ACAMS CAMS (Certified Anti-Money Laundering Specialist (the 6th edition)) Practice Test 73

Question 720

For this identified exposure, a bank decides to exit a high-risk customer while two divisions disagree about who has approval authority. Choose TWO complementary steps: one targeted safeguard and one test of its operation.

  1. Route material exits through approved multidisciplinary governance
  2. Inspect vendor ownership, personnel access, and conflicting engagements
  3. Audit high-risk exits for committee approval and documented rationale
  4. Test material overrides for AFC review and management escalation
  5. Test sensitive profile changes for provenance and dual authorization
  6. Obtain appropriate approvals and enhanced source-of-wealth review

Explanation

Correct Answers

A:

For the supported action of route material exits through approved multidisciplinary governance in this effectiveness test review involving a bank decides to exit a high-risk customer while two divisions disagree about who has…, compliance, legal, and business functions should make accountable and appropriately timed decisions. It addresses the live exposure in a bank decides to exit a high-risk customer while two divisions disagree about who has approval authority; corrective action is not a substitute for verifying its operation.

C:

Assurance can reveal inconsistent or unauthorized account closures. It produces control-performance evidence about a bank decides to exit a high-risk customer while two divisions disagree about who has approval authority; a documented plan alone would not prove operation.

Incorrect Answers

B:

This is not the central mechanism when a bank decides to exit a high-risk customer while two divisions disagree about who…; due diligence should establish who can change sensitive configurations and why. It seeks evidence about a technology supplier with access to screening rules also sells services to a…; the allegation under review instead involves a bank decides to exit a high-risk customer while two divisions disagree about who has approval…. For the alternative option of inspect vendor ownership, personnel access, and conflicting engagements in this effectiveness test review involving a bank decides to exit a high-risk customer while two divisions disagree about who has…, a two-part remediation plan for a bank decides to exit a high-risk customer while two divisions disagree about who… needs an issue-specific safeguard and proof that it operates, not this unrelated step.

D:

Assurance confirms that reporting lines do not impair compliance decisions; the observed record here instead involves a bank decides to exit a high-risk customer while two divisions disagree about who…. The sample would be probative if a growing bank moves AFC analysts into a sales reporting chain without clear conflict safeguards; a different population and test are needed for a bank decides to exit a high-risk customer while two divisions disagree about who has approval…. For the alternative option of test material overrides for afc review and management escalation in this effectiveness test review involving a bank decides to exit a high-risk customer while two divisions disagree about who has…, a two-part remediation plan for a bank decides to exit a high-risk customer while two divisions disagree about who… needs an issue-specific safeguard and proof that it operates, not this unrelated step.

E:

Against the reported situation in which a bank decides to exit a high-risk customer while two divisions disagree about who…, assurance should uncover silent rewrites of monitoring inputs. The test exercises an adjacent pathway, a relationship manager changes customer occupation data after repeated alerts without an audit trail, without directly challenging a bank decides to exit a high-risk customer while two divisions disagree about who has approval…. For the alternative option of test sensitive profile changes for provenance and dual authorization in this effectiveness test review involving a bank decides to exit a high-risk customer while two divisions disagree about who has…, a two-part remediation plan for a bank decides to exit a high-risk customer while two divisions disagree about who… needs an issue-specific safeguard and proof that it operates, not this unrelated step.

F:

The relevant alternative mechanism is different from a bank decides to exit a high-risk customer while two divisions disagree about who…: Governance should address both political influence and unexplained wealth accumulation. Its controls focus on a new customer is a PEP whose funds arrive from a closely held firm with undisclosed controllers, which would leave the observed problem of a bank decides to exit a high-risk customer while two divisions disagree about who has approval… unresolved. For the alternative option of obtain appropriate approvals and enhanced source-of-wealth review in this effectiveness test review involving a bank decides to exit a high-risk customer while two divisions disagree about who has…, a two-part remediation plan for a bank decides to exit a high-risk customer while two divisions disagree about who… needs an issue-specific safeguard and proof that it operates, not this unrelated step.

Question 721

The AFC team needs to demonstrate sustained remediation for the following weakness: A board committee receives repeated high-risk onboarding exceptions without documented challenge or outcomes. Which validation is appropriate?

