ACAMS Exam Review Questions with Verified
Correct Answers
2 ways remittance services can foster ML
• Packages containing large cash sums and even drugs anonymously.
• Another technique commonly used by money remitters and currency exchanges is for the
broker to make the funds available to the criminal organization at the destination country in
the local currency.
2 Ways to launder money in Real Estate
• By way of chain transactions in real estate to cloak the illicit source of funds (the layering
phase),
• By investment in, for example, tourist or holiday complexes that lend an appearance of
legality (the integration phase).
Ch 2.1 - 3 main points of ML definition
• The conversion or transfer of property, knowing it is derived from a criminal offense, for
the purpose of concealing or disguising its illicit origin
• The concealment or disguising of the true nature, of property knowing that it is derived
from a criminal offense
• The acquisition knowing at the time of its receipt that it was derived from a criminal offense
or from participation in a crime.
Ch 2.2 - 3 Stages of ML: All stages of Money Laundering Cycle
• Step One: Placement
• Step Two: Layering
• Step Three: Integration
,4 different operations of remittance services
• Funds transfer companies possessing separate networks (like Western Union and Money
Gram);
• Money transfer systems connected with clandestine banks (underground banking);
• Money transfers by way of the collection accounts of foreign banks
• International money orders.
4 Laundering risks and ways laundering can occur through vehicle sellers include:
• Structuring cash deposits below the reporting threshold, or purchasing vehicles with
structured checks and money orders.
• Trading in vehicles for other ones and conducting successive transactions of buying and
selling new and used vehicles to produce complex transaction layers.
• Arranging complex payment or invoicing for customers, thereby structuring cash payments
to avoid currency reports.
• Accepting third-party payments, particularly from jurisdictions with lax laundering controls.
4 Ways money laundering can occur in travel agencies include:
• Purchasing an expensive airline ticket for another person who then asks for a refund
• Structuring outgoing wire transfers in small amounts to avoid recordkeeping requirements,
especially those from foreign countries and unusually large amounts
• Sending a tour group to a country and making an offsetting payment in a foreign entity's
U.S. or other account while instructing the accountholder to cover
the cost of the group's trip
• Arranging complex payment or invoicing for customers, thereby structuring cash payments
to avoid currency reports.
,5 functions provided by lawyers, notaries, accountants and other professionals are the
most useful to a potential money launderer:
• Creation of corporate vehicles or other complex legal arrangements (trusts, for example).
Such constructions may serve to confuse the links between the proceeds
• of a crime and the perpetrator.
• Buying or selling property.
• Performing financial transactions.
• Financial and tax advice.
• Gaining introductions to financial institutions.
5 Measures that might limit the vulnerability to money laundering of new payment
technologies are:
• Limiting the functions and capacity of smart cards (including maximum value and turnover
limits, as well as number of smart cards per customer);
• Linking new payment technology to financial institutions and bank accounts;
• Requiring standard record keeping procedures for these systems to enable the examination,
• Documentation, and seizure of relevant records by investigating authorities; and
• Establishing international standards for these measures.
6 Aspects of the securities field that increase their exposures to laundering are:
• Its international nature
• Fast-paced transactions, often at the click of a mouse
• The easy conversion of holdings to cash without significant loss of principal
• The routine use of wire transfers from, to or through multiple jurisdictions
• The competitive, commission-driven environment, which, like private banking, provides
ample incentive to disregard the source of client funds
, • The practice of brokerage firms maintaining securities accounts as nominees or trustees,
thus permitting concealment of the identities of the true beneficiaries
Ch 2.5 - ML Risks with New Technology: ML risks for prepaid cards
• Anonymous card holders
• Anonymous funding and anonymous access to funds
• High value limits and no limits on the number of cards individuals can acquire
• Global access to cash through ATMs
• Offshore card issuers may not observe laws in all jurisdictions
• Substitute for bulk-cash smuggling
6 ways commodities/trading is susceptible to money laundering.
• Withdrawal of assets through transfers to unrelated accounts or to high-risk countries
• Frequent additions or withdrawals from accounts
• Checks drawn on, or wire transfers from, accounts of third parties with no relation to the
client
• Clients who require custodial arrangements that allow them to remain anonymous
• Transfers of funds to the adviser for management followed by transfers to accounts at other
institutions in a layering scheme.
• Investing illegal proceeds for a client
• Movement of funds to disguise their originator.
7 laundering techniques used in conjunction with criminal controlled companies:
• Using Nominees as Owners or Directors
• Layering
• Loans
• Fictitious business expenses/False invoicing
Correct Answers
2 ways remittance services can foster ML
• Packages containing large cash sums and even drugs anonymously.
