ACAMS STUDY GUIDE 2026 WITH ALL CORRECT & 100%
VERIFIED ANSWERS|ACTUAL COMPLETE EXAM|
ALREADY GRADED A+
What is money laundering? ✔Correct Answer-- Taking criminal proceeds, disguising illegal sources
to use the funds to perform legal or illegal activities.
- Process of making dirty money look clean
Give an example of the second stage of money laundering: ✔Correct Answer-- Electronically
moving funds from one country to another and dividing them into advanced financial options
- Moving funds from one financial institution to another or within multiple accounts at the same
institution
- Converting cash into monetary instruments
- Using shell companies to obscure beneficial owner and assets
Give an example of the third stage of money laundering: ✔Correct Answer-Purchasing luxury
assets like property, jewelry, high end automobiles, investments.
Give an example of the first stage of money laundering: ✔Correct Answer-- Blending funds,
purchasing stored value cards with currency, foreign exchange, currency smuggling, loans
What does the Yates Memo say? ✔Correct Answer-- Criminal and civil investigations into corporate
misconduct should also focus on the individuals who perpetrated the wrongdoing.
What are some indicators of money laundering using ETF? ✔Correct Answer-- Funds transfers to or
from a financial secrecy haven or high risk geographic location without apparent business reason, or
when activity is inconsistent with customer
- Lafarge funds transfers from foreign clients without reason
- Checks and money orders to receive many small incoming transfers of funds or to make deposits
- Unexplained funds activity
- Payments or receipts without link to legitimate contracts
- Funds transfers from the same person to or from different accounts
What is remote deposit capture and what risk is associated with it? ✔Correct Answer-- Bank
product that allows customers to check and transmit an electronic image of a check to the bank for
deposit.
- Decreases ability to identify fraud indicators
What are some of the money laundering risks pertaining to the use of payable through accounts
(PTAs)? ✔Correct Answer-- Foreign institutions licensed in offshore centers with weak supervision
and licensing laws
- Correspondent bank fails to apply CDD
- Subaccount holders have currency deposit and withdrawal privileges
- Used in conjunction with a subsidiary, representative, or other office of the respondent bank
What is a money laundering risk pertaining to the use of concentration accounts? ✔Correct
Answer-- Customer-identifying information is separated from the financial transaction.
- Results in a lost audit trail.
,Define a politically exposed person ✔Correct Answer-- Person who is or has been entrusted with a
prominent public function domestically or by a foreign country or organization.
What is structuring? ✔Correct Answer-- Designing a transaction to evade triggering a reporting or
record keeping requirement
- Breaking a cash deposit into smaller ones
Which money laundering stages are credit cards most likely to be used, and what is an example of
money laundering through the use of credit cards? ✔Correct Answer-- Most likely used in second
(layering) and third (integration) stages.
- Overpaying a credit card balance and asking for a refund.
What are some risks posed by third party payment processors: ✔Correct Answer-- Multiple
financial organization relationships that a TPPP cannot see inits entirety
High return rates from unauthorized transactions
What are some ways money services businesses (MSBs) can be used for money laundering?
✔Correct Answer-- Make funds available to criminal organizations at a destination country in the
local currency. Launderer or broker then sells the criminal dollars to foreign businesspeople wishing
to make legitimate purchases of goods for exports.
Cash intensive and transactional nature of MSBs facilitate ML
What are some of the aspects associated with the securities industry that increase its exposure to
money laundering? ✔Correct Answer-- International nature, speed of transactions, conduct free-
of-payment transfers, converting holdings to cash without loss of principal, wire transfers to from or
through multiple jurisdictions, competitive commission driven environment
What are some red flags of money laundering associated with casinos and gambling? ✔Correct
Answer-- Converting funds to be laundered from cash to checks and using casino credit to layer
transactions before transferring out funds
- Buying chips with illicit funds and requesting repayment via check drawn on casino account
- Using illegal funds to repay casino lines of credit
- Junket operators moving funds across borders and through multiple casines
- Unusual gaming patterns
Why is gold vulnerable to money laundering and terrorist financing risks? ✔Correct Answer-High
intrinsic value in compact, easy to transport form. Holds value regardless of form.
List ways in which travel agencies can be used to launder money: ✔Correct Answer-- Purchasing
expensive airline ticket for another person who asks for a refund, structuring wire transfers in small
amounts to avoid recordkeeping requirements, establishing tour operator networks with false
bookings to justify significant payments from foreign travel groups.
List various functions of gatekeepers - attorneys, notaries, accountants, and auditors - that can be
useful to money launderers: ✔Correct Answer-- Creating corporate vehicles and complex legal
arrangements
- Buying or selling property as a cover for illegal fund transfers
- Performing financial transactions and providing advice
- Setting up and managing charities
, Why is the issue of requiring attorneys to be gatekeepers in the AML/CFT area controversial?
