ACAMS CAMS (Certified Anti-Money Laundering Specialist (the 6th edition)) Practice Test 70

Question 690

The following risk prompted a control change: A precious-metals dealer receives repeated third-party deposits without links to purchased bullion. How should the institution confirm the control detects or prevents it?

  1. Test event-driven PEP updates against new public appointments
  2. Sample payment-to-delivery chains and unexplained funders
  3. Test collateral files for independent provenance and valuation proof
  4. Audit nominee files for documented control and escalation decisions

Explanation

Correct Answer

B:

The test exposes unsupported funding that a simple invoice check can miss. This test provides observable evidence about the affected process; a test focused on a client's brother becomes a senior procurement official and a related company receives… would not establish the same result.

Incorrect Answers

A:

This is not the central mechanism when a precious-metals dealer receives repeated third-party deposits without links to…; a working control will flag materially changed exposure and trigger appropriate review. Even a favorable result for a client's brother becomes a senior procurement official and a related company receives government… would not demonstrate the control works when a precious-metals dealer receives repeated third-party deposits without links to purchased bullion.

C:

A complete trail should support ownership and explain the scale of the pledged wealth; the observed record here instead involves a precious-metals dealer receives repeated third-party deposits without links to…. Testing this would validate controls for a private-banking client pledges opaque offshore holdings as collateral for unusually large credit…, not the effectiveness of remediation for a precious-metals dealer receives repeated third-party deposits without links to purchased bullion.

D:

Against the reported situation in which a precious-metals dealer receives repeated third-party deposits without links to…, the test focuses on who actually directs the entity, not just the shareholder register. The sample would be probative if a high-risk client uses a nominee shareholder whose instructions come from an unidentified…; a different population and test are needed for a precious-metals dealer receives repeated third-party deposits without links to purchased bullion.

Question 691

The following risk prompted a control change: A transaction-monitoring rule detects individual large transfers but misses repeated low-value transfers to one beneficiary. How should the institution confirm the control detects or prevents it?

  1. Sample OSINT assertions for verifiable sources and dated captures
  2. Test benign shared-IP clusters for false positive network formation
  3. Replay split-payment datasets and evaluate linked alert generation
  4. Compare model detection and drift against controlled benchmark cases

Explanation

Correct Answer

C:

Testing verifies detection of dispersed events below individual thresholds. The proposed sample exercises the failure seen in a transaction-monitoring rule detects individual large transfers but misses repeated low-value transfers…, rather than the separate pathway represented by investigators copy public social-media information into cases without recording where or….

Incorrect Answers

A:

This is not the central mechanism when a transaction-monitoring rule detects individual large transfers but misses repeated…; the test distinguishes investigative evidence from unsupported summaries. The test exercises an adjacent pathway, investigators copy public social-media information into cases without recording where or when they…, without directly challenging a transaction-monitoring rule detects individual large transfers but misses repeated low-value….

B:

When testing the contrasting pattern of a transaction-monitoring rule detects individual large transfers but misses repeated…, remember that assurance checks that weak links do not dominate suspicious-group classification. Even a favorable result for a graph model flags every customer sharing a common public IP address as a criminal network would not demonstrate the control works when a transaction-monitoring rule detects individual large transfers but misses repeated low-value….

D:

Against the reported situation in which a transaction-monitoring rule detects individual large transfers but misses repeated…, the test checks performance, explainability, and stability after deployment. Testing this would validate controls for a bank replaces every rules-based alert with a machine-learning score without evaluating…, not the effectiveness of remediation for a transaction-monitoring rule detects individual large transfers but misses repeated low-value….

Question 692

Independent assurance must evaluate an issue originally found as follows: A nonprofit training group claims authority to impose national AML penalties because it publishes research. What validation would most directly test effectiveness?

