ACAMS Practice
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1. C: The USA PATRIOT Act was passed in:
A) 1970
B) 1985
C) 2001
D) 2007
2. D: The three stages of money laundering are:
A) Layering, Placement, Refining
B) Placement, Refining, Integration
C) Refining. Integration, Layering
D) Integration, Layering, Placement
3. D: Which of the following would be satisfactory elements of an Anti-Money Laundering Program?
I - A CAMS certified employee in the Investigations Unit writes up a few policies and procedures and posts them on the
department bulletin board.
II - Shortly after attaining their CAMS certification, the individual provides AML training to the Investigations Unit.
III - The CAMS certified individual routinely reviews the work of the Investigations Unit.
IV - The CAMS certified individual assumes the responsibility of a compliance watchdog.
A) All of the above would be satisfactory
B) II and IV would be satisfactory
C) I and III would be satisfactory
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D) None of the above would be satisfactory
The correct answer would be "D - None of the above would be satisfactory."
I - The AML program must be approved by the Board of Directors.
II - An AML training program is required of all personnel (and contractors).
III - The review of the bank's Financial Intelligence Department, as part of the audit of the AML program, must be
performed by an independent (and knowledgeable) party.
IV - The Compliance Officer must be appointed by the Board of Directors (or upper management with the Board's
approval).
4. D: In determining what risks a customer poses, which consideration should NOT be a major factor?
A) Where the customer resides or where the business is headquartered.
B) What is the size of your financial institution.
C) What occupation or type of business does the customer derive their income from.
D) What are the customer's ethnic heritage, sexual orientation and political beliefs.
The correct answer would be "D." The customer's ethnic heritage, sexual orientation and political beliefs are more
discriminatory factors, and while they may help frame the context of certain transactions, they should not be a major
factor in assessing risk.
The size of your financial institution is a critical element in determining the level of sensitivity to risks for certain
customers.
Analysis questions require one to synthesize information, arrive at solutions and/or evaluate the usefulness of solutions.
, ACAMS Practice
Study online at https://quizlet.com/_hq9l9o
One needs to distinguish between facts and assumptions and to put various knowledge parts together to form a new
knowledge component or solution to a problem. While this is also an important part of being a professional, it comprises
only about 23% of the exam.
5. B: In general, the three phases of money laundering are said to be: Placement:
A. Structuring and manipulation. B. Layering and integration. C. Layering and smur ng. D. Integration and in ltration.
6. A: Which of the following is the most common method of laundering money through a legal money services
business?
A. Purchasing structured money instruments. B. Smuggling bulk-cash. C. Transferring funds through Payable Through
Accounts (PTAs). D. Exchanging Colombian pesos on the black market.
7. A: 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 smur ng is a signi cant money laundering technique identi ed by the Financial
Action Task Force, where a form of structuring uses nested accounts with shell banks in secrecy havens. C. In its
40 Recommendations, the FATF issued a list of "designated categories of offense" that asserts crimes for a money
laundering prosecution. D. E-cash is not attractive to the money launderer because it cannot be completely anonymous
and does not allow for large amounts to be "transported" quickly and easily.
8. BCD: Which three of the following is an indication of possible money laundering in an insurance industry
scenario? A. Insurance products sold through intermediaries, agents or brokers. B. Single-premium insurance bonds,
redeemed at a discount. C. Policyholders who are unconcerned about penalties for early cancellation. D. Policyholders
who make full use of the "free look" period.
9. AC: Which two activities are typically associated with the black market peso exchange (BMPE) money laundering
system? 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.
10. D: What is the Right of Reciprocity in the eld of international cooperation against money laundering? A. The legal
principle that nancial institutions that have referred customers to other nancial institutions can share information
about these customers with the other institutions. B. A rule of the Basel Committee allowing properly regulated nancia
institutes of another member state of the Basel Committee to do business without additional supervision to the degree
that the other state grants the same right. C. The right of each FATF member country to delegate prosecution of a case
of money laundering to another member that is already investigating the same case. D. A rule in the law of a country
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allowing its authorities to cooperate with authorities of other countries to the degree that their law allows them to do
the same.
11. C: The greatest risk for money laundering is for casinos that A. Provide their customers with a wide array of
gambling services. B. Operate in a non-Egmont member country. C. Allow customers with credit balances to withdraw
funds by check in another jurisdiction. D. Only send suspicious transaction reports to the nancial intelligence unit of
the country it operates in.
