ACAMS CAMS (Certified Anti-Money Laundering Specialist (the 6th edition)) Practice Test 78

Question 770

For this identified exposure, a notary receives large third-party escrow deposits with no connection to the declared asset transfer. Choose TWO complementary steps: one targeted safeguard and one test of its operation.

  1. Sample escrow ledgers against underlying client contracts and settlements
  2. Test governance privileges and customer-asset flows against declared roles
  3. Monitor unexplained escrow inflows and beneficiary changes
  4. Link cards, account holder, wagering history, and withdrawal beneficiaries
  5. Back-test low-play redemptions across pit, cage, and loyalty records
  6. Monitor coordinated betting and linked-account withdrawals

Explanation

Correct Answers

A:

End-to-end evidence establishes whether the professional account channels unsupported payments. It produces control-performance evidence about a notary receives large third-party escrow deposits with no connection to the declared asset transfer; a documented plan alone would not prove operation.

C:

Controls should challenge third-party funding unrelated to the underlying agreement. It addresses the live exposure in a notary receives large third-party escrow deposits with no connection to the declared asset transfer; corrective action is not a substitute for verifying its operation.

Incorrect Answers

B:

This is not the central mechanism when a notary receives large third-party escrow deposits with no connection to the…; assurance checks whether the stated operating model reflects what administrators can really control. The sample would be probative if a token project describes its protocol as decentralized but a company retains privileged controls…; a different population and test are needed for a notary receives large third-party escrow deposits with no connection to the declared asset…. For the alternative option of test governance privileges and customer-asset flows against declared roles in this effectiveness test review involving a notary receives large third-party escrow deposits with no connection to the declared asset…, a two-part remediation plan for a notary receives large third-party escrow deposits with no connection to the… needs an issue-specific safeguard and proof that it operates, not this unrelated step.

D:

Payment and betting evidence together reveal inconsistent ownership or disguised transfers; the observed record here instead involves a notary receives large third-party escrow deposits with no connection to the…. This would divert the fact-finding effort toward an online betting account is funded by several payment cards and withdraws winnings to a different… without resolving the key question raised by a notary receives large third-party escrow deposits with no connection to the declared asset…. For the alternative option of link cards, account holder, wagering history, and withdrawal beneficiaries in this effectiveness test review involving a notary receives large third-party escrow deposits with no connection to the declared asset…, a two-part remediation plan for a notary receives large third-party escrow deposits with no connection to the… needs an issue-specific safeguard and proof that it operates, not this unrelated step.

E:

Against the reported situation in which a notary receives large third-party escrow deposits with no connection to the…, controls should identify cash-to-chip-to-cash patterns spanning casino systems. This assurance method targets a casino patron exchanges large cash amounts for chips and redeems them shortly afterward without… rather than the reported process: a notary receives large third-party escrow deposits with no connection to the declared asset…. For the alternative option of back-test low-play redemptions across pit, cage, and loyalty records in this effectiveness test review involving a notary receives large third-party escrow deposits with no connection to the declared asset…, a two-part remediation plan for a notary receives large third-party escrow deposits with no connection to the… needs an issue-specific safeguard and proof that it operates, not this unrelated step.

F:

The relevant alternative mechanism is different from a notary receives large third-party escrow deposits with no connection to the…: Controls should combine gameplay patterns with identity and payment relationships. This safeguard targets several esports betting accounts trade bets against each other and cash out through the same device…; it does not directly remediate the process failure in a notary receives large third-party escrow deposits with no connection to the declared asset…. For the alternative option of monitor coordinated betting and linked-account withdrawals in this effectiveness test review involving a notary receives large third-party escrow deposits with no connection to the declared asset…, a two-part remediation plan for a notary receives large third-party escrow deposits with no connection to the… needs an issue-specific safeguard and proof that it operates, not this unrelated step.

Question 771

An institution has corrected a process after discovering this case: A procurement officer is offered consultancy fees tied to awarding a government infrastructure contract. Which test best proves the relevant safeguard operates?

  1. Measure sector-specific alert outcomes and intelligence referrals
  2. Audit flagged shipments against regulatory and customs exceptions
  3. Review sampled consultancy payments against contract decisions
  4. Sample alert-to-filing timelines and overdue-case exceptions
  5. Track repeat findings and correspondent service restrictions
  6. Replay known circular-trading patterns against surveillance rules

Explanation

Correct Answer

C:

Testing links between intermediaries, officials, and award timing exposes bypassed approvals. This test provides observable evidence about the affected process; a test focused on an illicit trade network infiltrates local payment channels and distorts competition with… would not establish the same result.

