Free ACAMS CAMS Practice Exam with Questions & Answers | Set: 2

The combination of frequent address changes and a recent change in the ultimate beneficial owner raises potential red flags that warrant immediate investigation. To mitigate risk, the insurance company should investigate these changes and temporarily decline any payment or withdrawal instructions until the review is complete and appropriate steps are agreed upon. This ensures both regulatory compliance and protection against potential misuse of the policy.

FATF standards require financial institutions to adopt a risk-based approach (RBA) that is informed by national and sectoral risk assessments. These assessments identify key threats, vulnerabilities, and typologies within a jurisdiction or industry and provide essential context for institutional risk management.

Financial institutions must reference and align their internal AML/CFT risk assessments with the findings of NRAs and sectoral assessments. This means demonstrating awareness of identified risks and showing how these risks are mitigated through policies, controls, and procedures.

However, institutions are not required to copy or mechanically apply the exact methodologies, weightings, or conclusions of these assessments. Each institution must tailor its risk assessment to its own business model, customer base, products, services, and geographic exposure.

Board oversight is required, but NRAs do not dictate how internal assessments must be written or approved. The key regulatory expectation is alignment, awareness, and effective risk management—not rigid adoption.

The finance industry is inherently vulnerable to money laundering risks due to the nature, scale, and complexity of its operations. FATF and global regulators consistently identify several structural characteristics that increase exposure to illicit financial activity.

One major vulnerability is the availability of complex financial products and services, such as derivatives, correspondent banking, and structured investments. These products can be misused to disguise the origin of funds through layering and complex transaction chains.

Another key risk arises from engagement with high-risk jurisdictions. Financial institutions often operate across borders, including in countries with weak AML controls or limited regulatory oversight, increasing exposure to money laundering and terrorist financing risks.

Additionally, high transaction volumes present a significant challenge. The sheer scale and speed of transactions make it difficult to detect suspicious activity, particularly when illicit transactions are deliberately structured to blend in with legitimate activity.

In contrast, heightened regulatory obligations and investments in technology are risk-mitigating factors, not vulnerabilities. They are designed to reduce exposure to financial crime rather than increase it.

A, B, C, D are all identified by CAMS 6th Edition and FATF as primary financial crime risks for e-commerce platforms:

A: Platforms can be exploited to launder money by processing the movement of criminal proceeds under the guise of legitimate sales.

B: Use of stolen credit/debit cards for online purchases is a common fraud and ML technique.

C: Fraud schemes (such as chargebacks or fake listings) are widespread on e-commerce platforms.

D: E-commerce platforms can serve as fronts for illicit goods or services, masking the true nature of transactions.

E and F are not commonly cited as principal inherent risks in AML/CTF guidance.

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)

Policies, controls, and procedures must be proportionate to the size and nature of the firm, approved by senior management, and regularly reviewed to ensure they remain effective in preventing and mitigating financial crime risk while aligning with regulatory expectations.

FATF and CAMS 6th Edition highlight certain third-party activities as red flags for money laundering in the life insurance sector:

Payments are regularly received from third parties that have no apparent relationship with the policy holder (C):“Red flags include payments made by third parties, especially where there is no apparent connection between the third party and the policy holder.”(FATF, Risk-Based Approach for Life Insurance Sector, Section IV: Red Flags; CAMS 6th Edition, Customer Due Diligence for Life Insurance)

A customer names an apparently unrelated third party as a beneficiary (D):“Another warning sign is when beneficiaries have no apparent relation to the policyholder.”(FATF, Ibid; CAMS 6th Edition, Life Insurance ML/TF Red Flags)

Incorrect Options:

A: Consulting an attorney is not, by itself, a red flag.

B: Policy transfer may warrant review but is not specifically a red flag for third-party involvement.

Trade-Based Money Laundering (TBML) is a recognized method used to move and disguise illicit funds through trade transactions. Regulatory guidance from FATF highlights several red flags that may indicate TBML risks.

Irregular or inconsistent trade volume and frequency that deviates from a counterparty’s historical activity can suggest artificial or manipulated transactions. This behavior may indicate over- or under-invoicing or fictitious trade.

Structuring transactions below reporting thresholds, such as repeated cash deposits just under regulatory limits, is a classic money laundering technique used to avoid detection and reporting obligations.

Engaging in unusual shipping routes, methods, or counterparties that do not align with normal business practices is another key TBML indicator. Criminals often use complex or illogical logistics to obscure the true nature of transactions.

Conversely, detailed trade documentation and transparent pricing with proactive explanations are indicators of legitimate trade activity and reduce AML risk rather than increase it.

Countries that are members of the Egmont Group can securely exchange information between their Financial Intelligence Units (FIUs) to support money laundering and terrorist financing investigations, even when the activity involves multiple jurisdictions.