ACAMS Example Questions with
Correct Answers
Tom works as a compliance officer at ABC bank. He is looking at the transactions of
one of the bank's customers, Mr. Brown. Mr. Brown is the owner of a check cashing
company which performs only check cashing services. Over the last six months, Mr.
Brown has not made withdrawals of cash against check deposits. He also deposited two
checks for US$2,000 each that were issued by a casino. When checking the KYC file,
Tom sees that, when opening the account, Mr. Brown had requested detailed
information about fees and commissions that are charged by the bank. What would
arouse your suspicion the most? That Mr. Brown:
A- Deposited checks from casinos
B- Did not make withdrawals of cash against check deposits
C- Showed uncommon curiosity about commissions and fees charged
D- Does not have an escrow account - ✔✔B
Which of the following statements is true?
Katelyn Whitman, All Rights Reserved © 2025 1
,A- Credit cards are not likely to be used in the layering phase of money laundering
because of restrictions in cash payments.
B- Credit cards are effective instruments for laundering money because the transactions
do not create a paper trail.
C- A launderer can launder money by prepaying his credit card using funds that are
already in the banking system, creating a credit balance on his account, and requesting
a credit refund.
D- A launderer can use illicit funds that are already in the banking system to pay his
credit card bill for goods purchased, which is an example of placement. - ✔✔C
Why is a Payable Through Account vulnerable to money laundering?
A. These are master correspondent accounts established at a domestic bank by a foreign
bank that allow the customers of the foreign bank to do a wide range of transactions.
B. These are correspondent accounts located in a non-cooperative country or territory.
C. These are nested correspondent accounts at a foreign shell bank with customers with
whom the domestic bank did not exercise due diligence.
D. These are master escrow accounts on which a domestic bank generally does not
conduct periodic verification. - ✔✔A
Which of the following statements is true? Correspondent banking is MOST
Katelyn Whitman, All Rights Reserved © 2025 2
,vulnerable to money laundering when the correspondent account is:
A. Maintained for foreign financial institutions that are banks.
B. Not used to provide services directly to third parties.
C. Maintained for a foreign bank that does not have a physical presence in any country.
D. Maintained for a foreign private bank that is publicly traded and is a qualified
intermediary. - ✔✔C
Which statement is true?
A. Lawyers/attorneys can generally not be used to serve as formation agents to set up
trusts, front companies or shell corporations.
B. Lawyers, accountants, notaries and other similar professionals are called money
services providers.
C. Lawyers can generally not be used to act as a nominee shareholder for another
person.
D. Launderers can abuse gatekeepers by using their accounts for the placement and the
layering of funds. - ✔✔D
Which two of the following activities are typically associated with the Black Market
Peso Exchange (BMPE) money laundering system?
Katelyn Whitman, All Rights Reserved © 2025 3
, A. Converting illicit drug proceeds from dollars or Euros to Colombian pesos
B. Converting illicit drug proceeds from Colombian pesos to dollars or Euros
C. Facilitating purchases by Colombian importers of goods manufactured in the United
States or Europe through peso brokers
D. Facilitating purchases by European or U.S. importers of goods manufactured in
Colombia through peso brokers - ✔✔A,C
Which statement is true?
A. Bust-out schemes are popular in creating large bankruptcy frauds where businesses
secure increasing loans in excess of the actual value of the company or property and
then run with the money, leaving the lender to foreclose and take a substantial loss.
B. Cuckoo smurfing is a significant money laundering technique identified by the
Financial Action Task Force, where a form of structuring uses nested
accounts with shell banks in secrecy havens.
C. In its revised 40 Recommendations of 2003, the FATF issued for the second time a list
of "designated categories of offense" that asserts crimes for a
money laundering prosecution.
Katelyn Whitman, All Rights Reserved © 2025 4
Correct Answers
Tom works as a compliance officer at ABC bank. He is looking at the transactions of
one of the bank's customers, Mr. Brown. Mr. Brown is the owner of a check cashing
company which performs only check cashing services. Over the last six months, Mr.
Brown has not made withdrawals of cash against check deposits. He also deposited two
checks for US$2,000 each that were issued by a casino. When checking the KYC file,
Tom sees that, when opening the account, Mr. Brown had requested detailed
information about fees and commissions that are charged by the bank. What would
arouse your suspicion the most? That Mr. Brown:
A- Deposited checks from casinos
B- Did not make withdrawals of cash against check deposits
C- Showed uncommon curiosity about commissions and fees charged
D- Does not have an escrow account - ✔✔B
Which of the following statements is true?
Katelyn Whitman, All Rights Reserved © 2025 1
,A- Credit cards are not likely to be used in the layering phase of money laundering
because of restrictions in cash payments.
B- Credit cards are effective instruments for laundering money because the transactions
do not create a paper trail.
C- A launderer can launder money by prepaying his credit card using funds that are
already in the banking system, creating a credit balance on his account, and requesting
a credit refund.
D- A launderer can use illicit funds that are already in the banking system to pay his
credit card bill for goods purchased, which is an example of placement. - ✔✔C
Why is a Payable Through Account vulnerable to money laundering?
A. These are master correspondent accounts established at a domestic bank by a foreign
bank that allow the customers of the foreign bank to do a wide range of transactions.
B. These are correspondent accounts located in a non-cooperative country or territory.
C. These are nested correspondent accounts at a foreign shell bank with customers with
whom the domestic bank did not exercise due diligence.
D. These are master escrow accounts on which a domestic bank generally does not
conduct periodic verification. - ✔✔A
Which of the following statements is true? Correspondent banking is MOST
Katelyn Whitman, All Rights Reserved © 2025 2
,vulnerable to money laundering when the correspondent account is:
A. Maintained for foreign financial institutions that are banks.
B. Not used to provide services directly to third parties.
C. Maintained for a foreign bank that does not have a physical presence in any country.
D. Maintained for a foreign private bank that is publicly traded and is a qualified
intermediary. - ✔✔C
Which statement is true?
A. Lawyers/attorneys can generally not be used to serve as formation agents to set up
trusts, front companies or shell corporations.
B. Lawyers, accountants, notaries and other similar professionals are called money
services providers.
C. Lawyers can generally not be used to act as a nominee shareholder for another
person.
D. Launderers can abuse gatekeepers by using their accounts for the placement and the
layering of funds. - ✔✔D
Which two of the following activities are typically associated with the Black Market
Peso Exchange (BMPE) money laundering system?
Katelyn Whitman, All Rights Reserved © 2025 3
, A. Converting illicit drug proceeds from dollars or Euros to Colombian pesos
B. Converting illicit drug proceeds from Colombian pesos to dollars or Euros
C. Facilitating purchases by Colombian importers of goods manufactured in the United
States or Europe through peso brokers
D. Facilitating purchases by European or U.S. importers of goods manufactured in
Colombia through peso brokers - ✔✔A,C
Which statement is true?
A. Bust-out schemes are popular in creating large bankruptcy frauds where businesses
secure increasing loans in excess of the actual value of the company or property and
then run with the money, leaving the lender to foreclose and take a substantial loss.
B. Cuckoo smurfing is a significant money laundering technique identified by the
Financial Action Task Force, where a form of structuring uses nested
accounts with shell banks in secrecy havens.
C. In its revised 40 Recommendations of 2003, the FATF issued for the second time a list
of "designated categories of offense" that asserts crimes for a
money laundering prosecution.
Katelyn Whitman, All Rights Reserved © 2025 4
