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CAMS Certified Anti-Money Laundering Specialist (CAMS7 the 7th edition) Questions and Answers

Questions 4

To provide aid in investigating a cross-border money laundering case, a Financial Intelligence Unit (PIU) that is a member of the Egmont Group can:

Options:

A.

directly contact financial institutions in another country and share information pertinent to the investigation.

B.

directly contact other FlUs in another country and share information pertinent to the investigation.

C.

deputize its law enforcement investigators to assist in a material ongoing investigation in another country

D.

assist law enforcement in another country with a material ongoing investigation.

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Questions 5

Which of the following scenarios warrants enhanced due diligence (EDD)? (Select Three.)

Options:

A.

An existing local league footballer trying to open a bank account with a bank in their local jurisdiction

B.

The current prime minister of a country trying to open a bank account in another country

C.

The former personal secretary to the minister of transport in a low-risk country 25 years ago opening a bank account at a bank in a neighboring low-risk country

D.

A bank located in a higher risk country trying to establish a correspondent-respondent banking relationship with a bank in a lower-risk country

E.

An individual with a current bank account who resides in one country becoming the ambassador of another country

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Questions 6

Country A's anti-corruption authority has been investigating the movement of potential proceeds of bribery and corruption to Country B and is now preparing to take the case to a local court.

Which method of obtaining the required evidence to prosecute the case would be most effective?

Options:

A.

Make an official request directly from the head of Country A's anti-corruption authority to Country B's corresponding law enforcement authority

B.

Make a request for the required evidence using Country A's mutual legal assistance treaty with Country B

C.

Use the International Criminal Police Organization (INTERPOL) network to obtain the required evidence from Country B

D.

Use the Egmont Secure Web to obtain the required evidence from Country B's financial intelligence unit

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Questions 7

Cryptocurrency-related technologies that can be exploited by money launderers include: (Select Two.)

Options:

A.

generative copilots.

B.

small language models.

C.

privacy coins.

D.

crypto-mixers.

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Questions 8

Under the Egmont Group Principles, information exchange among financial intelligence units (FIUs) should be conducted:

Options:

A.

Without the expectation of reciprocity on how the information will be used.

B.

Only if the status of the foreign FIU is related to law enforcement.

C.

Freely, spontaneously, and upon request, on the basis of reciprocity.

D.

With set limits on the amount of financial and administrative information provided.

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Questions 9

The US Department of the Treasury notes that which of the following represent high money laundering risk when de-risked from traditional financial institutions (FIs)? (Choose two.)

Options:

A.

Money services business (MSB)

B.

Multinational corporations

C.

Individual foreign customers

D.

Non-profit organizations with international operations

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Questions 10

Which of the following programs would most likely be considered part of an effective supervision regime for a regulator?

Options:

A.

Onsite and offsite reviews, cooperating on an international basis with access to a range of sanctions and outreach

B.

Onsite and offsite reviews, cooperating on an international and domestic basis with access to a range of sanctions and outreach

C.

Offsite reviews, cooperating on a domestic basis with access to a range of sanctions and outreach

D.

Onsite reviews, cooperating on an international and domestic basis with outreach and access to a range of sanctions

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Questions 11

An employee in a corporation's finance department hears news of an internal investigation into potential fraud within the company, quits her job, and disappears.

If they had been observed before her resignation, which characteristics of the employee would have been considered red flags? (Select Two.)

Options:

A.

The employee was originally from a high-risk jurisdiction

B.

The employee had friends in high-risk industries

C.

The employee had a lavish lifestyle for her income

D.

The employee was constantly evasive about the reasons for leaving her previous corporate finance job

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Questions 12

The UN Security Council's primary role in imposing sanctions is that it has the authority to:

Options:

A.

impose sanctions lo maintain of restore international peace and security

B.

impose sanctions on countries that lack AML/CFT controls.

C.

conduct research on and analyze the impacts of sanctions to improve the effectiveness of sanctions regimes.

D.

impose sanctions on economic targets to maintain or restore financial stability within a country.

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Questions 13

Which services provided by an accounting firm could be considered as higher risk from a financial crime perspective? (Choose three.)

Options:

A.

Forming a trust on behalf of a customer with a complex setup and acting as a nominee director

B.

Auditing a firm that provides payroll software to large corporate customers

C.

Preparing financial statements for a listed or a privately owned firm

D.

Providing tax advice to an international customer hoping to move their assets out of their home country

E.

Assisting an offshore corporation from a jurisdiction with no available beneficial owner information to buy property in the UK

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Questions 14

When deciding on the fuzzy matching threshold for sanctions screening, consideration should be given to:

Options:

A.

the operational burden of dealing with potential matches.

B.

the value of fines for non-compliance.

C.

the experience of the team dealing with potential matches.

D.

whether the data to be screened is reliable and verified.

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Questions 15

Which operational situation might indicate that money laundering is occurring at or through a deposit-taking financial institution?

Options:

A.

The institution has observed an increase in customer demand for large-denomination banknotes.

B.

The institution maintains a sequentially numbered log of the monetary instruments it sells.

C.

The institution has observed a reduced settlement time in the transaction services that support the rapid movement or remittance of funds.

D.

The institution has observed an increase in the adoption of its digital products and services.

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Questions 16

The supply of goods and services can be vulnerable to corruption within a company, particularly the solicitation and receipt of bribes and kickbacks, because: (Choose two.)