  1. Review cross-border disclosures for validated authority and data minimization
  2. Audit policy citations for source authority and legal status
  3. Test screening lists against effective local and UN update timelines
  4. Sample trade payments for prohibited product and destination flags

Explanation

Correct Answer

B:

The test prevents a private report from being treated as a regulator's directive. Operating-effectiveness evidence must reach the specific control gap here; a fraud analyst sends customer data to overseas police on an informal personal email request would require a different test.

Incorrect Answers

A:

Against the reported situation in which a nonprofit training group claims authority to impose national AML penalties because…, testing can reveal informal transfers unsupported by applicable safeguards. The sample would be probative if a fraud analyst sends customer data to overseas police on an informal personal email request; a different population and test are needed for a nonprofit training group claims authority to impose national AML penalties because it publishes….

C:

Compared with the stated facts about a nonprofit training group claims authority to impose national AML penalties because…, assurance checks whether legally operative changes reach payment controls promptly. Even a favorable result for a payments team assumes every UN Security Council sanctions resolution becomes locally enforceable… would not demonstrate the control works when a nonprofit training group claims authority to impose national AML penalties because it publishes….

D:

This is not the central mechanism when a nonprofit training group claims authority to impose national AML penalties because…; control testing demonstrates that embargoed activity is found even without a listed party. This assurance method targets a branch screens sanctioned party names but overlooks a UN embargo relating to a category of… rather than the reported process: a nonprofit training group claims authority to impose national AML penalties because it publishes….

Question 693

The AFC team needs to demonstrate sustained remediation for the following weakness: A legal adviser forms companies for a client while refusing to disclose the person providing instructions. Which validation is appropriate?

  1. Reconstruct title transfers and sale proceeds for sampled parcels
  2. Audit sale files for provenance and consistent settlement parties
  3. Review gatekeeper files for natural-person controllers and exceptions
  4. Sample nominee-led transactions for documented instruction sources
  5. Audit distributions against verified beneficiary and amendment records
  6. Check client-account payments against verified underlying buyer records

Explanation

Correct Answer

C:

Testing should verify that reliance on professional status has not displaced CDD. The proposed sample exercises the failure seen in a legal adviser forms companies for a client while refusing to disclose the person providing instructions, rather than the separate pathway represented by a land developer rapidly sells the same parcel among related entities at escalating prices.

Incorrect Answers

A:

The relevant alternative mechanism is different from a legal adviser forms companies for a client while refusing to disclose the person…: Testing exposes circular value creation even when each deed is formally registered. The test exercises an adjacent pathway, a land developer rapidly sells the same parcel among related entities at escalating prices, without directly challenging a legal adviser forms companies for a client while refusing to disclose the person providing….

B:

Compared with the stated facts about a legal adviser forms companies for a client while refusing to disclose the person…, testing reveals whether payments were accepted without linking actual buyer to artwork. Even a favorable result for an art dealer receives payment for a sculpture from a different offshore buyer than the invoice… would not demonstrate the control works when a legal adviser forms companies for a client while refusing to disclose the person providing….

D:

When testing the contrasting pattern of a legal adviser forms companies for a client while refusing to disclose the person…, remember that assurance confirms whether hidden controllers are surfaced for risk assessment. Testing this would validate controls for a nominee director signs transactions on instruction from an undisclosed offshore client, not the effectiveness of remediation for a legal adviser forms companies for a client while refusing to disclose the person providing….

E:

The check tests whether actual payments match authorized trust relationships; the observed record here instead involves a legal adviser forms companies for a client while refusing to disclose the person…. The sample would be probative if a trustee directs distributions to beneficiaries omitted from a family's original trust…; a different population and test are needed for a legal adviser forms companies for a client while refusing to disclose the person providing….

F:

Against the reported situation in which a legal adviser forms companies for a client while refusing to disclose the person…, the assurance review tests whether opaque settlements are identified before closing. The test exercises an adjacent pathway, an overseas investor uses a lawyer's client account to settle a property purchase without naming…, without directly challenging a legal adviser forms companies for a client while refusing to disclose the person providing….