• Another technique commonly used by money remitters and currency exchanges is for the
broker to make the funds available to the criminal organization at the destination country in
the local currency.
2 Ways to launder money in Real Estate
• By way of chain transactions in real estate to cloak the illicit source of funds (the layering
phase),
• By investment in, for example, tourist or holiday complexes that lend an appearance of
legality (the integration phase).
Ch 2.1 - 3 main points of ML definition
• The conversion or transfer of property, knowing it is derived from a criminal offense, for
the purpose of concealing or disguising its illicit origin
• The concealment or disguising of the true nature, of property knowing that it is derived
from a criminal offense
• The acquisition knowing at the time of its receipt that it was derived from a criminal offense
or from participation in a crime.
Ch 2.2 - 3 Stages of ML: All stages of Money Laundering Cycle
• Step One: Placement
• Step Two: Layering
• Step Three: Integration
,4 different operations of remittance services
• Funds transfer companies possessing separate networks (like Western Union and Money
Gram);
• Money transfer systems connected with clandestine banks (underground banking);
• Money transfers by way of the collection accounts of foreign banks
• International money orders.
4 Laundering risks and ways laundering can occur through vehicle sellers include:
• Structuring cash deposits below the reporting threshold, or purchasing vehicles with
structured checks and money orders.
• Trading in vehicles for other ones and conducting successive transactions of buying and
selling new and used vehicles to produce complex transaction layers.
• Arranging complex payment or invoicing for customers, thereby structuring cash payments
to avoid currency reports.
• Accepting third-party payments, particularly from jurisdictions with lax laundering controls.
4 Ways money laundering can occur in travel agencies include:
• Purchasing an expensive airline ticket for another person who then asks for a refund
• Structuring outgoing wire transfers in small amounts to avoid recordkeeping requirements,
especially those from foreign countries and unusually large amounts
• Sending a tour group to a country and making an offsetting payment in a foreign entity's
U.S. or other account while instructing the accountholder to cover
the cost of the group's trip
• Arranging complex payment or invoicing for customers, thereby structuring cash payments
to avoid currency reports.
,5 functions provided by lawyers, notaries, accountants and other professionals are the
most useful to a potential money launderer:
• Creation of corporate vehicles or other complex legal arrangements (trusts, for example).
Such constructions may serve to confuse the links between the proceeds
• of a crime and the perpetrator.
• Buying or selling property.
• Performing financial transactions.
• Financial and tax advice.
• Gaining introductions to financial institutions.
5 Measures that might limit the vulnerability to money laundering of new payment
technologies are:
• Limiting the functions and capacity of smart cards (including maximum value and turnover
limits, as well as number of smart cards per customer);
• Linking new payment technology to financial institutions and bank accounts;
• Requiring standard record keeping procedures for these systems to enable the examination,
• Documentation, and seizure of relevant records by investigating authorities; and
• Establishing international standards for these measures.
6 Aspects of the securities field that increase their exposures to laundering are:
• Its international nature
• Fast-paced transactions, often at the click of a mouse
• The easy conversion of holdings to cash without significant loss of principal
• The routine use of wire transfers from, to or through multiple jurisdictions
• The competitive, commission-driven environment, which, like private banking, provides
ample incentive to disregard the source of client funds
, • The practice of brokerage firms maintaining securities accounts as nominees or trustees,
thus permitting concealment of the identities of the true beneficiaries
Ch 2.5 - ML Risks with New Technology: ML risks for prepaid cards
• Anonymous card holders
• Anonymous funding and anonymous access to funds
• High value limits and no limits on the number of cards individuals can acquire
• Global access to cash through ATMs
• Offshore card issuers may not observe laws in all jurisdictions
• Substitute for bulk-cash smuggling
6 ways commodities/trading is susceptible to money laundering.
• Withdrawal of assets through transfers to unrelated accounts or to high-risk countries
• Frequent additions or withdrawals from accounts
• Checks drawn on, or wire transfers from, accounts of third parties with no relation to the
client
• Clients who require custodial arrangements that allow them to remain anonymous
• Transfers of funds to the adviser for management followed by transfers to accounts at other
institutions in a layering scheme.
• Investing illegal proceeds for a client
• Movement of funds to disguise their originator.
7 laundering techniques used in conjunction with criminal controlled companies:
• Using Nominees as Owners or Directors
• Layering
• Loans
• Fictitious business expenses/False invoicing