Options:

A.

certain contractors may receive preferential treatment, allowing them opportunities to inflate margins during the tender process

B.

unsuccessful bidders are informed of decisions and provided detailed justifications for awarding the contracts

C.

procurement and contracting processes involve the management of the tender process, which may lack sufficient oversight

D.

bids are solicited and disseminated to a wide audience through advertising and other channels.

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Questions 17

Which money laundering risks are posed by the misuse of trust and asset management services? (Select Three.)

Options:

A.

Concealing sources of funds

B.

Allowing for third-party custody safekeeping of funds

C.

Adding a layer of anonymity to transactions

D.

Concealing true legal and beneficial owners

E.

Establishing escrow accounts for real estate transactions

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Questions 18

The owner of a real estate investment company deposits multiple cashier's checks that were bought using cash over a three-month period, from the sale of two apartments. This account also receives several electronic transfers from other financial institutions for US$10,000 each.

What activity is considered suspicious of money laundering?

Options:

A.

Receiving electronic transfers for US$10,000 amounts from other financial institutions

B.

Using cash to buy multiple cashier's checks over a period of time

C.

Performing operations with real estate investment companies

D.

Using cashier's checks in the transactions with the real estate investment company's account

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Questions 19

When applying new technologies to AML, application programming interfaces (APIs) allow for:

Options:

A.

Digital identification on mobile devices

B.

Different applications to connect and communicate

C.

Authentication via artificial intelligence (AI) and biometrics

D.

Quick CDD and client traits analysis during onboarding

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Questions 20

The Office of Foreign Assets Control (OFAC) is responsible for:

Options:

A.

Ensuring an effective export control and treaty compliance system

B.

Administering and enforcing economic and trade sanctions

C.

Designating jurisdictions as primary money laundering concerns

D.

Managing trade agreements between the US and foreign countries

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Questions 21

Based on the AML principles outlined by the Wolfsberg Group, what do private and correspondent banks have in common when monitoring for terrorist financing?

Options:

A.

Cash access from a pre-paid card increases the potential that the card will be used for money laundering purposes.

B.

Transaction monitoring examines the relationship between due diligence information and account closings.

C.

Account and transactional activity are monitored after the proper identification and verification of customers.

D.

Numbered or alternate name accounts will only be accepted if the bank has established the identity of the client and beneficial owner.

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Questions 22

Which of the following statements is true regarding the 2012 Financial Action Task Force (FATF) 40 Recommendations and'or 11 Immediate Outcomes?

Options:

A.

The 40 Recommendations have not been updated to reflect the impact of new technology

B.

Each jurisdiction can reach out to the FATF for private access to the interpretive notes to the 40 Recommendations

C.

The 11 Immediate Outcomes are recommendations specific to high-risk jurisdictions requiring enhanced monitoring.

D.

The cornerstone of the 40 Recommendations is the adoption of a risk-based approach by each jurisdiction

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Questions 23

A multinational corporation is considering expanding into a new market with a history of political instability and corruption.

Which strategy would be most effective in mitigating reputational risk from a financial crime perspective associated with such an expansion?

Options:

A.

Ensure the jurisdiction risks and other relevant factors have been taken into consideration in the EWRA and the residual risks are within the corporation's risk appetite

B.

Partnering with established local businesses to leverage their knowledge and connections while sharing risks

C.

Ensuring the company has strong ties with local government officials to influence policy and avoid negative scrutiny

D.

Committing to open communication, ethical practices, and community engagement to build trust with stakeholders

E.

Minimizing the company's direct presence in the country to reduce exposure to potential risks

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Questions 24

Which of the following are common indicators of possible money laundering within the securities industry? (Select Two.)

Options:

A.

Receiving securities into an existing brokerage account following the death of a spouse

B.

Allowing fixed income securities to mature

C.

Using brokerage accounts like deposit accounts

D.

Engaging in transactions involving nominees or third parties

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Questions 25

A law enforcement agency submits several requests to a financial institution.

Which request is legitimate and requires the bank to respond?

Options:

A.

Keep an account open upon verbal request

B.

Produce documents and testimony without a subpoena

C.

Seize privileged documents upon written request

D.

Freeze an account in terms of a court order

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Questions 26

A large international bank's chief compliance officer (CCO) is exploring ways to enhance the bank's ability to identify suspicious activities by using intelligence data more effectively. One potential solution is to engage in public-private partnerships (PPPs) to leverage shared intelligence and enhance collaboration with government agencies.

The bank considers joining a PPP initiative with the local Financial Intelligence Unit (FIU) and other financial institutions to improve its access to relevant data and intelligence. The CCO understands that while PPPs can provide significant benefits, such as improved risk detection and enhanced information sharing, there are also potential limitations, including data privacy concerns and differing priorities between public and private sector partners.

Which approach would best maximize the benefits of PPPs for the bank while mitigating the limitations associated with data sharing and intelligence?

Options:

A.

Engage in the PPP without strict data sharing protocols, allowing for open and unrestricted flow of information between the bank, FIUs, and other financial institutions

B.

Rely solely on the intelligence provided by government agencies through the PPP because they have the most comprehensive data on suspicious activities

C.

Establish a clear framework within the PPP that outlines data privacy protections and ensures that information sharing complies with legal and regulatory requirements in all jurisdictions involved

D.

