Free ACAMS CAMS Practice Exam with Questions & Answers

Transaction monitoring governanceinvolves ensuring thatAML detection systems are effective, aligned with regulatory standards, and capable of identifying evolving threats.

Option B (Correct):Legal cooperation is essential for responding to subpoenas and law enforcement inquiries.

Option D (Correct):Regularly updating transaction monitoring scenarios ensures that the system adapts to emerging financial crime trends.

Why Other Options Are Incorrect:

Option A (Incorrect):SARs cannot be withdrawn unless an error was made—once filed, SARs remain confidential and must be retained.

Option C (Incorrect):Client profile updates are a CDD/KYC function, not directly related to transaction monitoring governance.

Best Practices for Transaction Monitoring Governance:

Regularly review system effectiveness through validation tests.

Collaborate with legal and compliance teams for risk mitigation.

Use AI and data analytics to refine detection accuracy.

OFAC sanctions are a key element of the U.S. AML/CFT framework. According to the CAMS 6th Edition and OFAC regulations:

Blocked funds must be placed into an interest-bearing account on a financial institution's books (B):“Blocked property must be held in a separate interest-bearing account on the books of the U.S. financial institution.”(CAMS 6th Edition, Sanctions Compliance; OFAC FAQs)

Sanctions can be either comprehensive or selective using the blocking of assets and trade restrictions (C):“OFAC administers both comprehensive and targeted (selective) sanctions programs to fulfill U.S. foreign policy and national security goals.”(CAMS 6th Edition, Sanctions Compliance)

Incorrect Options:

A: OFAC can sanction entities, vessels, and organizations—not just individuals or those in foreign countries.

D: There is no automatic expiration of OFAC sanctions after five years.

Cryptoassets, such as cryptocurrencies, pose specific ML/TF risks due to their technological characteristics and usage patterns:

Potential for anonymity (C): Cryptoassets allow users to make transactions without revealing their true identities, which hinders law enforcement from tracking illicit activity. The CAMS 6th Edition states:“Cryptoassets can be transferred or exchanged between users without the need for identification, presenting a significant risk due to the potential for anonymity.”(CAMS 6th Edition, Chapter: Risks and Methods of Money Laundering and Terrorist Financing, Virtual Assets section)

Global reach (D): Cryptoassets operate on a global scale, enabling rapid cross-border transfers without the limitations of traditional financial systems. This increases the complexity of monitoring and controlling illicit transactions.“The global nature of virtual assets makes it easy for criminals to move value across borders quickly, evading jurisdictional controls.”(CAMS 6th Edition; FATF Guidance on Virtual Assets 2019)

Use to layer illicit funds (F): The ability to move cryptoassets between numerous wallets and exchanges allows criminals to obscure the source of funds through layering, a key stage of money laundering.“Layering can be achieved by rapidly moving cryptoassets between wallets, exchanges, and across different jurisdictions, making tracing more difficult.”(CAMS 6th Edition, Chapter: Risks and Methods of Money Laundering and Terrorist Financing)

A financial institution may disclose a SAR only under a valid court order and after ensuring legal review and compliance with jurisdictional requirements. In most jurisdictions, SARs are highly confidential, and unauthorized disclosure - known as “tipping off” - is prohibited.

In a mutual evaluation, a country must demonstrate to the FATF that it has an effective framework to protect its financial system from abuse. This process assesses both technical compliance with FATF Recommendations and the effectiveness of the country's AML/CFT measures.

Trade finance red flags include account activity inconsistent with the account's stated purpose, unnecessarily complex transaction structures, poorly worded or foreign-language trade documents that may obscure details, and invoices with prices significantly above market value, which can indicate trade-based money laundering or fraud.

Verifying a customer’s identity is a fundamental CDD requirement under the FATF Recommendations, ensuring you know who your customer is.

Identifying the beneficial owner is required to uncover the natural persons ultimately controlling or benefiting from an account, closing the gap that would allow misuse of corporate vehicles.

Governance arrangements (A):“Sound governance and risk management arrangements are fundamental to assessing and managing ML/TF risk in products and services.”(CAMS 6th Edition, Risk-Based Approach for Products and Services)

Complexity of the products (B):“Complexity increases risk—products that are highly complex, opaque, or allow for multiple layers or jurisdictions are more vulnerable to misuse for ML/TF.”(CAMS 6th Edition, Product Risk Assessment)

Incorrect Options:

C: Last audit results inform program effectiveness, not inherent product risk.

D: Business financial status is considered in customer risk assessment, not product risk.

One of the central pillars of the EU AML Package adopted in June 2024 is theEU AML Regulation. This regulation introduces directly applicable AML/CFT rules across all EU member states, replacing the previous approach where AML directives were transposed into national laws. This shift addresses regulatory fragmentation and strengthens enforcement across borders.

The complete AML Package includes the following four pillars:

EU AML Regulation (directly applicable rulebook)

6th AML Directive (not the 7th)

Establishment of a new EU Anti-Money Laundering Authority (AMLA)

Revised Transfer of Funds Regulation, especially concerning crypto-asset service providers

The EU AML Regulation aims to unify and streamline the application of AML/CFT measures across the EU, ensuring a consistent and effective framework.