Incorrect Answers

A:

A targeted effectiveness measure tracks whether the identified criminal pattern is actually surfaced; the observed record here instead involves a procurement officer is offered consultancy fees tied to awarding a government…. Testing this would validate controls for an illicit trade network infiltrates local payment channels and distorts competition with…, not the effectiveness of remediation for a procurement officer is offered consultancy fees tied to awarding a government infrastructure….

B:

Against the reported situation in which a procurement officer is offered consultancy fees tied to awarding a government…, the assurance review assesses whether unlawful trade indicators survive onboarding and monitoring. The sample would be probative if a recycling firm receives international transfers inconsistent with its permits and declared scrap…; a different population and test are needed for a procurement officer is offered consultancy fees tied to awarding a government infrastructure….

D:

Compared with the stated facts about a procurement officer is offered consultancy fees tied to awarding a government…, elapsed-time testing establishes whether deadlines are consistently met and breaches are escalated. Even a favorable result for a suspicious-activity backlog grows until analysts miss required reporting deadlines would not demonstrate the control works when a procurement officer is offered consultancy fees tied to awarding a government infrastructure….

E:

This is not the central mechanism when a procurement officer is offered consultancy fees tied to awarding a government…; fewer unresolved root causes and stable relationships demonstrate more than a public apology. This assurance method targets a bank loses correspondent relationships after repeated failures to remediate reported AML… rather than the reported process: a procurement officer is offered consultancy fees tied to awarding a government infrastructure….

F:

When testing the contrasting pattern of a procurement officer is offered consultancy fees tied to awarding a government…, remember that back-testing should establish that the system connects counterparties rather than scoring each trade alone. Testing this would validate controls for a brokerage customer buys securities through several entities and quickly sells them back to…, not the effectiveness of remediation for a procurement officer is offered consultancy fees tied to awarding a government infrastructure….

Question 772

An institution has corrected a process after discovering this case: A trustee directs distributions to beneficiaries omitted from a family's original trust documentation. Which test best proves the relevant safeguard operates?

  1. Test related-entity flows against declared tax and trading activity
  2. Sample escrow ledgers against underlying client contracts and settlements
  3. Reconcile pooled balances to identifiable client-level subledgers
  4. Audit distributions against verified beneficiary and amendment records

Explanation

Correct Answer

D:

The check tests whether actual payments match authorized trust relationships. The proposed sample exercises the failure seen in a trustee directs distributions to beneficiaries omitted from a family's original trust documentation, rather than the separate pathway represented by a tax adviser creates repeated artificial loss-making entities whose transfers fund….

Incorrect Answers

A:

Reconciliation exposes entities that cannot support their transactions commercially; the observed record here instead involves a trustee directs distributions to beneficiaries omitted from a family's original…. This assurance method targets a tax adviser creates repeated artificial loss-making entities whose transfers fund personal luxury… rather than the reported process: a trustee directs distributions to beneficiaries omitted from a family's original trust….

B:

Against the reported situation in which a trustee directs distributions to beneficiaries omitted from a family's original…, end-to-end evidence establishes whether the professional account channels unsupported payments. Testing this would validate controls for a notary receives large third-party escrow deposits with no connection to the declared asset…, not the effectiveness of remediation for a trustee directs distributions to beneficiaries omitted from a family's original trust….

C:

The relevant alternative mechanism is different from a trustee directs distributions to beneficiaries omitted from a family's original…: Tests assess whether every movement can be traced to a legitimate account owner. The sample would be probative if a bookkeeping firm pools client receipts in its own account and remits them without customer-level…; a different population and test are needed for a trustee directs distributions to beneficiaries omitted from a family's original trust….

Question 773

A risk committee asks for operating-effectiveness evidence regarding the following: A fraud analyst sends customer data to overseas police on an informal personal email request. What would provide the strongest proof?

  1. Test typographic and transliteration variants of listed names
  2. Verify regional intelligence is reflected in customer and geographic risk scoring
  3. Audit policy citations for source authority and legal status
  4. Review cross-border disclosures for validated authority and data minimization
  5. Review notice-to-control change logs for jurisdictional accuracy
  6. Check procedures for regulatory coverage beyond association membership

Explanation

Correct Answer

D:

Testing can reveal informal transfers unsupported by applicable safeguards. For the supported action of review cross-border disclosures for validated authority and data minimization in this effectiveness test review involving a fraud analyst sends customer data to overseas police on an informal personal email request, 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:

Scenario testing should determine whether reasonable spelling differences are still surfaced; the observed record here instead involves a fraud analyst sends customer data to overseas police on an informal personal email…. Even a favorable result for a sanctions analyst releases a possible listed-person match because the customer name has different… would not demonstrate the control works when a fraud analyst sends customer data to overseas police on an informal personal email request.