Question 694

A remediation is marked complete for this case: A digital-wallet provider allows unverified subaccounts to transfer balances repeatedly between devices. Which operational test would best challenge that claim?

  1. Reconstruct pooled entries and exits to natural-person investors
  2. Test alerts for newly introduced high-risk external wallet addresses
  3. Test high-velocity wallet chains for traceable endpoints
  4. Reconcile token burns with verified fiat redemptions and approved payees

Explanation

Correct Answer

C:

The assurance review should expose anonymity gaps in account-to-account transfers. The proposed sample exercises the failure seen in a digital-wallet provider allows unverified subaccounts to transfer balances repeatedly between devices, rather than the separate pathway represented by a pooled investment vehicle permits rapid subscriptions and redemptions through several….

Incorrect Answers

A:

When testing the contrasting pattern of a digital-wallet provider allows unverified subaccounts to transfer balances…, remember that the review tests whether the fund can trace who provided and received value. The test exercises an adjacent pathway, a pooled investment vehicle permits rapid subscriptions and redemptions through several offshore…, without directly challenging a digital-wallet provider allows unverified subaccounts to transfer balances repeatedly between….

B:

Validation should consider address changes and behavioral risk, not only known exchange labels; the observed record here instead involves a digital-wallet provider allows unverified subaccounts to transfer balances…. Even a favorable result for a trading platform repeatedly sends virtual assets to an unhosted address controlled by an… would not demonstrate the control works when a digital-wallet provider allows unverified subaccounts to transfer balances repeatedly between….

D:

The relevant alternative mechanism is different from a digital-wallet provider allows unverified subaccounts to transfer balances…: Testing links on-chain events with actual fund recipients and settlement evidence. Testing this would validate controls for a virtual-asset custodian processes large stablecoin redemptions through offshore issuers with weak…, not the effectiveness of remediation for a digital-wallet provider allows unverified subaccounts to transfer balances repeatedly between….

Question 695

A financial-crime team must corroborate the concern, implement a specific safeguard, and verify that safeguard after this event: A country identifies high exposure to trade-based laundering in free trade zones; a bank uses only residency to rate corporate clients. Choose THREE steps that satisfy those three different needs.

  1. Expand geographical risk assessment to trade corridors and zones
  2. Collect shipping-route, counterparty, and free-zone activity data
  3. Publish locally approved reporting and escalation calendars
  4. Test samples where trade routes diverge from registered addresses
  5. Audit US submissions against applicable FinCEN triggers and deadlines
  6. Check EU legal acts, entry-into-force provisions, and national implementation schedules

Explanation

Correct Answers

A:

Scoring should capture where value and goods move, not just legal domicile. It addresses the live exposure in a country identifies high exposure to trade-based laundering in free trade zones; a bank uses only residency…; corrective action is not a substitute for verifying its operation.

B:

Operational geography reveals exposures hidden by incorporation data. It supplies corroborating evidence about a country identifies high exposure to trade-based laundering in free trade zones; a bank uses only residency…; investigation is distinct from implementing or testing a safeguard.

D:

An effective method detects exposure that residency-only logic would miss. It produces control-performance evidence about a country identifies high exposure to trade-based laundering in free trade zones; a bank uses only residency…; a documented plan alone would not prove operation.

Incorrect Answers

C:

This is not the central mechanism when a country identifies high exposure to trade-based laundering in free trade zones; a…; a global standard should be adapted to each authority's binding requirements. The intervention addresses a different exposure: a local compliance team automatically applies US suspicious-activity deadlines to an EU subsidiary; the present case concerns a country identifies high exposure to trade-based laundering in free trade zones; a bank uses only…. For the alternative option of publish locally approved reporting and escalation calendars in this effectiveness test review involving a country identifies high exposure to trade-based laundering in free trade zones; a bank uses…, for a country identifies high exposure to trade-based laundering in free trade zones; a…, corroboration, targeted correction, and assurance must all relate to the same failure.