  1. Resample reviewed cases after training for sustained error reduction
  2. Audit regulatory alerts through implementation and staff communication
  3. Test sampled policies for version control and legal sign-off
  4. Run seeded sanctioned-name tests before and after threshold changes
  5. Test exception decisions for implementation and overdue action follow-up

Explanation

Correct Answer

E:

Assurance detects a committee that merely notes risks. For the supported action of test exception decisions for implementation and overdue action follow-up in this effectiveness test review involving a board committee receives repeated high-risk onboarding exceptions without documented…, success on this scenario would be relevant to the original failure, whereas management counts completed training modules without checking repeated analyst errors tests a different exposure.

Incorrect Answers

A:

The relevant alternative mechanism is different from a board committee receives repeated high-risk onboarding exceptions without…: Assurance checks behavior change rather than attendance. Even a favorable result for management counts completed training modules without checking repeated analyst errors would not demonstrate the control works when a board committee receives repeated high-risk onboarding exceptions without documented challenge or….

B:

Compared with the stated facts about a board committee receives repeated high-risk onboarding exceptions without…, testing finds changes that were read but never operationalized. This assurance method targets an AFC policy remains unchanged despite a regulator's new guidance on high-risk digital payments rather than the reported process: a board committee receives repeated high-risk onboarding exceptions without documented challenge or….

C:

This is not the central mechanism when a board committee receives repeated high-risk onboarding exceptions without…; assurance checks that outsourced text is not treated as inherently compliant. Testing this would validate controls for a bank adopts a vendor's proposed policy wording without review of local reporting law, not the effectiveness of remediation for a board committee receives repeated high-risk onboarding exceptions without documented challenge or….

D:

When testing the contrasting pattern of a board committee receives repeated high-risk onboarding exceptions without…, remember that the test provides direct evidence of sensitivity rather than relying on volume alone. The sample would be probative if a bank celebrates a decline in sanctions alerts after a vendor changes matching sensitivity; a different population and test are needed for a board committee receives repeated high-risk onboarding exceptions without documented challenge or….

Question 722

The compliance team introduces remediation for this weakness: Operational risk owns vendor outages but never shares payment-data disruptions with AML monitoring. Which evidence best shows it is functioning?

  1. Trace reported metrics back to case management and source systems
  2. Sample customer contacts around filed reports for prohibited disclosures
  3. Test outages for timely AML impact assessment and backlog recovery
  4. Test country files for correct report recipients and timing

Explanation

Correct Answer

C:

Assurance shows whether dependent financial-crime controls received attention. The assessment probes the affected transactions and decisions, not just an adjacent risk such as a board pack reports alert volumes but omits false positives, overdue cases, and filing….

Incorrect Answers

A:

The relevant alternative mechanism is different from operational risk owns vendor outages but never shares payment-data disruptions with…: Validation checks completeness, definitions, and accuracy of the board pack. The sample would be probative if a board pack reports alert volumes but omits false positives, overdue cases, and filing timeliness; a different population and test are needed for operational risk owns vendor outages but never shares payment-data disruptions with AML monitoring.

B:

Compared with the stated facts about operational risk owns vendor outages but never shares payment-data disruptions with…, the test checks that staff maintain legal confidentiality while handling inquiries. The test exercises an adjacent pathway, an institution sends a suspicious-activity report directly to a customer to explain a payment delay, without directly challenging operational risk owns vendor outages but never shares payment-data disruptions with AML monitoring.

D:

When testing the contrasting pattern of operational risk owns vendor outages but never shares payment-data disruptions with…, remember that an audit detects reports misrouted to a global mailbox instead of a competent authority. This assurance method targets a compliance analyst assumes suspicious activity always must be reported to the same global office rather than the reported process: operational risk owns vendor outages but never shares payment-data disruptions with AML monitoring.

Question 723

A risk committee asks for operating-effectiveness evidence regarding the following: A shipping broker uses frequent last-minute vessel name and flag changes during sanctioned-region voyages. What would provide the strongest proof?

  1. Reconcile pooled balances to identifiable client-level subledgers
  2. Test alerts for identity changes and inconsistent shipping histories
  3. Sample nominee-led transactions for documented instruction sources
  4. Test revenue exceptions against independent tax and bank records

Explanation

Correct Answer

B:

Detection should preserve links across renamed vessels and suspicious route deviations. Success on this scenario would be relevant to the original failure, whereas a bookkeeping firm pools client receipts in its own account and remits them without… tests a different exposure.