Prioritize the bank’s internal data sources over external intelligence from PPPs, as internal data is easier to control and does not present data privacy challenges

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Questions 27

Which statement best describes a key money laundering risk associated with virtual asset service providers (VASPs), cryptoassets, and related products?

Options:

A.

Cryptoassets can be transferred across borders quickly, but the volatility of their value still makes them less attractive for money laundering compared to traditional assets

B.

Mandatory reporting requirements have been implemented for certain types of crypto transactions, but gaps in regulation and enforcement still leave room for money laundering activities.

C.

The transparency of blockchain technology helps law enforcement trace transactions, but it can also provide criminals with ways to obscure their financial activities through complex layering techniques.

D.

The pseudonymous nature of transactions allows criminals to hide their identities while transferring large sums of money globally, making it difficult to trace the ultimate beneficial owner.

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Questions 28

According to the Financial Action Task Force's (FATF's) "Guidance for a Risk-Based Approach Life Insurance Sector," which of the following are money laundering red flags relating to the involvement of a third party in a life insurance product? (Select Two.)

Options:

A.

A customer engages an attorney to consult on the issuance of the policy.

B.

A customer transfers the policy to another insurance company unaffiliated with the original policy issuer.

C.

Payments are regularly received from third parties that have no apparent relationship with the policy holder.

D.

A customer names an apparently unrelated third party as a beneficiary.

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Questions 29

Which of the following measures can help maintain the independence of BSA/AML compliance staff to ensure effective compliance controls?

Options:

A.

Establishing BSA/AML compliance staff reporting to the management of the business line in the first line of defense

B.

Ensuring BSA/AML compliance staff is primarily outsourced

C.

Providing BSA/AML compliance staff a reporting line to compliance or other second line of defense internal control function

D.

Providing BSA/AML compliance staff with a reporting line to the chief financial officer

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Questions 30

Which of the following are considered best practices regarding senior management involvement in a financial crime compliance program? (Choose two.)

Options:

A.

Setting tone from the top

B.

Mandatory participation in all regulatory inspections

C.

Mandatory attendance and review of all financial crime trainings

D.

Setting clear criteria for escalations to senior management

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Questions 31

Which changes at a financial institution (FI) should trigger an enterprise-wide reassessment of its inherent AML risk exposure? (Select Three.)

Options:

A.

Introduction of new products or services

B.

Mergers or acquisitions

C.

Restructuring of the FI's risk and compliance functions

D.

Use of new technologies for delivering existing products

E.

Changes in the individuals overseeing the FI's product lines and sales strategies

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Questions 32

Which scenario indicates potential money laundering activity by a lawyer?

Options:

A.

A lawyer located in a higher risk country deposits their firm's bank draft issued from their trust account to another lawyer's trust account located in a low-risk country for legal services rendered.

B.

A lawyer's trust account regularly receives wire transfers from unknown remitters from a higher risk country and immediately transfers the same amount of funds received to a known beneficiary's account in a low-risk country.

C.

A lawyer's trust account receives a large-value wire transfer from a regulated insurance company and immediately transfers the same amount of funds received to the beneficiary's bank account located in a low-risk country.

D.

A lawyer's trust account receives a large wire transfer deposit from a client that wanted to purchase a piece of property and then transfers the same amount to the property seller's lawyer's trust account.

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Questions 33

An EU Trust and Company Service Provider analyst notices some unusual activity while looking through a customer's financial statements and detailed general ledger. The customer is in the business of importing and exporting machineries.

Which transaction indicator warrants further escalation to the compliance officer?

Options:

A.

The payment of company secretarial retainer fees to a foreign company in a tax-efficient jurisdiction

B.

The payment of virtual offices services overseas

C.

Inter-company loans from the holding company to the subsidiary company to finance the shipment of machinery

D.

The payment of consultancy fees to unrelated companies and service providers established in a foreign jurisdiction

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Questions 34

A financial institution's US Branch receives a subpoena from law enforcement requesting detailed records of a customer's account activity. The customer is part of an ongoing investigation into a money laundering operation. At the same time, the institution has received a FinCEN 314(b) information-sharing request from another bank seeking details on transactions linked to the same customer. The compliance team is tasked with responding to both the subpoena and the FinCEN 314(b) request.

What should the compliance officer prioritize in responding to these requests while ensuring that all legal and regulatory obligations are met?

Options:

A.

Notify the customer of the information-sharing request from the other financial institution and seek their consent before responding

B.

Consult the institution's legal counsel to validate the subpoena, then respond directly to law enforcement while ensuring all documentation is properly recorded

C.

Respond to the FinCEN 314(b) request first, as it allows for voluntary information sharing with partner organizations

D.

Provide the requested records to both law enforcement and the other financial institution immediately to ensure full cooperation and transparency

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Questions 35

Which of the following actions is specifically permitted or required under FinCEN section 314(b) for financial institutions (FIs) to enhance their efforts in combating money laundering and terrorist financing?

Options:

A.

FIs may disclose customer information to any third party

B.

FIs may provide information about their internal compliance programs to law enforcement agencies without any limitations

C.

FIs are required to report all transactions involving foreign entities to FinCEN so that FinCEN can share this information with other financial institutions

D.

FIs may share information about suspected money laundering activities with other FIs to aid in identifying and reporting suspicious transactions

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Questions 36

Which should be provided to the board of directors or designated specialized committee when preparing suspicious activity reports (SARs)?

Options:

A.

Statistical data regarding SARs filed during the reported period

B.