E:

Assurance confirms correct legal regime rather than general resemblance to foreign rules; the observed record here instead involves a country identifies high exposure to trade-based laundering in free trade zones; a…. This assurance method targets a US branch relies on European transaction reporting rules to set its US suspicious-activity filing… rather than the reported process: a country identifies high exposure to trade-based laundering in free trade zones; a bank uses only…. For the alternative option of audit us submissions against applicable fincen triggers and deadlines in this effectiveness test review involving a country identifies high exposure to trade-based laundering in free trade zones; a bank uses…, for a country identifies high exposure to trade-based laundering in free trade zones; a…, corroboration, targeted correction, and assurance must all relate to the same failure.

F:

Against the reported situation in which a country identifies high exposure to trade-based laundering in free trade zones; a…, the timing and scope of obligations matter more than the publication date alone. That review would be useful if an EU financial group assumes a policy written before the 2024 AML regulatory package will remain…, 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…. For the alternative option of check eu legal acts, entry-into-force provisions, and national implementation schedules in this effectiveness test review involving a country identifies high exposure to trade-based laundering in free trade zones; a bank uses…, for a country identifies high exposure to trade-based laundering in free trade zones; a…, corroboration, targeted correction, and assurance must all relate to the same failure.

Question 696

The compliance team introduces remediation for this weakness: A bank independently records KYC changes in three tools but does not synchronize customer risk classifications. Which evidence best shows it is functioning?

  1. Replay known time-ordered payments through the normalized data pipeline
  2. Validate mapped ownership values against original evidence across systems
  3. Test profile changes for propagation and downstream risk recalculation
  4. Test rejected-message recovery with record-count and amount reconciliation

Explanation

Correct Answer

C:

The review checks whether updates reach all systems that rely on customer classification. Success on this scenario would be relevant to the original failure, whereas a monitoring engine receives transaction dates as free-form strings and misorders transfers… tests a different exposure.

Incorrect Answers

A:

The relevant alternative mechanism is different from a bank independently records KYC changes in three tools but does not synchronize…: Tests should detect sequencing errors before alerts rely on corrupted timestamps. This assurance method targets a monitoring engine receives transaction dates as free-form strings and misorders transfers across… rather than the reported process: a bank independently records KYC changes in three tools but does not synchronize customer risk….

B:

Compared with the stated facts about a bank independently records KYC changes in three tools but does not synchronize…, assurance checks that normalized fields retain accurate real-world control information. Testing this would validate controls for different businesses label the same beneficial-owner field as shareholder, controller, or principal…, not the effectiveness of remediation for a bank independently records KYC changes in three tools but does not synchronize customer risk….

D:

When testing the contrasting pattern of a bank independently records KYC changes in three tools but does not synchronize…, remember that the test proves that no relevant payment disappears silently from monitoring. The test exercises an adjacent pathway, a data warehouse silently drops payment records that fail a new schema validation rule, without directly challenging a bank independently records KYC changes in three tools but does not synchronize customer risk….

Question 697

An examiner questions whether a revised procedure works after this event: An institution sends a suspicious-activity report directly to a customer to explain a payment delay. Which test directly addresses the event?

  1. Sample customer contacts around filed reports for prohibited disclosures
  2. Test exception decisions for implementation and overdue action follow-up
  3. Test outages for timely AML impact assessment and backlog recovery
  4. Audit media referrals for completion of documented compliance review
  5. Trace reported metrics back to case management and source systems
  6. Run seeded sanctioned-name tests before and after threshold changes

Explanation

Correct Answer

A:

The test checks that staff maintain legal confidentiality while handling inquiries. The proposed sample exercises the failure seen in an institution sends a suspicious-activity report directly to a customer to explain a payment delay, rather than the separate pathway represented by a board committee receives repeated high-risk onboarding exceptions without documented….