Incorrect Answers

A:

Tests assess whether every movement can be traced to a legitimate account owner; the observed record here instead involves a shipping broker uses frequent last-minute vessel name and flag changes during…. The test exercises an adjacent pathway, a bookkeeping firm pools client receipts in its own account and remits them without customer-level…, without directly challenging a shipping broker uses frequent last-minute vessel name and flag changes during sanctioned-region….

C:

The relevant alternative mechanism is different from a shipping broker uses frequent last-minute vessel name and flag changes during…: Assurance confirms whether hidden controllers are surfaced for risk assessment. This assurance method targets a nominee director signs transactions on instruction from an undisclosed offshore client rather than the reported process: a shipping broker uses frequent last-minute vessel name and flag changes during sanctioned-region….

D:

Compared with the stated facts about a shipping broker uses frequent last-minute vessel name and flag changes during…, effective validation detects fabricated turnover despite professionally prepared statements. Testing this would validate controls for an accountant certifies revenue for a client despite bank receipts that sharply diverge from tax…, not the effectiveness of remediation for a shipping broker uses frequent last-minute vessel name and flag changes during sanctioned-region….

Question 724

Quality assurance is reviewing a remediation plan for this situation: A property investor funds down payments with loans from companies that immediately receive matching offshore deposits. Which sample or test is most useful?

  1. Review sampled consultancy payments against contract decisions
  2. Back-test deposit alerts against verified sales and branch activity
  3. Audit flagged shipments against regulatory and customs exceptions
  4. Reconstruct drawdowns and repayments across connected accounts
  5. Test whether linked accounts and wage anomalies reach investigators
  6. Track repeat findings and correspondent service restrictions

Explanation

Correct Answer

D:

A full flow-of-funds review reveals whether purported loans are self-funded circular movements. The assessment probes the affected transactions and decisions, not just an adjacent risk such as a procurement officer is offered consultancy fees tied to awarding a government….

Incorrect Answers

A:

When testing the contrasting pattern of a property investor funds down payments with loans from companies that immediately…, remember that testing links between intermediaries, officials, and award timing exposes bypassed approvals. Even a favorable result for a procurement officer is offered consultancy fees tied to awarding a government infrastructure… would not demonstrate the control works when a property investor funds down payments with loans from companies that immediately receive matching….

B:

The review tests whether anomalous cash injections would be detected without treating every cash retailer alike; the observed record here instead involves a property investor funds down payments with loans from companies that immediately…. This assurance method targets a warehouse operator routes illicit cash proceeds into retail deposits while claiming ordinary shop… rather than the reported process: a property investor funds down payments with loans from companies that immediately receive matching….

C:

Against the reported situation in which a property investor funds down payments with loans from companies that immediately…, the assurance review assesses whether unlawful trade indicators survive onboarding and monitoring. Testing this would validate controls for a recycling firm receives international transfers inconsistent with its permits and declared scrap…, not the effectiveness of remediation for a property investor funds down payments with loans from companies that immediately receive matching….

E:

Compared with the stated facts about a property investor funds down payments with loans from companies that immediately…, an effective control should identify related employers, beneficiaries, and implausible payroll patterns. The test exercises an adjacent pathway, an account receives payments from employers implicated in withholding migrant workers' wages and…, without directly challenging a property investor funds down payments with loans from companies that immediately receive matching….

F:

This is not the central mechanism when a property investor funds down payments with loans from companies that immediately…; fewer unresolved root causes and stable relationships demonstrate more than a public apology. Even a favorable result for a bank loses correspondent relationships after repeated failures to remediate reported AML… would not demonstrate the control works when a property investor funds down payments with loans from companies that immediately receive matching….

Question 725

A firm wants measurable assurance for this identified exposure: A commodity broker ships industrial valves through successive intermediaries to obscure a restricted end user. Which evaluation should be conducted?