All possible details of SARs filed during the reported period

C.

Copies of all SARs filed during the reported period

D.

Names of all customers subject to SARs filed during the reported period

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Questions 37

Which techniques would be most efficient for a complex investigation of unusual patterns of activity involving multiple businesses, triggered by an automated monitoring system alert? (Select Two.)

Options:

A.

Perform a control and ownership assessment of the businesses involved, using the information available in the client files

B.

Contact local law enforcement and request that they assist in the analysis and investigation

C.

Review the information presented in the automated monitoring system's alert description and decline any future transactions

D.

Contact the account manager and ask for the reasons behind the patterns of activity highlighted in the AML alerts

E.

Use social media platforms to connect with the businesses and request details about the account activity

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Questions 38

A compliance analyst has recently investigated an account where money was deposited in amounts below the reporting limit and almost entirely withdrawn in a foreign country.

Which type of money laundering is the compliance analyst potentially identifying?

Options:

A.

Trade-based

B.

Check Kiting

C.

Microstructuring

D.

Structuring

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Questions 39

Which of the following ate efficient approaches lo performing horizon scanning? (Select Two.)

Options:

A.

Subscribing lo a regulators' newsletter

B.

Using a specific provider for regulatory horizon scanning

C.

Regularly contacting the regulator to inquire about updates and future developments

D.

Relying on information and insights from peers and working groups

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Questions 40

Which of the following are key components of the Know Your Customer (KYC) process? (Select Two.)

Options:

A.

Inquiring about the source of wealth and source of funds

B.

Asking to provide a list of immediate family members

C.

Verifying the financial crime awareness of the client

D.

Collecting necessary documents to verify the veracity of information

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Questions 41

The Wolfsberg Group's AML Principles on Private Banking:

Options:

A.

Assist financial institutions conducting business in jurisdictions with high data privacy standards in working with industries susceptible to money laundering

B.

Advise banks to accept only those clients whose source of funds and beneficial ownership is understood

C.

Establish rules for private bankers on how to deal with politically exposed persons (PEPs) and persons residing in high-risk countries

D.

Require banks to better manage reputational risk and protect the privacy of wealthy clients

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Questions 42

When services are provided by a trust and company service provider (TCSP) connected to a high-risk country, which of the following may present an immediate financial crime risk concern?

Options:

A.

Management structure

B.

Governance framework

C.

Asset structure

D.

Origin of the funds

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Questions 43

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?

Options:

A.

Document the customer's transaction history and keep the investigation confidential until further suspicious activity is detected.

B.

Immediately escalate the case to senior management, recommending the closure of the customer's accounts due to potential reputational risk.

C.

Report the investigation to external auditors and await further guidance before taking any action.

D.

Draft a SAR that includes a detailed chronology of the transactions, customer background and the rationale for suspicion, and submit it to the relevant financial intelligence unit (FIU) within the regulatory timelines.

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Questions 44

Which of the following is a benefit of an institution implementing machine learning to identify suspicious transactions?

Options:

A.

Adaptable to new AFC typologies through continuous model training

B.

Completely unbiased and without error through continuous model training

C.

More consistent and reliable detection outcomes

D.

Transparent and easy to explain algorithms for regulator and compliance purposes

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Questions 45

When making an independent determination on whether to close an account based on an internal Investigation, a financial institution (F1) should consider. (Select Five.)

Options:

A.

reputational risk.

B.

the customers personal relationships.

C.

the frequency of account activity

D.

the Fl's policies and procedures.

E.

the seriousness of the underlying conduct.

F.

correspondence with law enforcement

G.

the legal basis for closing the account.

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Questions 46

A bank has been fined for failing to take reasonable care to establish and maintain effective systems and controls for high-risk customers, including politically exposed persons (PEPs).

Which typical financial crime risks should the bank have addressed? (Choose three.)

Options:

A.

Gathering sufficient information to establish the source of funds and source of wealth

B.

Assessing the level of money laundering risk posed by prospective and existing high-risk customers

C.

Assessing and reviewing the minutes of the relevant committee responsible for onboarding customers

D.

Ensuring an employee is responsible for liaison with the authorities on matters related to countering the finance of terrorism

E.

Ensuring that resources in its compliance and AML areas kept pace with the bank's growth

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Questions 47

A trust and company services provider that offers a variety of services to businesses is approached by a client interested in establishing a new company. The client requests assistance with the incorporation process, a local business address, annual maintenance services, and the designation of individuals to serve in official capacities for the new company.

Which of the following services involves a higher money laundering risk?

Options:

A.

Appointing individuals to serve in official capacities of the company

B.

Annual maintenance services

C.

Provision of a local business address

D.

Company incorporation services

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Questions 48

What are the primary sources of reference besides AML laws and regulations when developing and maintaining the AML policies, standards, and procedures of a bank? (Choose three.)

Options:

A.

National Risk Assessment

B.

Regulatory guidance or publications

C.

Government or state-run newspapers

D.

Guidance issued by international bodies

E.

Policies and procedures developed by other banks

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Questions 49

A compliance officer at a financial institution has completed an investigation into a high-risk customer's activities and determined that there are strong indications of money laundering. The compliance officer has documented their findings and is ready to recommend offboarding the customer. However, the relationship manager responsible for the customer is resistant to the idea, citing the customer’s significant revenue contribution to the institution.

What should the compliance officer do next to ensure the appropriate escalation and decision-making process is followed?

