goods move, not just legal domicile; the observed record here instead involves an FIU receives information suggesting an overseas account is connected to local…. Its controls focus on a country identifies high exposure to trade-based laundering in free trade zones; a bank uses only…, which would leave the observed problem of an FIU receives information suggesting an overseas account is connected to local predicate crime unresolved.

D:

Against the reported situation in which an FIU receives information suggesting an overseas account is connected to local…, governance should separate well-supported observations from tentative assertions. That would be a coherent mitigation for a bank repeats industry research claims about laundering indicators without checking methodology or…, whereas the immediate gap concerns an FIU receives information suggesting an overseas account is connected to local predicate crime.

Question 515

This fact pattern is being incorporated into the AFC control inventory: A customer profile lists salary income but transactions show unusually large commercial receipts. Which measure directly addresses it?

  1. Build controlled cross-risk referrals into scoring and investigations
  2. Implement event-driven KYC refresh and ongoing customer review
  3. Trigger targeted CDD refresh and transaction review for behavior changes
  4. Obtain appropriate approvals and enhanced source-of-wealth review
  5. Escalate account exit through legal and AFC governance before closure

Explanation

Correct Answer

C:

A linked process investigates anomalies rather than automatically treating them as crime. Targeting the exposed workflow is more effective than deploying a measure intended for a fraud team sees mule-account patterns that the AML team never incorporates into customer….

Incorrect Answers

A:

Sharing validated indicators improves awareness without treating every fraud alert as proven laundering; the observed record here instead involves a customer profile lists salary income but transactions show unusually large…. That would be a coherent mitigation for a fraud team sees mule-account patterns that the AML team never incorporates into customer risk…, whereas the immediate gap concerns a customer profile lists salary income but transactions show unusually large commercial receipts.

B:

Against the reported situation in which a customer profile lists salary income but transactions show unusually large…, lifecycle controls should react to material changes, not only fixed anniversaries. This safeguard targets a risk team updates KYC at account opening but not after a complex customer changes ownership; it does not directly remediate the process failure in a customer profile lists salary income but transactions show unusually large commercial receipts.

D:

Compared with the stated facts about a customer profile lists salary income but transactions show unusually large…, governance should address both political influence and unexplained wealth accumulation. The intervention addresses a different exposure: a new customer is a PEP whose funds arrive from a closely held firm with undisclosed controllers; the present case concerns a customer profile lists salary income but transactions show unusually large commercial receipts.

E:

This is not the central mechanism when a customer profile lists salary income but transactions show unusually large…; coordinated decision-making balances customer risk with valid investigative requirements. Its controls focus on a bank closes an account under investigation without considering an authorized law-enforcement…, which would leave the observed problem of a customer profile lists salary income but transactions show unusually large commercial receipts unresolved.

Question 516

A risk owner seeks a focused response rather than blanket customer exclusion: A technology supplier with access to screening rules also sells services to a sanctioned-counterparty intermediary. Which option is best?

  1. Require layered ownership mapping and enhanced relationship approval
  2. Obtain appropriate approvals and enhanced source-of-wealth review
  3. Apply specialized trade EDD and sanctions escalation before settlement
  4. Apply vendor risk review, least-privilege access, and monitoring

Explanation

Correct Answer

D:

Access governance and conflict management reduce manipulation opportunities. Its scope matches this process, while the alternative would mainly address a complex group uses three layers of offshore holdings with trustee powers to redirect….

Incorrect Answers

A:

Against the reported situation in which a technology supplier with access to screening rules also sells services to a…, the bank should establish control before treating legal entities as transparent. This safeguard targets a complex group uses three layers of offshore holdings with trustee powers to redirect profits; it does not directly remediate the process failure in a technology supplier with access to screening rules also sells services to a….

B:

The relevant alternative mechanism is different from a technology supplier with access to screening rules also sells services to a…: Governance should address both political influence and unexplained wealth accumulation. That measure could be appropriate where a new customer is a PEP whose funds arrive from a closely held firm with undisclosed controllers, but the described weakness is a technology supplier with access to screening rules also sells services to a….

C:

Compared with the stated facts about a technology supplier with access to screening rules also sells services to a…, tailored checks should address the nature of the goods and end-use route. The intervention addresses a different exposure: a trade client purchases dual-use machinery through several intermediary companies near a conflict…; the present case concerns a technology supplier with access to screening rules also sells services to a….

Question 517

A control-design team faces this gap: A virtual-asset provider fails to exchange required originator and beneficiary information with another covered provider. Which tailored safeguard should it prioritize?

  1. Build interoperable counterparty-information exchange and exception handling
  2. Require linked-party checks for unusually clustered policy sales
  3. Apply proportionate identity tiers and linked-wallet monitoring
  4. Monitor seller-payout changes and unusually circular orders

Explanation

Correct Answer

A:

A process should obtain and transmit required data where local rules apply, with controlled failures. This intervention operates at the point where the reported weakness arises; an insurance broker proposes many single-premium policies purchased by entities with the… presents a different failure mode.