  1. Test whether linked accounts and wage anomalies reach investigators
  2. Test end-user documentation against vessel and customs data
  3. Review sampled consultancy payments against contract decisions
  4. Measure sector-specific alert outcomes and intelligence referrals

Explanation

Correct Answer

B:

Independent route checks can reveal whether disclosed destinations match the actual movement of goods. The proposed sample exercises the failure seen in a commodity broker ships industrial valves through successive intermediaries to obscure a restricted end…, rather than the separate pathway represented by an account receives payments from employers implicated in withholding migrant workers'….

Incorrect Answers

A:

This is not the central mechanism when a commodity broker ships industrial valves through successive intermediaries to…; an effective control should identify related employers, beneficiaries, and implausible payroll patterns. Testing this would validate controls for an account receives payments from employers implicated in withholding migrant workers' wages and…, not the effectiveness of remediation for a commodity broker ships industrial valves through successive intermediaries to obscure a….

C:

Testing links between intermediaries, officials, and award timing exposes bypassed approvals; the observed record here instead involves a commodity broker ships industrial valves through successive intermediaries to…. The test exercises an adjacent pathway, a procurement officer is offered consultancy fees tied to awarding a government infrastructure…, without directly challenging a commodity broker ships industrial valves through successive intermediaries to obscure a….

D:

Against the reported situation in which a commodity broker ships industrial valves through successive intermediaries to…, a targeted effectiveness measure tracks whether the identified criminal pattern is actually surfaced. Even a favorable result for an illicit trade network infiltrates local payment channels and distorts competition with… would not demonstrate the control works when a commodity broker ships industrial valves through successive intermediaries to obscure a….

Question 726

An institution has corrected a process after discovering this case: A privacy team deletes records under an automated schedule without considering mandatory AML retention holds. Which test best proves the relevant safeguard operates?

  1. Review board challenge records and follow-up after training
  2. Audit deletion exceptions against valid holds and applicable schedules
  3. Audit critical workflows for named owners and actual completion
  4. Test material overrides for AFC review and management escalation

Explanation

Correct Answer

B:

The test detects both missing evidence and unjustified retention. For the supported action of audit deletion exceptions against valid holds and applicable schedules in this effectiveness test review involving a privacy team deletes records under an automated schedule without considering mandatory AML…, this test provides observable evidence about the affected process; a test focused on a board receives annual compliance training identical to the material used for new… would not establish the same result.

Incorrect Answers

A:

The outcome measure tests whether directors apply the instruction; the observed record here instead involves a privacy team deletes records under an automated schedule without considering…. Even a favorable result for a board receives annual compliance training identical to the material used for new customer-service… would not demonstrate the control works when a privacy team deletes records under an automated schedule without considering mandatory AML….

C:

The relevant alternative mechanism is different from a privacy team deletes records under an automated schedule without considering…: Testing reveals control gaps hidden by broad department titles. Testing this would validate controls for a financial crime team has investigators but no ownership of data quality, training, or sanctions…, not the effectiveness of remediation for a privacy team deletes records under an automated schedule without considering mandatory AML….

D:

Compared with the stated facts about a privacy team deletes records under an automated schedule without considering…, assurance confirms that reporting lines do not impair compliance decisions. The sample would be probative if a growing bank moves AFC analysts into a sales reporting chain without clear conflict safeguards; a different population and test are needed for a privacy team deletes records under an automated schedule without considering mandatory AML….

Question 727

Independent assurance must evaluate an issue originally found as follows: A bank's risk appetite says 'zero financial crime' but gives no measurable boundaries for high-risk relationships. What validation would most directly test effectiveness?

  1. Audit product-launch approvals against risk reassessment records
  2. Test exceptional transactions against documented appetite limits
  3. Track repeat weaknesses across training, audit, and management actions
  4. Recalculate sample scores to verify controls affect only residual risk

Explanation

Correct Answer

B:

Assurance shows whether risk acceptance stays within the declared boundaries. The assessment probes the affected transactions and decisions, not just an adjacent risk such as a firm expands into a high-risk remittance corridor but leaves enterprise risk scores….

Incorrect Answers

A:

Against the reported situation in which a bank's risk appetite says 'zero financial crime' but gives no measurable boundaries…, assurance checks that expanding activities are evaluated before exposure grows unchecked. This assurance method targets a firm expands into a high-risk remittance corridor but leaves enterprise risk scores unchanged for… rather than the reported process: a bank's risk appetite says 'zero financial crime' but gives no measurable boundaries for high-risk….