Options:

A.

Escalate the matter to the institution's high-risk client committee, presenting the investigation findings and recommending offboarding while also acknowledging the relationship manager's concerns

B.

Proceed with offboarding the customer unilaterally based on their investigation findings and anti-money laundering (AML) concerns

C.

Attempt to persuade the relationship manager to agree with the offboarding recommendation by highlighting the potential reputational and regulatory risks associated with maintaining the relationship

D.

Delay the offboarding decision and continue monitoring the customer's activities, waiting for further evidence to solidify the case for termination

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Questions 50

When the Financial Action Task Force (FATF) places a jurisdiction on the list of "jurisdictions under increased monitoring," also known as the "grey list," the jurisdiction:

Options:

A.

Accepts to participate in an off-cycle FATF mutual evaluation to be held within the next 12 months.

B.

Must pay a fine to be removed from the list before the next FATF plenary.

C.

Has committed to swiftly resolving the deficiencies identified in a FATF mutual evaluation.

D.

Poses a high money laundering, terrorist financing and proliferation financing risk and must be restricted from accessing the international financial system.

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Questions 51

A recruitment manager in the human resources department of a bank has shortlisted a candidate for the position of relationship manager in its private banking division. The compliance policy of the bank stipulates that proper background checks on new employees

must be completed by the recruiting team to protect the bank against potential risks, including fraud and money laundering.

Which resources would be most useful for identifying any potential negative information regarding the shortlisted candidate? (Select Three.)

Options:

A.

Criminal history searches

B.

Personal resume

C.

Internet and public media searches

D.

Past employment records

E.

Personal references from close associates

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Questions 52

A bank has joined a public-private partnership (PPP) to work with law enforcement and regulators on combating financial crime. However, the bank's data protection officer is concerned about sharing sensitive customer data, and the compliance officer is worried about potential delays in receiving useful information from the government.

Which of the following best describes a benefit of PPPs in fighting financial crime?

Options:

A.

PPPs improve financial crime detection and prevention by sharing intelligence between banks and law enforcement.

B.

PPPs help banks reduce compliance costs by automating information sharing.

C.

PPPs allow banks to manage their own suspicious activity report (SAR) filing process without the need to involve the Financial Intelligence Unit (FIU).

D.

PPPs maximize the efficiency of the bank's compliance program by providing real-time intelligence from law enforcement.

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Questions 53

Which of the services provided by Trust and Company Service Providers (TCSPs) present the greatest financial crime risks? (Choose three.)

Options:

A.

Providing clear procedures to ensure compliance with local tax regulations

B.

Using trusts to obscure the identity of beneficial owners

C.

Promoting the use of complex corporate structures

D.

Maintaining accurate and updated beneficial ownership details for all customers registered for their services

E.

Establishing shell companies for holding financial assets

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Questions 54

Which collective body of Financial Intelligence Units (FlUs) was formed with an objective to improve Information exchange and sharing mechanisms among member FlUs as well as to support its members by enhancing their capabilities'?

Options:

A.

The Organisation for Economic Co-operation and Development (OECD)

B.

The Egmont Group

C.

The Wolfsberg Group

D.

The International Monetary Fund (IMF)

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Questions 55

Which activities are part of adverse media screening for negative news and reputational risks? (Select Three.)

Options:

A.

Analyzing customer sentiment through feedback and surveys

B.

Identifying individuals or entities linked to criminal activities or sanctions

C.

Periodically monitoring regulatory updates and enforcement actions for associated entities

D.

Scanning publicly available news articles and regulatory alerts

E.

Monitoring changes in credit scores of individuals or entities

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Questions 56

A risk-based approach (RBA) to anti-financial crimes (AFC) involves understanding and managing risks by:

Options:

A.

applying uniform controls to all customers, regardless of their risk profile

B.

allocating resources and implementing controls based on the level of identified risks

C.

prioritizing regulatory compliance over customer experience and operational efficiency

D.

relying on automated systems to detect and mitigate AFC risks

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Questions 57

Which risk factors should a financial institution (FI) examine for a new corporate customer intending to open a new bank account? (Select Three.)

Options:

A.

All the financial institutions where the new customer currently banks or banked previously

B.

The type of business the corporate customer is engaged in

C.

The employment profiles and information of all employees of the new customer

D.

The country or location where the customer is from or conducts business

E.

The identity of senior managing officials and all individuals authorized to operate the account

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Questions 58

A key advantage of privacy enhancing technologies (PETs) in anti-money laundering is that they offer:

Options:

A.

simultaneous encryption and decryption for underlying data.

B.

full access to underlying data with full and uninterrupted calculations made on the data.

C.

secure processing of data while it remains encrypted.

D.

transfer, decryption and storage of data by the data processor.

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Questions 59

Professions such as lawyers, accountants, and trust and company service providers (TCSPs) are sometimes referred to as "gatekeepers" because they:

Options:

A.

often do not understand and are not covered by money laundering laws and regulations, unwittingly allowing criminals to enter the legitimate economy.

B.

are an entry point to the financial system and a first line of defense against the infiltration of illicit funds into the legitimate economy.

C.

are required under money laundering laws and regulations in all jurisdictions to stop any criminals from being able to integrate illicit funds into the legitimate economy.

D.

are high-risk actors who can deliberately allow criminals to enter the legitimate economy.

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Questions 60

Common risks associated with cryptocurrency and convertible virtual currencies include: (Choose three.)