Incorrect Answers

B:

The relevant alternative mechanism is different from an institution sends a suspicious-activity report directly to a customer to explain a…: Assurance detects a committee that merely notes risks. This assurance method targets a board committee receives repeated high-risk onboarding exceptions without documented challenge or… rather than the reported process: an institution sends a suspicious-activity report directly to a customer to explain a payment delay.

C:

Compared with the stated facts about an institution sends a suspicious-activity report directly to a customer to explain a…, assurance shows whether dependent financial-crime controls received attention. Testing this would validate controls for operational risk owns vendor outages but never shares payment-data disruptions with AML monitoring, not the effectiveness of remediation for an institution sends a suspicious-activity report directly to a customer to explain a payment delay.

D:

This is not the central mechanism when an institution sends a suspicious-activity report directly to a customer to explain a…; testing verifies closure of the intelligence-to-decision path. The sample would be probative if a reputational-risk team discovers adverse media about a major customer but does not inform…; a different population and test are needed for an institution sends a suspicious-activity report directly to a customer to explain a payment delay.

E:

When testing the contrasting pattern of an institution sends a suspicious-activity report directly to a customer to explain a…, remember that validation checks completeness, definitions, and accuracy of the board pack. The test exercises an adjacent pathway, a board pack reports alert volumes but omits false positives, overdue cases, and filing timeliness, without directly challenging an institution sends a suspicious-activity report directly to a customer to explain a payment delay.

F:

The test provides direct evidence of sensitivity rather than relying on volume alone; the observed record here instead involves an institution sends a suspicious-activity report directly to a customer to explain a…. Even a favorable result for a bank celebrates a decline in sanctions alerts after a vendor changes matching sensitivity would not demonstrate the control works when an institution sends a suspicious-activity report directly to a customer to explain a payment delay.

Question 698

An examiner questions whether a revised procedure works after this event: A bank opens a payable-through correspondent arrangement but cannot identify the foreign bank's downstream users. Which test directly addresses the event?

  1. Test event-driven PEP updates against new public appointments
  2. Test that prohibited end-use scenarios trigger specialist holds
  3. Check whether PEP downgrades considered influence and associated parties
  4. Sample respondent payments for originator and beneficiary visibility

Explanation

Correct Answer

D:

An effectiveness test confirms whether downstream activity can be identified and escalated. The proposed sample exercises the failure seen in a bank opens a payable-through correspondent arrangement but cannot identify the foreign bank's…, rather than the separate pathway represented by a client's brother becomes a senior procurement official and a related company receives….

Incorrect Answers

A:

Against the reported situation in which a bank opens a payable-through correspondent arrangement but cannot identify the…, a working control will flag materially changed exposure and trigger appropriate review. This assurance method targets a client's brother becomes a senior procurement official and a related company receives government… rather than the reported process: a bank opens a payable-through correspondent arrangement but cannot identify the foreign bank's….

B:

The relevant alternative mechanism is different from a bank opens a payable-through correspondent arrangement but cannot identify the…: The control should respond to product and beneficiary red flags even without list-name matches. Testing this would validate controls for a licensed firearms wholesaler ships dual-use components to newly created intermediaries with…, not the effectiveness of remediation for a bank opens a payable-through correspondent arrangement but cannot identify the foreign bank's….

C:

Compared with the stated facts about a bank opens a payable-through correspondent arrangement but cannot identify the…, controls should resist automatic removals based only on a departure date. The sample would be probative if a former senior politician retains influence over a state-owned enterprise through close associates; a different population and test are needed for a bank opens a payable-through correspondent arrangement but cannot identify the foreign bank's….

Question 699

An examiner questions whether a revised procedure works after this event: A small nonprofit receives the same level of documentation demands as a complex offshore corporate group. Which test directly addresses the event?