C:

Compared with the stated facts about a bank's risk appetite says 'zero financial crime' but gives no measurable boundaries…, the measure tests program effectiveness rather than one person's job title. The sample would be probative if a bank appoints an AML officer but does not test policies or train relationship staff; a different population and test are needed for a bank's risk appetite says 'zero financial crime' but gives no measurable boundaries for high-risk….

D:

This is not the central mechanism when a bank's risk appetite says 'zero financial crime' but gives no measurable boundaries…; testing detects models that double-count or hide mitigation. The test exercises an adjacent pathway, a bank calculates inherent country risk after deducting the effectiveness of its screening controls, without directly challenging a bank's risk appetite says 'zero financial crime' but gives no measurable boundaries for high-risk….

Question 728

A firm wants measurable assurance for this identified exposure: An internal team equates a jurisdiction's technical compliance with effective AML outcomes. Which evaluation should be conducted?

  1. Test typographic and transliteration variants of listed names
  2. Track remedial actions against effectiveness gaps and inspection evidence
  3. Track intelligence-triggered updates and investigation outcomes
  4. Test screening lists against effective local and UN update timelines
  5. Sample trade payments for prohibited product and destination flags

Explanation

Correct Answer

B:

Independent follow-up can show whether improved practices generate credible results. For the supported action of track remedial actions against effectiveness gaps and inspection evidence in this effectiveness test review involving an internal team equates a jurisdiction's technical compliance with effective AML outcomes, the assessment probes the affected transactions and decisions, not just an adjacent risk such as a sanctions analyst releases a possible listed-person match because the customer name has….

Incorrect Answers

A:

This is not the central mechanism when an internal team equates a jurisdiction's technical compliance with effective AML…; scenario testing should determine whether reasonable spelling differences are still surfaced. This assurance method targets a sanctions analyst releases a possible listed-person match because the customer name has different… rather than the reported process: an internal team equates a jurisdiction's technical compliance with effective AML outcomes.

C:

Evidence should demonstrate whether the organization learns from reputable non-government sources; the observed record here instead involves an internal team equates a jurisdiction's technical compliance with effective AML…. The sample would be probative if a policy team ignores a credible advocacy report that documents exploitation patterns affecting its…; a different population and test are needed for an internal team equates a jurisdiction's technical compliance with effective AML outcomes.

D:

Against the reported situation in which an internal team equates a jurisdiction's technical compliance with effective AML…, assurance checks whether legally operative changes reach payment controls promptly. The test exercises an adjacent pathway, a payments team assumes every UN Security Council sanctions resolution becomes locally enforceable…, without directly challenging an internal team equates a jurisdiction's technical compliance with effective AML outcomes.

E:

The relevant alternative mechanism is different from an internal team equates a jurisdiction's technical compliance with effective AML…: Control testing demonstrates that embargoed activity is found even without a listed party. Even a favorable result for a branch screens sanctioned party names but overlooks a UN embargo relating to a category of… would not demonstrate the control works when an internal team equates a jurisdiction's technical compliance with effective AML outcomes.

Question 729

For this identified exposure, a banking consortium wants to share scam indicators but only discusses names instead of transactional patterns. Choose TWO complementary steps: one targeted safeguard and one test of its operation.

  1. Measure member adoption of indicators and validated hit quality
  2. Challenge risk ratings against sector-level evidence and portfolio reality
  3. Expand geographical risk assessment to trade corridors and zones
  4. Build typology-focused collaboration with controlled escalation paths
  5. Review dated risk-methodology revisions and affected-customer decisions
  6. Examine research methods, data limitations, and corroborating studies

Explanation

Correct Answers

A:

Testing reveals whether collaboration led to better detection outcomes. It produces control-performance evidence about a banking consortium wants to share scam indicators but only discusses names instead of transactional patterns; a documented plan alone would not prove operation.

D:

The design should turn common patterns into actionable internal monitoring updates. It addresses the live exposure in a banking consortium wants to share scam indicators but only discusses names instead of transactional patterns; corrective action is not a substitute for verifying its operation.

