CAMS Exam Questions & Answers
Certified Anti-Money Laundering Specialist v7 • Acams
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Sample CAMS Questions
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Which red flag is most relevant to money laundering through capital markets?
The compliance department of a casino is reviewing recent transactions and has identified activities that may require further scrutiny.
Which transaction would require further investigation?
Casinos are recognized as high-risk entities under AML/CFT frameworks due to their exposure to large cash volumes and convertible instruments such as chips. Regulators and FATF guidance highlight minimal or no gaming activity combined with rapid cash-out as a major red flag.
In this scenario, the player purchases a large amount of chips using multiple funding methods, including an international wire transfer, does not engage in any gambling, and then immediately cashes out. This behavior is consistent with placement and layering techniques, where a casino is used as a pass-through to legitimize illicit funds.
The absence of gaming activity strongly suggests that the intent was not entertainment but financial manipulation. Casinos are frequently misused for this exact purpose due to their ability to convert cash into ''winnings.''
The other scenarios describe activity that may be higher risk but are consistent with legitimate casino behavior when properly documented.
A compliance officer at a large bank has been tasked with investigating a series of unusual transactions involving a long-time customer. The customer has made several large cash deposits into multiple accounts within a short period, raising red flags. After gathering and analyzing transaction data, reviewing customer records, and cross-referencing external sources, the compliance officer determines that there is a reasonable suspicion of money laundering. As part of documenting this investigation, the compliance officer must decide how and when to escalate the matter internally and whether to file a suspicious activity report (SAR).
What is the next critical step in this process?
Once there is reasonable suspicion of money laundering, the next critical step is to draft and file a suspicious activity report (SAR) with the relevant financial intelligence unit within the required regulatory timeframe. The SAR should contain a clear chronology of transactions, relevant customer details, and the rationale for suspicion to support potential investigation by authorities.
In order to prevent financial crime risk, the implemented policies, controls, and procedures must:
Effective AML/CFT policies, controls, and procedures must be risk-based, proportionate, and well-governed, as emphasized by FATF and national regulators. Proportionality ensures that controls are appropriate to the firm's size, complexity, products, services, and risk exposure.
Senior management approval is essential to establish accountability and tone from the top. Regular review ensures policies remain effective as risks, regulations, and business models evolve.
AML responsibility is shared across the three lines of defense, not owned solely by the business. External validation may support assurance but does not replace internal accountability. While technology can enhance controls, regulators do not mandate the use of advanced or cutting-edge solutions; effectiveness and governance are more important than sophistication.
The purpose of a risk appetite statement is to:
A risk appetite statement clearly defines the level and type of financial crime risk a financial institution is willing to accept in pursuit of its objectives. It guides decision-making and ensures consistency in risk-taking across the organization.
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