B:

Against the reported situation in which a fraud analyst sends customer data to overseas police on an informal personal email…, a traceable assessment explains why specific regional exposure receives additional scrutiny. This assurance method targets a bank ignores guidance from the regional FATF-style body serving one of its markets rather than the reported process: a fraud analyst sends customer data to overseas police on an informal personal email request.

C:

The relevant alternative mechanism is different from a fraud analyst sends customer data to overseas police on an informal personal email…: The test prevents a private report from being treated as a regulator's directive. Testing this would validate controls for a nonprofit training group claims authority to impose national AML penalties because it publishes…, not the effectiveness of remediation for a fraud analyst sends customer data to overseas police on an informal personal email request.

E:

This is not the central mechanism when a fraud analyst sends customer data to overseas police on an informal personal email…; testing verifies that responses follow current statements and domestic instructions. The test exercises an adjacent pathway, a compliance officer assumes a FATF public-listing announcement requires identical account…, without directly challenging a fraud analyst sends customer data to overseas police on an informal personal email request.

F:

When testing the contrasting pattern of a fraud analyst sends customer data to overseas police on an informal personal email…, remember that assurance confirms that voluntary recommendations have not hidden statutory gaps. Even a favorable result for a bank uses an industry association's voluntary principles as its only legal compliance standard would not demonstrate the control works when a fraud analyst sends customer data to overseas police on an informal personal email request.

Question 774

Quality assurance is reviewing a remediation plan for this situation: A cybersecurity team detects a compromised customer login but the AFC team never reviews the resulting transfer chain. Which sample or test is most useful?

  1. Audit referrals from relationship teams for timeliness and follow-up
  2. Test material overrides for AFC review and management escalation
  3. Review board challenge records and follow-up after training
  4. Test incident referrals for full payment-chain review and closure

Explanation

Correct Answer

D:

Assurance checks that cyber alerts produce appropriate financial-crime investigation. Operating-effectiveness evidence must reach the specific control gap here; a wealth adviser notices unexpected offshore transfers but believes only the monitoring… would require a different test.

Incorrect Answers

A:

When testing the contrasting pattern of a cybersecurity team detects a compromised customer login but the AFC team never…, remember that testing measures use of customer intelligence beyond automated alerts. Testing this would validate controls for a wealth adviser notices unexpected offshore transfers but believes only the monitoring system can…, not the effectiveness of remediation for a cybersecurity team detects a compromised customer login but the AFC team never reviews the….

B:

Assurance confirms that reporting lines do not impair compliance decisions; the observed record here instead involves a cybersecurity team detects a compromised customer login but the AFC team never…. 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 cybersecurity team detects a compromised customer login but the AFC team never reviews the….

C:

Against the reported situation in which a cybersecurity team detects a compromised customer login but the AFC team never…, the outcome measure tests whether directors apply the instruction. The test exercises an adjacent pathway, a board receives annual compliance training identical to the material used for new customer-service…, without directly challenging a cybersecurity team detects a compromised customer login but the AFC team never reviews the….

Question 775

Quality assurance is reviewing a remediation plan for this situation: A bank uses the number of written AML policies as proof that residual risk is low. Which sample or test is most useful?

  1. Review false positives and missed cases by risk segment
  2. Review aged exceptions against renewal decisions and approved limits
  3. Sample new correspondent relationships for policy-aligned approval
  4. Challenge high-effectiveness ratings against unresolved audit findings

Explanation

Correct Answer

D:

The review checks for credible evidence supporting risk reductions. Success on this scenario would be relevant to the original failure, whereas an institution rates all foreign transactions high-risk without considering destination,… tests a different exposure.

Incorrect Answers

A:

When testing the contrasting pattern of a bank uses the number of written AML policies as proof that residual risk is low, remember that testing shows whether segmentation improves both effectiveness and proportionality. The sample would be probative if an institution rates all foreign transactions high-risk without considering destination, customer,…; a different population and test are needed for a bank uses the number of written AML policies as proof that residual risk is low.

B:

Assurance checks that exceptions are monitored, challenged, and closed; the observed record here instead involves a bank uses the number of written AML policies as proof that residual risk is low. The test exercises an adjacent pathway, a bank repeatedly grants exceptions for the same high-risk product without reporting them to its…, without directly challenging a bank uses the number of written AML policies as proof that residual risk is low.