Options:

A.

funds being stolen from other users.

B.

obscuring the source of illicit funds.

C.

layering transactions to hide the origin of funds derived from illicit activity.

D.

difficulty converting into physical currency.

E.

facilitating payment for other illicit activities and goods.

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Questions 61

The Basel Committee on Banking Supervision published guidelines on the "Sound management of risks related to money laundering and financing of terrorism."

With regard to identifying and accepting customers, it recommends that banks: (Select Two.)

Options:

A.

Establish policies and procedures to ensure due diligence activities are identical for all customers.

B.

Establish policies and procedures to identify and verify customers, beneficial owners, and any individuals that can transact on behalf of their customers.

C.

Establish policies and procedures for customer due diligence that vary based on risk.

D.

Are prohibited from offering numbered accounts to customers, even if procedures are established to gather and maintain due diligence information.

E.

Establish policies and procedures that encourage processing transactions while due diligence information is being established and verified.

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Questions 62

The purpose of a risk appetite statement is to:

Options:

A.

clearly define the level of risk exposure to financial crime which a financial institution is willing to take.

B.

help investors understand the risk a financial institution is willing to take.

C.

help customers understand which financial institutions may be willing to bank their business.

D.

eliminate high-risk business types from a financial institution.

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Questions 63

Tax evasion is:

Options:

A.

a deliberate attempt not to pay the tax which is due or obliged.

B.

bending the rules to pay less tax than required.

C.

not an important crime as it does not impact society.

D.

a sophisticated process which always means the same as tax avoidance.

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Questions 64

A National Risk Assessment (NRA) can impact a financial institution's (Fl's) risk-based approach to anti-money laundering and terrorism financing by:

Options:

A.

dictating what predicate offences must be considered in the Fl's risk assessment.

B.

providing guidance on the types of customers and transactions that pose the highest risk.

C.

defining exactly what policies and procedures must be implemented.

D.

determining the maximum fines that can be imposed for AML violations.

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Questions 65

During a routine periodic KYC refresh of a policyholder and client of an insurance company, updated business registry documentation has highlighted that the policyholder's business has changed addresses five times during the last year and that the ultimate beneficial owner (UBO) changed two weeks ago.

What actions should be taken immediately?

Options:

A.

Investigate the changes of address and change of UBO and in the meantime decline payment and withdrawal instructions from the policy until completion of the investigation and next steps are agreed upon

B.

Request the relationship manager set up a meeting with the policyholder to update their address and submit details of the new UBO in the name of good customer service

C.

Investigate the changes of address and change of UBO and in the meantime freeze the client's policy

D.

File a suspicious transaction report because the insurance company was not made aware of the business' change of UBO

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Questions 66

How should risk-related issues be addressed to ensure the effectiveness of the three lines of defense model?

Options:

A.

Ensure that the second line reviews, monitors, and escalates risk-related issues as needed to senior management while maintaining independent oversight from the third line

B.

Have senior management handle risk-related issues directly when possible because they are ultimately responsible for the organisation's overall risk management strategy

C.

Delegate some risk-related issues to the first line to avoid overwhelming the second line and to ensure operational efficiency

D.

Assign risk-related oversight duties to the third line to provide an independent review and address issues more effectively by avoiding conflicts of interest in the first and second lines

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Questions 67

Which of the below would be relevant money laundering red flags for life insurance companies? (Select Two.)

Options:

A.

Paying premium several years in advance and terminating early for a refund

B.

Natural persons having more than one insurance policy

C.

High-premium life insurances that provide high payouts

D.

Regularly switching policies and accepting penalties

E.

Beneficiary payouts to elderly people

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Questions 68

The role of FATF-style regional bodies (FSRBs) is to; (Select Three.)

Options:

A.

identify and address the current financial crime trends through the issuance of typologies originating in members outside of their FSRB's Jurisdiction.

B.

provide AM L/C FT technical assistance needed by members in their FSRB junsdiction.

C.

coordinate technical assistance for members in their FSRB jurisdiction

D.

set and amend the FATF 40 Recommendations for members in their FSRB jurisdiction.

E.

identify and address any gaps in the AML/CFT policies for members outside of their FSRB jurisdiction.

F.

offer mutual evaluation and follow-up processes for members in their FSRB Jurisdiction.

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Questions 69

An internal audit team is reviewing the anti-financial crime (AFC) program of its firm.

Which of the following attributes of the third line of defense would be most critical to ensure unbiased and effective oversight?

Options:

A.

Consistency of approach

B.

Periodic training of the function

C.

Qualification of the team

D.

Independent testing

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Questions 70

Which principle about safeguarding privacy and data should an auditor adhere to when performing an AML investigation?

Options:

A.

AML and Data Protection Privacy laws should not be mutually exclusive.

B.

During evidence gathering, privacy laws are less important than local AML laws.

C.

Terrorist financing is more relevant in the context of data protection and supersedes laws.

D.

Countries should clarify where AML and Data Protection Privacy laws are not balanced.

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Questions 71

A law enforcement action alleged that on several trading days over the course of two months, defendants engaged in a series of copper gold, crude oil. and natural gas futures transactions on an electronic trading platform One defendant repeatedly bought future contracts at low prices from the other, and then immediately sold them back at higher prices. As a result, one defendant effectively pocketed the same amount as the other lost even though there were no changes in the open positions held by either defendant.

What is a name for this typology?

