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

An AML compliance officer is drafting plans to address deficiencies identified in an independent audit.

Which approach is the best option?

ADraft action plans in consultation with the jurisdiction's FIU to remain aligned with other similar companies.

BOnly commit to action plans that can be implemented and closed within the three-month management reporting cycle.

CDraft action plans that will take many months to fully implement to address the root cause of the deficiencies.

DOnly commit to action plans that require no new investment to maximize shareholder value.

Answer : C

A long-term, root cause-based approach ensures AML deficiencies are fully remediated.

Option C (Correct): Addressing root causes ensures the institution remains compliant and prevents recurring violations.

Option A (Incorrect): Consulting with an FIU is unnecessary for internal remediation plans.

Option B (Incorrect): Short-term fixes do not resolve systemic AML issues.

Option D (Incorrect): AML compliance improvements may require investment---cost-cutting should not compromise compliance.

Best Practices for AML Audit Remediation:

Conduct root cause analysis before implementing corrective measures.

Develop a long-term compliance improvement plan.

Allocate sufficient resources for sustainable AML enhancements.

FATF Recommendation 18 (AML Compliance & Internal Controls)

Wolfsberg Group Guidance on AML Audit Remediation

Basel Committee's AML Risk Management Guidelines

Question 7

A U.S. bank recently received a regulatory order to remediate its AML programs, which included several violations of law.

What degree of accountability is it possible for the bank's senior management and employees to face?

AThe bank's designated AML compliance officer and senior management may face personal liability if they failed to take actions while aware of AML violations at the bank.

BThe bank's designated AML compliance officer is likely to face criminal prosecution because the bank received a regulatory order.

CThe bank's designated AML compliance officer is the only individual in the company's senior management team that can face personal liability for violation of AML laws.

DThe bank's designated AML compliance officer and senior management can face civil prosecution but not criminal prosecution for violation of AML laws.

Answer : A

Senior management and AML officers may face personal liability if they knowingly allow AML violations to persist.

Option A (Correct): If senior management or the AML officer was aware of violations and failed to act, they could face regulatory or criminal liability.

Option B (Incorrect): Criminal liability depends on intent and negligence---an AML officer is not automatically prosecuted because a bank receives a regulatory order.

Option C (Incorrect): Liability extends beyond the AML officer---other senior executives can also be held accountable.

Option D (Incorrect): Violations can result in both civil and criminal prosecution, depending on the severity.

Legal Risks for AML Compliance Failures:

Civil penalties (fines and sanctions) for AML program deficiencies.

Criminal charges if executives knowingly ignore violations.

Regulatory enforcement actions leading to license revocation.

USA PATRIOT Act Section 352 (AML Compliance Program Requirements)

FinCEN Guidelines on AML Compliance Officer Liability

FATF Recommendation 35 (Sanctions for AML Non-Compliance)