✔Correct Answer-- Attorneys have confidential relationships with their clients
What makes real estate an attractive channel for laundering illicit funds? ✔Correct Answer-- It can
be purchased with cash
- Ultimate beneficial owner can be disguised
- Stable and reliable investment
- Value able to be increased.
What are some common money laundering techniques involved with trade=based money
laundering? ✔Correct Answer-- Over Invoicing and under invoicing, overshipping and short
shipping, ghost shipping, shell companies, multiple invoicing and black market trades.
What is the Black Market Peso Exchange? ✔Correct Answer-- Money in the US derived from illegal
activity is purchased by peso brokers and deposited in US bank accounts established by the brokers.
- The brokers sell checks and wire transfers drawn on those accounts to legitimate businesses which
use them to purchase goods and services in the US.
What are the potential risk factors commonly associated with prepaid bank cards? ✔Correct
Answer-- Anonymous cardholders, funding, access to funds
- High value limits and no limits on the number of cards individuals can acquire
- Global access to cash through ATMs
What are some specific controls that e-money institutions can implement to mitigate the money
laundering risk of prepaid cards, mobile payments, and internet-based payment services?
✔Correct Answer-- Robust oversight of outsourced functions
- Limits on storage value transactions
- Identifying customers with multiple purses, accounts, and cards
- Geolocation services
- Geographic restrictions on the use and function of e money products
Explain the roles of the following participants in the VC ecosystem: user, exchanger, administrator.
✔Correct Answer-- User: obtains VC to make purchases
- Exchanger: business in exchange of VC for another form of currency
- Administrator: business in issuing VC and authority to redeem the VC
What are some emerging risks for terrorist financing? ✔Correct Answer-- Self-funding by foreign
terrorist fighters
- Raising funds through social media
- New payment products and services
- Exploitation of natural resources
Explain the legal concept of willful blindness in the context of money laundering: ✔Correct
Answer-- Deliberate avoidance of knowledge of the facts... equivalent of actual knowledge of the
illegal source of funds.
In what ways is correspondent banking vulnerable to financial crime? ✔Correct Answer-- Do not
know the customers of the respondent directly and rely on the respondent banks internal controls.
- Some respondents are correspondents to third banks.
VERIFIED ANSWERS|ACTUAL COMPLETE EXAM|
ALREADY GRADED A+
What is money laundering? ✔Correct Answer-- Taking criminal proceeds, disguising illegal sources
to use the funds to perform legal or illegal activities.
- Process of making dirty money look clean
Give an example of the second stage of money laundering: ✔Correct Answer-- Electronically
moving funds from one country to another and dividing them into advanced financial options
- Moving funds from one financial institution to another or within multiple accounts at the same
institution
- Converting cash into monetary instruments
- Using shell companies to obscure beneficial owner and assets
Give an example of the third stage of money laundering: ✔Correct Answer-Purchasing luxury
assets like property, jewelry, high end automobiles, investments.
Give an example of the first stage of money laundering: ✔Correct Answer-- Blending funds,
purchasing stored value cards with currency, foreign exchange, currency smuggling, loans
What does the Yates Memo say? ✔Correct Answer-- Criminal and civil investigations into corporate
misconduct should also focus on the individuals who perpetrated the wrongdoing.
What are some indicators of money laundering using ETF? ✔Correct Answer-- Funds transfers to or
from a financial secrecy haven or high risk geographic location without apparent business reason, or
when activity is inconsistent with customer
- Lafarge funds transfers from foreign clients without reason
- Checks and money orders to receive many small incoming transfers of funds or to make deposits
- Unexplained funds activity
- Payments or receipts without link to legitimate contracts
- Funds transfers from the same person to or from different accounts
What is remote deposit capture and what risk is associated with it? ✔Correct Answer-- Bank
product that allows customers to check and transmit an electronic image of a check to the bank for
deposit.
- Decreases ability to identify fraud indicators
What are some of the money laundering risks pertaining to the use of payable through accounts
(PTAs)? ✔Correct Answer-- Foreign institutions licensed in offshore centers with weak supervision
and licensing laws
- Correspondent bank fails to apply CDD
- Subaccount holders have currency deposit and withdrawal privileges
- Used in conjunction with a subsidiary, representative, or other office of the respondent bank
What is a money laundering risk pertaining to the use of concentration accounts? ✔Correct
Answer-- Customer-identifying information is separated from the financial transaction.
- Results in a lost audit trail.
,Define a politically exposed person ✔Correct Answer-- Person who is or has been entrusted with a
prominent public function domestically or by a foreign country or organization.