Incorrect Answers

B:

When testing the contrasting pattern of a virtual-asset provider fails to exchange required originator and beneficiary…, remember that monitoring should recognize shared controllers and intermediaries across multiple contracts. That would be a coherent mitigation for an insurance broker proposes many single-premium policies purchased by entities with the same…, whereas the immediate gap concerns a virtual-asset provider fails to exchange required originator and beneficiary information with….

C:

Controls should match transactional permissions to verified identity and observed activity; the observed record here instead involves a virtual-asset provider fails to exchange required originator and beneficiary…. This safeguard targets a digital-wallet provider allows unverified subaccounts to transfer balances repeatedly between…; it does not directly remediate the process failure in a virtual-asset provider fails to exchange required originator and beneficiary information with….

D:

Against the reported situation in which a virtual-asset provider fails to exchange required originator and beneficiary…, marketplace controls should assess legitimacy of trade before funds reach beneficiaries. That measure could be appropriate where a marketplace pays seller proceeds to newly added bank accounts after bursts of fabricated purchase…, but the described weakness is a virtual-asset provider fails to exchange required originator and beneficiary information with….

Question 518

A risk owner seeks a focused response rather than blanket customer exclusion: A trading company requests a letter of credit with documents inconsistent on port, cargo, and invoice amount. Which option is best?

  1. Escalate dual-use transactions for sanctions and end-use checks
  2. Apply partner due diligence and proportionate grant monitoring
  3. Conduct a documented risk-based PEP reassessment
  4. Require third-party payer scrutiny and delivery reconciliation
  5. Escalate material trade-document inconsistencies before settlement

Explanation

Correct Answer

E:

Control points must address trade substance rather than accepting facially complete papers. The control is aligned with the actual failure in a trading company requests a letter of credit with documents inconsistent on port, cargo, and invoice…; safeguards designed for a licensed firearms wholesaler ships dual-use components to newly created intermediaries… would not close that gap.

Incorrect Answers

A:

Against the reported situation in which a trading company requests a letter of credit with documents inconsistent on port,…, specialist review should integrate ownership, goods and destination rather than price alone. This safeguard targets a licensed firearms wholesaler ships dual-use components to newly created intermediaries with…; it does not directly remediate the process failure in a trading company requests a letter of credit with documents inconsistent on port, cargo, and….

B:

The relevant alternative mechanism is different from a trading company requests a letter of credit with documents inconsistent on port,…: A risk-sensitive arrangement can preserve assistance while managing diversion and TF risk. That measure could be appropriate where a relief organization routes grants to an unverified local partner in an active conflict area, but the described weakness is a trading company requests a letter of credit with documents inconsistent on port, cargo, and….

C:

Compared with the stated facts about a trading company requests a letter of credit with documents inconsistent on port,…, the institution should adjust due diligence using credible evidence of remaining influence. The intervention addresses a different exposure: a former senior politician retains influence over a state-owned enterprise through close associates; the present case concerns a trading company requests a letter of credit with documents inconsistent on port, cargo, and….

D:

This is not the central mechanism when a trading company requests a letter of credit with documents inconsistent on port,…; controls should link each payment to a genuine purchaser and documented commodity sale. Its controls focus on a precious-metals dealer receives repeated third-party deposits without links to purchased bullion, which would leave the observed problem of a trading company requests a letter of credit with documents inconsistent on port, cargo, and… unresolved.

Question 519

For this identified exposure, a retail customer receives a series of unrelated inbound transfers and sends almost all funds overseas immediately. Choose TWO complementary steps: one targeted safeguard and one test of its operation.

  1. Verify end users, product classification, ownership, and shipping routes
  2. Sample PEP accounts for ownership verification and approval evidence
  3. Check linked-transfer alerts for consistent investigation and disposition
  4. Open a documented relationship-level unusual-activity investigation
  5. Apply vendor risk review, least-privilege access, and monitoring

Explanation

Correct Answers

C:

Testing validates that connected inflows and outflows are analyzed together. It produces control-performance evidence about a retail customer receives a series of unrelated inbound transfers and sends almost all funds overseas…; a documented plan alone would not prove operation.

D:

A holistic review should compare the pattern to expected behavior and reporting thresholds. It addresses the live exposure in a retail customer receives a series of unrelated inbound transfers and sends almost all funds overseas…; corrective action is not a substitute for verifying its operation.