Options:

A.

Short position

B.

Reverse flip

C.

Bid-ask spread

D.

Wash trading

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Questions 72

Money laundering has social and economic impacts, especially within developing countries. A high volume of money laundering in a country may: (Select Two.)

Options:

A.

Dissuade government tax incentive programs

B.

Reduce confidence in the country's financial sector.

C.

Dissuade foreign investment.

D.

Lower the employment rate.

E.

Reduce volatility in exchange and interest rates.

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Questions 73

Which of the following can be considered a reliable, independent source document, data, or information?

Options:

A.

Information provided by a prospective customer

B.

Photocopy of a copy of a government-issued identity document

C.

Information obtained from an open-source database

D.

Information obtained directly from a government-managed registry

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Questions 74

Which activities would be considered money laundering red flags when reviewing the business operations of a money services business (MSB)? (Select Two.)

Options:

A.

A customer being hesitant to provide beneficiary name or address information when sending international wire transfers

B.

Cash-intensive businesses, such as convenience stores or restaurants, making large cash deposits

C.

A customer exchanging foreign currency from a higher-risk jurisdiction for domestic currency under the reporting threshold

D.

A customer using multiple accounts under different names to conduct transactions

E.

A customer completing frequent small-dollar international money transfers to their native country

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Questions 75

Which of the following are part of a risk-based approach? (Select Three.)

Options:

A.

Determining detailed risk profiles for customers based on their activities and relationships

B.

Focusing monitoring primarily on previously flagged customers while using standard controls for others

C.

Choosing and applying effective controls that align with the identified risk levels

D.

Performing a comprehensive risk assessment to identify customer, transaction, and geographic risks

E.

Allocating resources equally across all customer segments to ensure fairness

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Questions 76

Which of the following risk factors are considered by many supervisory authorities as representing a higher inherent risk associated with MSBs? (Select Two.)

Options:

A.

The use of new technologies to facilitate the onboarding of customers remotely

B.

The prevalence of international wire transfers

C.

Domestic business with small and medium-sized enterprises

D.

The cash-intensive nature of the services offered

E.

The use of digital channels and traceable payment methods

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Questions 77

Common risks and red flags associated with trade finance clients may include: (Choose four.)

Options:

A.

account activity that is not consistent with the purpose of the account

B.

bills of lading matching the description of goods, quantities, and values with transshipment details justified

C.

transaction structures that appear unnecessarily complex

D.

trade documents, such as invoices and letters of credit, that are not clearly worded or are in foreign languages

E.

invoices with prices that are much higher than market price

F.

fluctuations in the pricing of standard goods and services

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Questions 78

The United Nations Security Council (UNSC) is empowered to impose sanctions regimes against countries and terrorist organizations.

Which statements are true regarding sanctions imposed by the UNSC? (Select Two.)

Options:

A.

Attempts to circumvent or evade sanctions imposed by the UNSC can constitute a criminal offense if designated under local laws and regulations

B.

The UN can impose arms embargoes but cannot prohibit direct or indirect exports of other goods to specific countries

C.

Member countries of the United Nations are expected to implement and enforce sanctions imposed by the UNSC

D.

Direct breaches of sanctions imposed by the UNSC constitute a criminal offense in all member countries

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Questions 79

Which customer actions are red flags for virtual currency peer-to-peer transactions? (Choose two.)

Options:

A.

A customer receives funds from a popular decentralized mixer

B.

A customer uses funds from their monthly income to purchase virtual currency

C.

A customer makes a transaction on the blockchain that their traditional financial institution is unaware of

D.

A customer receives multiple wires from different sources and uses those funds to purchase virtual currency

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Questions 80

A large financial institution (FI) is considering expanding business to an area of the world with weak AML laws. The risk-based assessment indicates that the location will increase the FI's risk appetite beyond the stated acceptable amount.

Which risk factors should be used to identify the priority of the FI?

Options:

A.

Cash-intensive businesses risks

B.

Unknown third-party risks

C.

Geographic risks

D.

Anonymous transactions risks

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Questions 81

According to the Egmont Group, which benefits do public-private partnerships (PPPs) provide to Financial Intelligence Units (FIUs)? (Select Three.)

Options:

A.

Helping overcome data protection and information sharing limitations

B.

Enhancing the quality of reporting and additional informational input

C.

Helping to alleviate the financial cost burden on law enforcement

D.

Helping to design common approaches and identify desired deliverables

E.

Offering flexibility, agility, and opportunities to adjust to the ML/TF threat environment

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Questions 82

A compliance officer is reviewing an institutional banking prospect proposal for a new foreign entity that is a multinational business but headquartered in a country where most businesses are state-owned.

Which risks should be prioritized in the review? (Choose two.)

Options:

A.

Politically exposed persons (PEPs)

B.

Capital flight risk

C.

Anti-bribery and corruption risk

D.

Tax evasion

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Questions 83

In a large US bank, an individual leads a team in charge of overseeing the governance and effectiveness of the bank's transaction monitoring approach.

Which strategies should the team implement? (Select Two.)

Options:

A.

Periodic and ad hoc cooperation with the legal team to appropriately investigate and monitor the transactions of subjects of subpoenas or government inquiries

B.

Periodic review of client profiles to ensure that the most up-to-date information is on file for high-risk clients in line with the bank's internal policies and procedures

C.

Periodic review of suspicious activity reports (SARs) filed with FinCEN to determine whether any should be withdrawn

D.