C:

Against the reported situation in which a bank uses the number of written AML policies as proof that residual risk is low, testing confirms that stated restrictions influence actual onboarding outcomes. Even a favorable result for a board approves restricted correspondent banking but sales continues to onboard nested-payment… would not demonstrate the control works when a bank uses the number of written AML policies as proof that residual risk is low.

Question 776

A firm wants measurable assurance for this identified exposure: A bank calculates inherent country risk after deducting the effectiveness of its screening controls. Which evaluation should be conducted?

  1. Review false positives and missed cases by risk segment
  2. Verify auditors did not approve the controls they later audited
  3. Recalculate sample scores to verify controls affect only residual risk
  4. Sample customer risk classifications across branches for consistency

Explanation

Correct Answer

C:

Testing detects models that double-count or hide mitigation. Operating-effectiveness evidence must reach the specific control gap here; an institution rates all foreign transactions high-risk without considering destination,… would require a different test.

Incorrect Answers

A:

This is not the central mechanism when a bank calculates inherent country risk after deducting the effectiveness of its…; testing shows whether segmentation improves both effectiveness and proportionality. Even a favorable result for an institution rates all foreign transactions high-risk without considering destination, customer,… would not demonstrate the control works when a bank calculates inherent country risk after deducting the effectiveness of its screening controls.

B:

When testing the contrasting pattern of a bank calculates inherent country risk after deducting the effectiveness of its…, remember that workpaper review and role histories expose impaired independence. This assurance method targets internal audit designs the transaction monitoring rules it must later assess rather than the reported process: a bank calculates inherent country risk after deducting the effectiveness of its screening controls.

D:

Against the reported situation in which a bank calculates inherent country risk after deducting the effectiveness of its…, testing exposes mismatches between group definitions and frontline decisions. The sample would be probative if two branches define 'high-risk customer' differently despite a central group standard; a different population and test are needed for a bank calculates inherent country risk after deducting the effectiveness of its screening controls.

Question 777

The compliance team introduces remediation for this weakness: A money remitter's agent repeatedly breaks large customer transfers into many nearby transactions. Which evidence best shows it is functioning?

  1. Reconstruct common-controller relationships in policy issuance files
  2. Reconstruct pooled entries and exits to natural-person investors
  3. Sample policies for premium-origin and payout-recipient consistency
  4. Replay fragmented remittance patterns across multiple agent identifiers

Explanation

Correct Answer

D:

Detection tests should identify linked small transfers despite distribution across outlets. The assessment probes the affected transactions and decisions, not just an adjacent risk such as an insurance broker proposes many single-premium policies purchased by entities with the….

Incorrect Answers

A:

The relevant alternative mechanism is different from a money remitter's agent repeatedly breaks large customer transfers into many nearby…: An effective control catches a network that looks ordinary at policy level. Even a favorable result for an insurance broker proposes many single-premium policies purchased by entities with the same… would not demonstrate the control works when a money remitter's agent repeatedly breaks large customer transfers into many nearby transactions.

B:

Compared with the stated facts about a money remitter's agent repeatedly breaks large customer transfers into many nearby…, the review tests whether the fund can trace who provided and received value. This assurance method targets a pooled investment vehicle permits rapid subscriptions and redemptions through several offshore… rather than the reported process: a money remitter's agent repeatedly breaks large customer transfers into many nearby transactions.

C:

This is not the central mechanism when a money remitter's agent repeatedly breaks large customer transfers into many nearby…; testing addresses the laundering channel created by rapid encashment and unrelated funders. Testing this would validate controls for a customer buys a large life policy using a third party and requests early surrender despite steep…, not the effectiveness of remediation for a money remitter's agent repeatedly breaks large customer transfers into many nearby transactions.

Question 778

A risk committee asks for operating-effectiveness evidence regarding the following: An institution uses AI to prioritize sanctions cases but lets the system permanently clear high-risk matches without review. What would provide the strongest proof?

  1. Run above-the-line and below-the-line tests for missed cases
  2. Inject unsupported relationships and verify they are rejected in review
  3. Back-test thresholds using segment-specific suspicious cases and false positives
  4. Seed ambiguous high-risk matches and examine reviewer escalation

Explanation

Correct Answer

D:

Assurance checks that automation does not bypass critical adjudication. The assessment probes the affected transactions and decisions, not just an adjacent risk such as an AML model's thresholds are reduced until alert volume rises sharply but investigators….