  1. Test low- and high-risk cases for proportionate control application
  2. Walk through PEP cases to verify staff can follow documented steps
  3. Challenge high-effectiveness ratings against unresolved audit findings
  4. Recalculate sample scores to verify controls affect only residual risk

Explanation

Correct Answer

A:

Assurance identifies both excessive friction and insufficient enhanced scrutiny. The assessment probes the affected transactions and decisions, not just an adjacent risk such as a policy requires EDD for foreign PEPs but staff cannot find the corresponding review steps.

Incorrect Answers

B:

The relevant alternative mechanism is different from a small nonprofit receives the same level of documentation demands as a complex…: Assurance tests practical execution rather than policy availability. Even a favorable result for a policy requires EDD for foreign PEPs but staff cannot find the corresponding review steps would not demonstrate the control works when a small nonprofit receives the same level of documentation demands as a complex offshore corporate….

C:

Compared with the stated facts about a small nonprofit receives the same level of documentation demands as a complex…, the review checks for credible evidence supporting risk reductions. This assurance method targets a bank uses the number of written AML policies as proof that residual risk is low rather than the reported process: a small nonprofit receives the same level of documentation demands as a complex offshore corporate….

D:

This is not the central mechanism when a small nonprofit receives the same level of documentation demands as a complex…; testing detects models that double-count or hide mitigation. Testing this would validate controls for a bank calculates inherent country risk after deducting the effectiveness of its screening controls, not the effectiveness of remediation for a small nonprofit receives the same level of documentation demands as a complex offshore corporate….

Question 700

Quality assurance is reviewing a remediation plan for this situation: A bank responds to a law-enforcement subpoena by providing unrelated records outside the requested period. Which sample or test is most useful?

  1. Audit staff referrals for preservation, timeliness, and case linkage
  2. Sample retained high-risk clients for condition compliance and escalation
  3. Audit high-risk exits for committee approval and documented rationale
  4. Compare segment outcomes before and after risk-based changes
  5. Audit productions against the request and approval inventory
  6. Review sent RFIs for scope, tone, and confidentiality compliance

Explanation

Correct Answer

E:

Assurance detects overproduction, omissions, and unexplained transfers. This test provides observable evidence about the affected process; a test focused on an employee reports a customer attempting to suppress questions about repeated third-party… would not establish the same result.

Incorrect Answers

A:

When testing the contrasting pattern of a bank responds to a law-enforcement subpoena by providing unrelated records outside…, remember that the test checks whether frontline observations enter formal investigations. This assurance method targets an employee reports a customer attempting to suppress questions about repeated third-party cash… rather than the reported process: a bank responds to a law-enforcement subpoena by providing unrelated records outside the requested….

B:

Testing checks that governance decisions actually alter ongoing controls; the observed record here instead involves a bank responds to a law-enforcement subpoena by providing unrelated records outside…. Testing this would validate controls for a customer is retained despite repeated unresolved suspicious transactions because revenue targets…, not the effectiveness of remediation for a bank responds to a law-enforcement subpoena by providing unrelated records outside the requested….

C:

Against the reported situation in which a bank responds to a law-enforcement subpoena by providing unrelated records outside…, assurance can reveal inconsistent or unauthorized account closures. The sample would be probative if a bank decides to exit a high-risk customer while two divisions disagree about who has approval…; a different population and test are needed for a bank responds to a law-enforcement subpoena by providing unrelated records outside the requested….

D:

The relevant alternative mechanism is different from a bank responds to a law-enforcement subpoena by providing unrelated records outside…: Testing evaluates whether targeted safeguards preserve control effectiveness and access. The test exercises an adjacent pathway, an MSB withdraws from an entire remittance corridor after isolated suspicious cases without…, without directly challenging a bank responds to a law-enforcement subpoena by providing unrelated records outside the requested….

F:

This is not the central mechanism when a bank responds to a law-enforcement subpoena by providing unrelated records outside…; the check tests both information quality and communications risk. This assurance method targets an investigator requests business documents through a customer-facing team using an accusatory… rather than the reported process: a bank responds to a law-enforcement subpoena by providing unrelated records outside the requested….

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