CAMS-FCI Practice Questions

"The FATF measures the effectiveness of a country's efforts to combat money laundering and

terrorist financing through a mutual evaluation process. During a mutual evaluation, the FATF

assesses a country's legal and institutional framework, its implementation of measures to combat

money laundering and terrorist financing, and the effectiveness of its efforts. The FATF then issues a

report with recommendations for improvement" [CAMS Study Guide 6th edition, page 15-16].

An investigator should avoid escalating a suspicious event to the chief compliance officer if there is a

potential conflict of interest, such as when a close family member of the officer is involved in the

transaction. In such a case, the investigator should pursue other channels, such as reporting to a

higher authority or an independent committee. The other options do not present a conflict of

interest and should be escalated to the chief compliance officer as part of the normal procedure.

Reference: Advanced CAMS-FCI Certification Handbook, page 18.

The analyst should clarify discrepancies noted in the customer’s declared profile given the

downstream impact on the risk assessment. This is because discrepancies between the customer’s

nature of business and the information on the business registry may indicate that the customer is not

operating a legitimate business or is trying to conceal its true activities. The analyst should verify the

customer’s identity, source of funds, and purpose of transactions to ensure that the customer’s risk

profile is accurate and consistent with the Fl’s risk appetite.

Reference: Leading Complex Investigations Certificate, Module 2, page 9.

According to the CAMS manual 6th edition, the USA PATRIOT Act allows the US government to

subpoena documents from foreign financial institutions (FIs) that have no presence in the US (option

B). The manual states that "The USA PATRIOT Act provides US law enforcement agencies with the

power to subpoena documents from foreign banks that maintain correspondent accounts with US

banks or have no presence in the United States" (p. 77).

According to the Certified Anti-Money Laundering Specialist (the 6th edition), the financial institution

(Fl) should take the following actions:

A . Review the client's activity, determine if suspicious activity exists, and report accordingly. The Fl

should assess the risk of the situation and determine if there is any suspicious activity that needs to

be reported to the appropriate authorities. This would involve conducting a review of the client's

account activity and transactions to determine if there are any indicators of money laundering or

terrorist financing.

D . Inform local LEA and regulator of the request for awareness. The Fl should inform the local law

enforcement agency and regulator of the request from the foreign jurisdiction to raise awareness of

the situation and determine if any further actions need to be taken.

The SAR/STR narrative should include the suspicious accounts and transactions identified, as well as

the reasons why they are considered suspicious. The narrative should provide a clear and concise

description of the activity, the parties involved, the dates, amounts, and frequencies of the

transactions, and any other relevant information that would assist law enforcement in understanding

the nature and purpose of the activity. The narrative should not include the investigator’s subjective

opinion, personal tax records, or supporting documentation that is not essential to explain the

suspicious activity. Supporting documentation can be attached separately to the SAR/STR form or

provided upon request by law enforcement.

The total suspicious transaction amount that the investigator should report is 659,000,000 USD. This

is the sum of the two transactions involving the LLC and the state-run oil company, which are

59,000,000 USD and 600,000,000 USD respectively. The other transactions that the LLC made to

other accounts, a money brokerage firm, and real estate purchases are not relevant to the question,

as they are not part of the series of transactions that triggered the alert.

Reference: Advanced CAMS-FCI Certification | ACAMS

The condition that should be met to satisfy the regulator is that the program is drafted using a risk-

based approach to avoid the FI being used as a conduit for criminal activities. A risk-based approach

means that the FI identifies, assesses, and understands its exposure to financial crime risks and

applies appropriate measures to mitigate them. This is consistent with the international standards

and best practices for anti-financial crime compliance. The program being aligned with the financial

industry’s anti-financial crime priorities, meeting the minimum requirements of anti-financial crime

standards published by a financial industry association, or having no high-severity issues in internal

auditing results are not sufficient to satisfy the regulator, as they do not necessarily reflect the

specific risks faced by the FI or demonstrate its effectiveness in preventing and detecting financial

crimes.

Reference: [Advanced CAMS-FCI Study Guide], page 14-15; [FATF Guidance on Risk-Based Approach

for Effective Supervision], page 7-8.

This is stated in the Certified Anti-Money Laundering Specialist (the 6th edition) manual on page 595,

which states: “Potential indicators of money laundering associated with Trust and Company Service

Providers include the use of legal persons in jurisdictions with strict secrecy laws, structuring cash

deposits into third party accounts, multi-jurisdictional wire transfers with no legal purpose, and

frequent deposits to or withdrawals from bank accounts.”

The correct answers are B and C because these are the most relevant and reasonable steps for the

investigations team to perform enhanced due diligence on the operations of the foreign bank and its

customers. Asking for the risk rating, customer profiles, and official licenses would help the team

assess the level of risk and compliance of the foreign bank and its customers, who are engaged in a

high-risk activity of exporting scrap gold and silver. The other options are not appropriate because

they are either premature or ineffective. Rescinding the contract, filing a SAR/STR, or closing the

accounts would require more evidence and justification, and they may also damage the relationship

with the foreign bank.

Reference: : Precious Metals & Stones