ACAMS Certified Anti-Money Laundering Specialist v6 Exam Practice Test

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Question 1

Findings from a regulatory examination report states that the job descriptions of personnel outside of the

compliance department do not include references to anti-money laundering responsibilities.

Which action should the firm take?

AUpdate all job descriptions to include anti-money laundering responsibilities

BRespond that only compliance personnel have anti-money laundering responsibilities

CSend an email to all staff stating that personnel must observe the anti-money laundering policy

DReply that a description of anti-money laundering responsibilities is included in the annual training

Answer : A

According to the ACAMS Study Guide, one of the essential elements of an effective anti-money laundering (AML) program is to assign clear roles and responsibilities to all staff members, regardless of their position or department1. This ensures that everyone is aware of their obligations and expectations in relation to AML compliance, and that they receive appropriate training and guidance. Therefore, the firm should update all job descriptions to include references to AML responsibilities, such as identifying and reporting suspicious activity, conducting customer due diligence, and adhering to AML policies and procedures.

The other options are not sufficient or correct, because:

B . Responding that only compliance personnel have AML responsibilities is incorrect, because AML compliance is not only the responsibility of the compliance department, but of the entire organization1. All staff members should be involved in the AML program and contribute to its effectiveness.

C . Sending an email to all staff stating that personnel must observe the AML policy is not sufficient, because it does not specify what the AML policy entails, or how it applies to different roles and functions. An email is also not a permanent or formal way of communicating AML responsibilities, and it may not reach all staff members or be taken seriously.

D . Replying that a description of AML responsibilities is included in the annual training is not sufficient, because it does not address the issue of the job descriptions, which should reflect the AML responsibilities of each position. Moreover, annual training may not be frequent or comprehensive enough to cover all aspects of AML compliance, and it may not be tailored to the specific needs and risks of each role or department.

1: ACAMS Study Guide, 6th Edition, Chapter 2: Developing an Effective Anti-Money Laundering Program, page 49.

Question 2

A newly appointed senior money laundering reporting officer (MLRO) at a digital bank has been instructed to implement an effective AML transaction monitoring system.

What are important considerations for selecting and implementing the AML system? (Select Two.)

AWhether the monitoring system is adequate with respect to the bank's size, activities, complexity, and risks.

BWhether the vendor has documented appropriate internal controls for designing the system and data integration schema.

CWhether the permissions and user access settings for reviewing, investigating, and reporting details of alerts generated by the system are commensurate with those in use at other banks.

DWhether the monitoring system can be configured to enable the bank to execute trend analysis of transaction activity and to identify unusual business relationships and transactions.

Answer : A, D

An effective AML transaction monitoring system must align with the bank's operational complexity, risk exposure, and analytical capabilities.

Option A (Correct): The system must be tailored to the bank's specific risk profile to ensure effectiveness.

Option D (Correct): A strong AML system should support trend analysis to identify long-term suspicious behaviors.

Why Other Options Are Incorrect:

Option B (Incorrect): While vendor controls are important, they do not determine system suitability.

Option C (Incorrect): User access settings should be based on the bank's internal risk framework, not industry standards alone.

Best Practices for Implementing an AML Monitoring System:

Ensure scalability to adapt to evolving financial crime risks.

Leverage AI and machine learning to enhance detection accuracy.

Integrate real-time screening and transaction trend analysis.

FATF Recommendation 10 (Customer Due Diligence & Monitoring)

Wolfsberg Group Guidance on AML Technology Implementation

Basel Committee's Guidelines on Transaction Monitoring System Effectiveness

Question 3

Which statement is the most accurate in describing who must comply with Office of Foreign Assets Control (OFAC) sanctions?

AAll U.S. citizens and permanent residents regardless of where they are located, all U.S.-incorporated entities and their foreign branches, and all individuals and entities within the United States.

BAll U.S. citizens and permanent residents regardless of where they are located, all U.S.-incorporated entities excluding their foreign branches, and all individuals and entities within the United States.

CAll U.S. citizens except those with dual nationality, U.S. permanent residents, all U.S.-incorporated entities, and all individuals within the United States.

DAll U.S. citizens and permanent residents while located in the U.S., all U.S.-incorporated entities and their foreign branches, and all individuals within the United States.

US. Sanctions Compliance Framework by OFAC

Answer : A

OFAC sanctions apply extraterritorially, meaning U.S. persons must comply regardless of their location.

Option A (Correct): OFAC sanctions apply to all U.S. citizens, permanent residents, entities incorporated in the U.S. (including foreign branches), and individuals/entities within U.S. jurisdiction.

Option B (Incorrect): Foreign branches of U.S.-incorporated entities must comply with OFAC sanctions.

Option C (Incorrect): OFAC sanctions apply to all U.S. citizens, including dual nationals.

Option D (Incorrect): U.S. citizens and permanent residents must comply with OFAC sanctions even when located abroad.

Best Practices for OFAC Compliance:

Screen all transactions against the Specially Designated Nationals (SDN) list.

Ensure compliance programs extend to foreign branches and subsidiaries.

Monitor international business activities for potential sanctions violations.

OFAC Sanctions Guidelines (U.S. Treasury Department)

FATF Recommendation 7 (Targeted Financial Sanctions Compliance)

Question 4

Which section of the USA PATRIOT Act permits the U.S. government to seize funds deposited in a U.S. correspondent account of a foreign bank, creating extraterritorial impact?