Incorrect Answers

B:

This is not the central mechanism when a banking consortium wants to share scam indicators but only discusses names instead…; testing shows whether the assessment differentiates exposed and unrelated products. Testing this would validate controls for a bank scores a low-risk domestic payment product using a national threat assessment for an…, not the effectiveness of remediation for a banking consortium wants to share scam indicators but only discusses names instead of…. For the alternative option of challenge risk ratings against sector-level evidence and portfolio reality in this effectiveness test review involving a banking consortium wants to share scam indicators but only discusses names instead of…, a two-part remediation plan for a banking consortium wants to share scam indicators but only discusses names instead… needs an issue-specific safeguard and proof that it operates, not this unrelated step.

C:

When testing the contrasting pattern of a banking consortium wants to share scam indicators but only discusses names instead…, remember that scoring should capture where value and goods move, not just legal domicile. That measure could be appropriate where a country identifies high exposure to trade-based laundering in free trade zones; a bank uses only…, but the described weakness is a banking consortium wants to share scam indicators but only discusses names instead of…. For the alternative option of expand geographical risk assessment to trade corridors and zones in this effectiveness test review involving a banking consortium wants to share scam indicators but only discusses names instead of…, a two-part remediation plan for a banking consortium wants to share scam indicators but only discusses names instead… needs an issue-specific safeguard and proof that it operates, not this unrelated step.

E:

Against the reported situation in which a banking consortium wants to share scam indicators but only discusses names instead…, the test proves that updated national findings actually changed control treatment. Even a favorable result for a new national risk assessment highlights cash-intensive money service businesses but the bank's… would not demonstrate the control works when a banking consortium wants to share scam indicators but only discusses names instead of…. For the alternative option of review dated risk-methodology revisions and affected-customer decisions in this effectiveness test review involving a banking consortium wants to share scam indicators but only discusses names instead of…, a two-part remediation plan for a banking consortium wants to share scam indicators but only discusses names instead… needs an issue-specific safeguard and proof that it operates, not this unrelated step.

F:

The relevant alternative mechanism is different from a banking consortium wants to share scam indicators but only discusses names instead…: Quality assessment prevents unsupported claims from driving disproportionate controls. It seeks evidence about a bank repeats industry research claims about laundering indicators without checking methodology or…; the allegation under review instead involves a banking consortium wants to share scam indicators but only discusses names instead of…. For the alternative option of examine research methods, data limitations, and corroborating studies in this effectiveness test review involving a banking consortium wants to share scam indicators but only discusses names instead of…, a two-part remediation plan for a banking consortium wants to share scam indicators but only discusses names instead… needs an issue-specific safeguard and proof that it operates, not this unrelated step.

Question 730

Quality assurance is reviewing a remediation plan for this situation: A bank centralizes all customer data in one country despite incompatible transfer restrictions in another. Which sample or test is most useful?

  1. Test policies against applicable EU reform obligations at each effective date
  2. Measure member adoption of indicators and validated hit quality
  3. Test filing timeliness using each entity's actual legal triggers
  4. Test cross-border data access against consent and legal bases where applicable

Explanation

Correct Answer

D:

Audit logs reveal whether disclosures remain within authorized use. Operating-effectiveness evidence must reach the specific control gap here; an EU financial group assumes a policy written before the 2024 AML regulatory package will… would require a different test.

Incorrect Answers

A:

When testing the contrasting pattern of a bank centralizes all customer data in one country despite incompatible transfer…, remember that assurance should not treat future requirements as already binding or ignore commenced duties. Testing this would validate controls for an EU financial group assumes a policy written before the 2024 AML regulatory package will remain…, not the effectiveness of remediation for a bank centralizes all customer data in one country despite incompatible transfer restrictions in….

B:

Testing reveals whether collaboration led to better detection outcomes; the observed record here instead involves a bank centralizes all customer data in one country despite incompatible transfer…. The sample would be probative if a banking consortium wants to share scam indicators but only discusses names instead of…; a different population and test are needed for a bank centralizes all customer data in one country despite incompatible transfer restrictions in….

C:

Against the reported situation in which a bank centralizes all customer data in one country despite incompatible transfer…, assurance detects both late and incorrectly routed reports. The test exercises an adjacent pathway, a local compliance team automatically applies US suspicious-activity deadlines to an EU subsidiary, without directly challenging a bank centralizes all customer data in one country despite incompatible transfer restrictions in….

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