Periodic review of the transaction monitoring scenarios and their productivity to ensure that appropriate AML typologies are reflected

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Questions 84

Which section of the USA PATRIOT Act relates to forfeiture of funds and allows for extraterritorial reach?

Options:

A.

Section 319(b)

B.

Section 314(b)

C.

Section 314(a)

D.

Section 319(a)

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Questions 85

Using artificial intelligence (Al) and machine learning-based techniques tn adverse media screening can: (Choose three.)

Options:

A.

ensure that all adverse media sources are comprehensively analyzed without the need for human review.

B.

significantly reduce human errors arising from repetitive tasks by delivering consistent and highly accurate analysis.

C.

instantly identify intent behind media articles, allowing for more effective risk scoring.

D.

automate the process of identifying new information and distinguishing it from previously encountered data.

E.

cover multiple languages and scripts, surpassing the limitations of human linguistics.

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Questions 86

Which statements regarding using network analysis tools to determine links to criminality are true? (Choose three.)

Options:

A.

When using network analysis data to fight money laundering and financial crime, data protection and privacy can be disregarded because fighting crime takes precedent

B.

Network analysis tools are an efficient means of generating relevant results because they only need a limited amount of data and computation power and artificial intelligence (Al) allows less-skilled people to quickly learn to use these systems

C.

When using artificial intelligence (Al) with network analysis tools, it must be ensured that the algorithms used are not biased towards social criteria, such as race, gender, or religion

D.

Network analysis allows for the identification of individuals or entities in a network by analyzing connections or links between them and can be used to study a wide range of systems, such as social or transportation networks

E.

Analyzing relationships between individuals in a social network allows for the identification of hierarchies, the detection of behaviors and geographical movements, or an understanding of how groups are organized

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Questions 87

Which of the following best describes the degree of cooperation between regulatory authorities, law enforcement agencies, and Financial Intelligence Units (FIUs) during money laundering investigations, including cross-border cases?

Options:

A.

Regulatory authorities primarily work independently but share information when requested by international law enforcement agencies.

B.

FIUs primarily handle reporting from financial institutions, while regulatory authorities and law enforcement agencies are limited to enforcing domestic AML laws without international cooperation.

C.

Law enforcement agencies and FIUs only cooperate during domestic investigations, leaving cross-border investigations to international organizations like INTERPOL.

D.

Regulatory authorities, law enforcement agencies, and FIUs share intelligence and coordinate efforts to streamline cross-border money laundering investigations, often through formal agreements.

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Questions 88

A bank organized under foreign law and located outside of the US maintains a correspondent banking relationship with a US-based bank to handle financial transactions in US dollars for its clients. In compliance with the USA PATRIOT Act of 2001, all US banks and broker-dealers in securities must obtain a signed certification from all non-US foreign bank clients conducting business with them.

What information does the USA PATRIOT Act of 2001 require the foreign bank to certify to the US bank? (Select Three.)

Options:

A.

The foreign bank will not allow indirect use of the correspondent bank accounts by Politically Exposed Persons (PEPs)

B.

The jurisdictions in which the foreign bank maintains a physical presence

C.

The foreign bank's operations will be limited to the country of incorporation

D.

The ownership details of the foreign bank

E.

The foreign bank will not allow indirect use of the correspondent bank accounts by shell banks

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Questions 89

Financial crime risk related to the use of "hawalas" can stem from: (Choose two.)

Options:

A.

remote verification of identity by third-party program managers

B.

heavy usage by senior political figures.

C.

heightened risks of returned transactions.

D.

informal networks used for cross-border transactions outside of the formal banking system

E.

difficulty in tracking the originator recipient, and source of transactions.

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Questions 90

One key aspect of promoting an enterprise-wide compliance culture within a financial institution is that the:

Options:

A.

Relevant information should be shared throughout the organization.

B.

Revenue-generating business sectors should have precedence over compliance.

C.

First line of defense should establish its own policies independently.

D.

Cost of compliance should increase proportionately to revenues.

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Questions 91

As emphasized in the Basel Committee guidance for "Sound management of risks related to money laundering and financing of terrorism", the third line of defense, or audit function, should:

Options:

A.

Conduct AML audits no less often than every 12 months for consistency in annual reporting.

B.

Remain independent from expressing opinions on the sufficiency of remediation or action plans to address findings and recommendations.

C.

Be involved in the day-to-day operations of the AML program to immediately prevent control failures.

D.

Report to the audit committee of the board of directors to maintain independence.

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Questions 92

Perpetual KYC includes: (Choose two.)

Options:

A.

triggers identifying static data changes and data based on client's behaviors in real time.

B.

periodic refreshing at one-, three- and five-year cycles.

C.

ability to prioritize better based on client data rather than driven by schedules alone.

D.

classification of clients into categories of risk.

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Questions 93

The UN Security Council's primary role in imposing sanctions is that it has the authority to:

Options:

A.

impose sanctions to maintain or restore international peace and security.

B.

impose sanctions on countries that lack AML/CFT controls.

C.

conduct research on and analyze the impacts of sanctions to improve the effectiveness of sanctions regimes.

D.

impose sanctions on economic targets to maintain or restore financial stability within a country.

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Exam Code: CAMS
Exam Name: Certified Anti-Money Laundering Specialist (CAMS7 the 7th edition)
Last Update: Nov 20, 2025
Questions: 313
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