Incorrect Answers

A:

Testing compares triggers and near misses to locate useful thresholds; the observed record here instead involves an institution uses AI to prioritize sanctions cases but lets the system permanently…. Even a favorable result for an AML model's thresholds are reduced until alert volume rises sharply but investigators find fewer… would not demonstrate the control works when an institution uses AI to prioritize sanctions cases but lets the system permanently clear….

B:

Against the reported situation in which an institution uses AI to prioritize sanctions cases but lets the system permanently…, testing measures whether errors are caught before escalation and reporting. This assurance method targets a case system auto-generates suspicious-activity narratives using AI that sometimes invents account… rather than the reported process: an institution uses AI to prioritize sanctions cases but lets the system permanently clear….

C:

The relevant alternative mechanism is different from an institution uses AI to prioritize sanctions cases but lets the system permanently…: Testing should check recall and alert quality across different populations. Testing this would validate controls for a small-business monitoring scenario uses the same cash threshold as a multinational…, not the effectiveness of remediation for an institution uses AI to prioritize sanctions cases but lets the system permanently clear….

Question 779

Quality assurance is reviewing a remediation plan for this situation: A securities intermediary receives funding through unrelated customer accounts before a bulk share allocation. Which sample or test is most useful?

  1. Sample policies for premium-origin and payout-recipient consistency
  2. Test known linked-account scenarios against anti-collusion alerts
  3. Investigate suspicious seller clusters for genuine shipments and returns
  4. Sample subscriptions for source-account and allocation consistency

Explanation

Correct Answer

D:

Testing ensures that aggregation does not obscure the ultimate investor and source of funds. The proposed sample exercises the failure seen in a securities intermediary receives funding through unrelated customer accounts before a bulk share…, rather than the separate pathway represented by a customer buys a large life policy using a third party and requests early surrender….

Incorrect Answers

A:

When testing the contrasting pattern of a securities intermediary receives funding through unrelated customer accounts before…, remember that testing addresses the laundering channel created by rapid encashment and unrelated funders. This assurance method targets a customer buys a large life policy using a third party and requests early surrender despite steep… rather than the reported process: a securities intermediary receives funding through unrelated customer accounts before a bulk share….

B:

Assurance requires identifying coordinated groups, not just high stake amounts; the observed record here instead involves a securities intermediary receives funding through unrelated customer accounts before…. Testing this would validate controls for several esports betting accounts trade bets against each other and cash out through the same device…, not the effectiveness of remediation for a securities intermediary receives funding through unrelated customer accounts before a bulk share….

C:

Against the reported situation in which a securities intermediary receives funding through unrelated customer accounts before…, control testing checks whether coordinated buyer-seller activity is identified. The sample would be probative if a marketplace pays seller proceeds to newly added bank accounts after bursts of fabricated purchase…; a different population and test are needed for a securities intermediary receives funding through unrelated customer accounts before a bulk share….

Question 780

The AFC team needs to demonstrate sustained remediation for the following weakness: A bank screens PEPs only during initial account opening. Which validation is appropriate?

  1. Sample mule referrals for consistent risk reassessment and action
  2. Seed new-PEP events and inspect alerts plus escalation records
  3. Sample PEP accounts for ownership verification and approval evidence
  4. Test entity inventories for inclusion across applicable AFC assessments

Explanation

Correct Answer

B:

The test verifies continuing coverage rather than one-time clearance. The assessment probes the affected transactions and decisions, not just an adjacent risk such as a fraud team sees mule-account patterns that the AML team never incorporates into customer….

Incorrect Answers

A:

The relevant alternative mechanism is different from a bank screens PEPs only during initial account opening: Testing checks whether relevant fraud intelligence drives AFC review. This assurance method targets a fraud team sees mule-account patterns that the AML team never incorporates into customer risk… rather than the reported process: a bank screens PEPs only during initial account opening.

C:

This is not the central mechanism when a bank screens PEPs only during initial account opening; the review tests whether heightened scrutiny is substantive. The sample would be probative if a new customer is a PEP whose funds arrive from a closely held firm with undisclosed controllers; a different population and test are needed for a bank screens PEPs only during initial account opening.

D:

When testing the contrasting pattern of a bank screens PEPs only during initial account opening, remember that assurance checks that material subsidiaries are not invisible in specialist reporting. The test exercises an adjacent pathway, a high-risk subsidiary is included in the enterprise risk assessment but not in the…, without directly challenging a bank screens PEPs only during initial account opening.

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