Incorrect Answers

A:

Compared with the stated facts about a retail customer receives a series of unrelated inbound transfers and sends almost…, the combined evidence is required to assess actual restricted-use exposure. The inquiry is suited to a trade client purchases dual-use machinery through several intermediary companies near a conflict…; the requested evidence must instead address a retail customer receives a series of unrelated inbound transfers and sends almost all funds…. For the alternative option of verify end users, product classification, ownership, and shipping routes in this risk mitigation review involving a retail customer receives a series of unrelated inbound transfers and sends almost all funds…, a two-part remediation plan for a retail customer receives a series of unrelated inbound transfers and sends almost… needs an issue-specific safeguard and proof that it operates, not this unrelated step.

B:

This is not the central mechanism when a retail customer receives a series of unrelated inbound transfers and sends almost…; the review tests whether heightened scrutiny is substantive. The test exercises an adjacent pathway, a new customer is a PEP whose funds arrive from a closely held firm with undisclosed controllers, without directly challenging a retail customer receives a series of unrelated inbound transfers and sends almost all funds…. For the alternative option of sample pep accounts for ownership verification and approval evidence in this risk mitigation review involving a retail customer receives a series of unrelated inbound transfers and sends almost all funds…, a two-part remediation plan for a retail customer receives a series of unrelated inbound transfers and sends almost… needs an issue-specific safeguard and proof that it operates, not this unrelated step.

E:

Against the reported situation in which a retail customer receives a series of unrelated inbound transfers and sends almost…, access governance and conflict management reduce manipulation opportunities. This safeguard targets a technology supplier with access to screening rules also sells services to a…; it does not directly remediate the process failure in a retail customer receives a series of unrelated inbound transfers and sends almost all funds…. For the alternative option of apply vendor risk review, least-privilege access, and monitoring in this risk mitigation review involving a retail customer receives a series of unrelated inbound transfers and sends almost all funds…, a two-part remediation plan for a retail customer receives a series of unrelated inbound transfers and sends almost… needs an issue-specific safeguard and proof that it operates, not this unrelated step.

Question 520

An AFC remediation plan must both address this gap and demonstrate effectiveness: A vendor's watchlist feed stops updating for four days while payment processing continues. Choose TWO actions that together accomplish that.

  1. Sample enrichment hits for correct person, source quality, and currency
  2. Combine biometric matching with liveness and identity-document validation
  3. Simulate missed feed updates and verify operational escalation
  4. Review current corporate filings, acquisition records, and customer declarations
  5. Implement feed freshness alerts, reconciliation, and release gates

Explanation

Correct Answers

C:

For the supported action of simulate missed feed updates and verify operational escalation in this risk mitigation review involving a vendor's watchlist feed stops updating for four days while payment processing continues, assurance checks whether the institution responds before stale data becomes prolonged exposure. It produces control-performance evidence about a vendor's watchlist feed stops updating for four days while payment processing continues; a documented plan alone would not prove operation.

E:

Critical list updates should be traceable and exceptions should trigger risk decisions. It addresses the live exposure in a vendor's watchlist feed stops updating for four days while payment processing continues; corrective action is not a substitute for verifying its operation.

Incorrect Answers

A:

Against the reported situation in which a vendor's watchlist feed stops updating for four days while payment processing…, assurance gauges mistaken identity and stale information separately. Even a favorable result for a bank buys adverse-media data but cannot explain which persons its records actually match would not demonstrate the control works when a vendor's watchlist feed stops updating for four days while payment processing continues. For the alternative option of sample enrichment hits for correct person, source quality, and currency in this risk mitigation review involving a vendor's watchlist feed stops updating for four days while payment processing continues, a two-part remediation plan for a vendor's watchlist feed stops updating for four days while payment processing… needs an issue-specific safeguard and proof that it operates, not this unrelated step.

B:

The relevant alternative mechanism is different from a vendor's watchlist feed stops updating for four days while payment processing…: A layered approach reduces spoofing risk without assuming biometrics prove identity on their own. That would be a coherent mitigation for a remote account applicant uses a high-quality printed face photograph to defeat a simple selfie…, whereas the immediate gap concerns a vendor's watchlist feed stops updating for four days while payment processing continues. For the alternative option of combine biometric matching with liveness and identity-document validation in this risk mitigation review involving a vendor's watchlist feed stops updating for four days while payment processing continues, a two-part remediation plan for a vendor's watchlist feed stops updating for four days while payment processing… needs an issue-specific safeguard and proof that it operates, not this unrelated step.

D:

This is not the central mechanism when a vendor's watchlist feed stops updating for four days while payment processing…; cross-source comparison identifies differences requiring further verification. The inquiry is suited to an onboarding system relies on a beneficial-ownership register that has not been updated following…; the requested evidence must instead address a vendor's watchlist feed stops updating for four days while payment processing continues. For the alternative option of review current corporate filings, acquisition records, and customer declarations in this risk mitigation review involving a vendor's watchlist feed stops updating for four days while payment processing continues, a two-part remediation plan for a vendor's watchlist feed stops updating for four days while payment processing… needs an issue-specific safeguard and proof that it operates, not this unrelated step.

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