ASection 319(b)

BSection 314(b)

CSection 314(a)

DSection 319(a)

Answer : A

Section 319(b) of the USA PATRIOT Act allows U.S. authorities to seize funds from correspondent accounts held by foreign banks in the U.S.

Option A (Correct): Section 319(b) grants the U.S. government authority to seize assets in U.S. correspondent bank accounts belonging to foreign financial institutions involved in illicit activities.

Option B (Incorrect): Section 314(b) facilitates voluntary information sharing among financial institutions but does not authorize asset seizure.

Option C (Incorrect): Section 314(a) relates to law enforcement requests for financial intelligence, not asset seizures.

Option D (Incorrect): Section 319(a) concerns record-keeping requirements for foreign banks but does not authorize asset seizures.

Best Practices for Foreign Banks with U.S. Correspondent Accounts:

Ensure full AML compliance to avoid regulatory scrutiny.

Avoid processing high-risk transactions that may trigger U.S. jurisdiction.

Monitor cross-border transactions to detect potential financial crime exposure.

USA PATRIOT Act Section 319(b) (Correspondent Banking Asset Seizures)

FinCEN Guidance on Extraterritorial AML Compliance

FATF Recommendation 13 (Correspondent Banking AML Risks)

Question 5

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

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

AThe employee was constantly evasive about the reasons for leaving their previous corporate finance job.

BThe employee was originally from a high-risk jurisdiction.

CThe employee had friends in high-risk industries.

DThe employee had a lavish lifestyle for their income.

Answer : A, D

Fraud and financial crime are often associated with sudden resignations, attempts to evade scrutiny, and financial behaviors inconsistent with legitimate income.

Option A (Correct): Being evasive about past employment suggests potential undisclosed misconduct.

Option D (Correct): Living beyond one's means is a major financial crime red flag, indicating possible fraud or illicit earnings.

Why Other Options Are Incorrect:

Option B (Incorrect): Nationality alone does not indicate fraud risk.

Option C (Incorrect): Having friends in high-risk industries is not necessarily a direct red flag.

Common Red Flags for Employee-Related Financial Crime:

Reluctance to take vacations or change roles (attempting to conceal wrongdoing).

Sudden resignation or disappearance following internal investigations.

Unusual financial activity, including large unexplained deposits.

Best Practices for Fraud Prevention in Corporations:

Regularly monitor employees in high-risk roles (e.g., finance, procurement).

Use whistleblower channels to detect internal misconduct.

Conduct thorough background checks before hiring employees.

FATF Guidance on Internal Fraud and Money Laundering

Wolfsberg Group Best Practices for Employee Monitoring

Basel Committee Guidelines on Insider Financial Crime Risks

Question 6

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

AThe 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.

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

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

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

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

Answer : C, D, E

Enhanced Due Diligence (EDD) applies to high-risk customers and transactions, including politically exposed persons (PEPs), high-risk jurisdictions, and correspondent banking relationships.

Option C (Correct): Correspondent banking relationships with high-risk jurisdictions require EDD to prevent cross-border financial crime.

Option D (Correct): Ambassadors are considered PEPs, which require EDD due to corruption risks.

Option E (Correct): A current prime minister is a high-profile PEP, requiring EDD and ongoing transaction monitoring.

Why Other Options Are Incorrect:

Option A (Incorrect): The individual no longer holds a PEP position and is in a low-risk country, so EDD is not required.

Option B (Incorrect): A local footballer does not present a high financial crime risk warranting EDD.

EDD Best Practices for High-Risk Customers:

Verify the source of wealth and funds for PEPs.

Conduct ongoing transaction monitoring on high-risk accounts.

Apply stricter controls on correspondent banking with high-risk jurisdictions.

FATF Recommendation 10 & 12 (EDD & PEPs)

Basel Committee's Correspondent Banking Guidelines

Wolfsberg Group Guidance on High-Risk Customers & EDD

Question 7

According to FinCEN, which red flags within a bank account may, taken together, be indications of modern slavery, human trafficking, and exploitation? (Select Two.)

ATransactional activity with a registered virtual currency exchange.

BFrequent payments for online advertisements or non-local classified ads.

CIncoming fund transfers from third-party payment processors, with limited originator information.

DLarge amounts of cash payments to migrant agricultural workers.

Answer : B, C

Human trafficking and modern slavery involve illicit financial transactions, often conducted through banks, money service businesses (MSBs), or virtual assets.

Option B (Correct): Frequent payments for online advertisements can indicate recruitment for illicit labor or trafficking operations.

Option C (Correct): Incoming funds from third-party processors with unclear originators suggest concealed financial flows linked to illicit activities.

Why Other Options Are Incorrect:

Option A (Incorrect): Transactional activity with a virtual currency exchange alone is not a strong human trafficking red flag.

Option D (Incorrect): Cash payments to workers could indicate labor law violations but do not necessarily indicate human trafficking.

Common Financial Red Flags for Human Trafficking:

Unexplained cash deposits and withdrawals from multiple accounts.

Frequent wire transfers to high-risk jurisdictions.

Use of prepaid cards to move funds anonymously.

Best Practices for Detecting & Preventing Human Trafficking-Related Transactions:

Train frontline staff to recognize financial indicators of trafficking.

Monitor unusual transaction patterns in industries with high labor exploitation risks.

File Suspicious Activity Reports (SARs) when trafficking-related transactions are suspected.

FinCEN Human Trafficking Financial Red Flags (2021)

FATF Report on Financial Flows Linked to Human Trafficking

6th EU AML Directive (6AMLD) on Human Trafficking & Financial Crime