What is structuring? ✔Correct Answer-- Designing a transaction to evade triggering a reporting or
record keeping requirement
- Breaking a cash deposit into smaller ones
Which money laundering stages are credit cards most likely to be used, and what is an example of
money laundering through the use of credit cards? ✔Correct Answer-- Most likely used in second
(layering) and third (integration) stages.
- Overpaying a credit card balance and asking for a refund.
What are some risks posed by third party payment processors: ✔Correct Answer-- Multiple
financial organization relationships that a TPPP cannot see inits entirety
High return rates from unauthorized transactions
What are some ways money services businesses (MSBs) can be used for money laundering?
✔Correct Answer-- Make funds available to criminal organizations at a destination country in the
local currency. Launderer or broker then sells the criminal dollars to foreign businesspeople wishing
to make legitimate purchases of goods for exports.
Cash intensive and transactional nature of MSBs facilitate ML
What are some of the aspects associated with the securities industry that increase its exposure to
money laundering? ✔Correct Answer-- International nature, speed of transactions, conduct free-
of-payment transfers, converting holdings to cash without loss of principal, wire transfers to from or
through multiple jurisdictions, competitive commission driven environment
What are some red flags of money laundering associated with casinos and gambling? ✔Correct
Answer-- Converting funds to be laundered from cash to checks and using casino credit to layer
transactions before transferring out funds
- Buying chips with illicit funds and requesting repayment via check drawn on casino account
- Using illegal funds to repay casino lines of credit
- Junket operators moving funds across borders and through multiple casines
- Unusual gaming patterns
Why is gold vulnerable to money laundering and terrorist financing risks? ✔Correct Answer-High
intrinsic value in compact, easy to transport form. Holds value regardless of form.
List ways in which travel agencies can be used to launder money: ✔Correct Answer-- Purchasing
expensive airline ticket for another person who asks for a refund, structuring wire transfers in small
amounts to avoid recordkeeping requirements, establishing tour operator networks with false
bookings to justify significant payments from foreign travel groups.
List various functions of gatekeepers - attorneys, notaries, accountants, and auditors - that can be
useful to money launderers: ✔Correct Answer-- Creating corporate vehicles and complex legal
arrangements
- Buying or selling property as a cover for illegal fund transfers
- Performing financial transactions and providing advice
- Setting up and managing charities
, Why is the issue of requiring attorneys to be gatekeepers in the AML/CFT area controversial?
✔Correct Answer-- Attorneys have confidential relationships with their clients
What makes real estate an attractive channel for laundering illicit funds? ✔Correct Answer-- It can
be purchased with cash
- Ultimate beneficial owner can be disguised
- Stable and reliable investment
- Value able to be increased.
What are some common money laundering techniques involved with trade=based money
laundering? ✔Correct Answer-- Over Invoicing and under invoicing, overshipping and short
shipping, ghost shipping, shell companies, multiple invoicing and black market trades.
What is the Black Market Peso Exchange? ✔Correct Answer-- Money in the US derived from illegal
activity is purchased by peso brokers and deposited in US bank accounts established by the brokers.
- The brokers sell checks and wire transfers drawn on those accounts to legitimate businesses which
use them to purchase goods and services in the US.
What are the potential risk factors commonly associated with prepaid bank cards? ✔Correct
Answer-- Anonymous cardholders, funding, access to funds
- High value limits and no limits on the number of cards individuals can acquire
- Global access to cash through ATMs
What are some specific controls that e-money institutions can implement to mitigate the money
laundering risk of prepaid cards, mobile payments, and internet-based payment services?
✔Correct Answer-- Robust oversight of outsourced functions
- Limits on storage value transactions
- Identifying customers with multiple purses, accounts, and cards
- Geolocation services
- Geographic restrictions on the use and function of e money products
Explain the roles of the following participants in the VC ecosystem: user, exchanger, administrator.
✔Correct Answer-- User: obtains VC to make purchases
- Exchanger: business in exchange of VC for another form of currency
- Administrator: business in issuing VC and authority to redeem the VC
What are some emerging risks for terrorist financing? ✔Correct Answer-- Self-funding by foreign
terrorist fighters
- Raising funds through social media
- New payment products and services
- Exploitation of natural resources
Explain the legal concept of willful blindness in the context of money laundering: ✔Correct
Answer-- Deliberate avoidance of knowledge of the facts... equivalent of actual knowledge of the
illegal source of funds.
In what ways is correspondent banking vulnerable to financial crime? ✔Correct Answer-- Do not
know the customers of the respondent directly and rely on the respondent banks internal controls.
- Some respondents are correspondents to third banks.