12. B: Which statement is true regarding the risk of Politically Exposed Persons (PEPs)? A. PEPs provide access to third
parties on whom the nancial institution has not conducted suf cient due diligence. B. PEPs have signi cantly greater
exposure to the politically corrupt funds, including accepting bribes or misappropriating government funds. C. PEPs
are foreign customers who inherently present additional risk as they are engaged in cross-border transactions. D. PEPs
generally do not pose enhanced risks to an institution due to their political standing; rather, PEPs increase the prestige
of an institution.
13. B: Dirty money, derived from criminal activities of Belgian Criminal A, is sent to a foreign bank account of Corpora-
tion B. Then in Belgium, a new investment Company C is incorporated. Criminal A is appointed as a director of Company
C. Company C borrows money from the foreign Company B and buys real estate in Belgium. The real estate is rented
to third parties. Director (Criminal) A also rents an apartment in the building. With the funds generated by the rent,
Company C pays off the loan to Corporation B, and the salary of Director A. Criminal A now converted his dirty money
in legal funds. This laundering method is commonly referred to as what? A. Offsetting real estate transactions. B. Loan
back. C. Cuckoo smur ng. D. Loan manipulation.
14. ACD: A new customer approaches a bank to open a commercial account. The customer provides an address for
the account located across the city from the branch. When asked by the account representative if the customer requires
any additional banking services, the customer responds she is also interested in opening a personal investment account.
The account representative refers the customer to their broker-dealer. The customer tells the rm representative she has
never had a brokerage account before and has a few questions about how an investment account works. The customer
asks how deposits can be made into her account, if there are any reporting requirements, and how to go about moving
balances out of the account using wire transfers. No questions are asked about fees associated with these transactions.
Which three items would be considered suspicious? A. The customer asks many questions about the brokerage account,
but none of them are related to investing. B. The customer is opening a commercial account and at the same time a
personal investment account. C. The address of the account holder and the branch where the customer came to open
the account are not close to each other. D. That the customer appears unconcerned about the fees.
15. A: International trade in goods and services can be used as either a cover for money laundering or as the
laundering mechanism itself. What is MOST important for the launderer when engaging in this method? The ability: A.
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1. C: The USA PATRIOT Act was passed in:
A) 1970
B) 1985
C) 2001
D) 2007
2. D: The three stages of money laundering are:
A) Layering, Placement, Refining
B) Placement, Refining, Integration
C) Refining. Integration, Layering
D) Integration, Layering, Placement
3. D: Which of the following would be satisfactory elements of an Anti-Money Laundering Program?
I - A CAMS certified employee in the Investigations Unit writes up a few policies and procedures and posts them on the
department bulletin board.
II - Shortly after attaining their CAMS certification, the individual provides AML training to the Investigations Unit.
III - The CAMS certified individual routinely reviews the work of the Investigations Unit.
IV - The CAMS certified individual assumes the responsibility of a compliance watchdog.
A) All of the above would be satisfactory
B) II and IV would be satisfactory
C) I and III would be satisfactory
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D) None of the above would be satisfactory
The correct answer would be "D - None of the above would be satisfactory."
I - The AML program must be approved by the Board of Directors.
II - An AML training program is required of all personnel (and contractors).
III - The review of the bank's Financial Intelligence Department, as part of the audit of the AML program, must be
performed by an independent (and knowledgeable) party.
IV - The Compliance Officer must be appointed by the Board of Directors (or upper management with the Board's
approval).
4. D: In determining what risks a customer poses, which consideration should NOT be a major factor?
A) Where the customer resides or where the business is headquartered.
B) What is the size of your financial institution.
C) What occupation or type of business does the customer derive their income from.
D) What are the customer's ethnic heritage, sexual orientation and political beliefs.
The correct answer would be "D." The customer's ethnic heritage, sexual orientation and political beliefs are more
discriminatory factors, and while they may help frame the context of certain transactions, they should not be a major
factor in assessing risk.
The size of your financial institution is a critical element in determining the level of sensitivity to risks for certain
customers.
Analysis questions require one to synthesize information, arrive at solutions and/or evaluate the usefulness of solutions.
, ACAMS Practice
Study online at https://quizlet.com/_hq9l9o
One needs to distinguish between facts and assumptions and to put various knowledge parts together to form a new
knowledge component or solution to a problem. While this is also an important part of being a professional, it comprises
only about 23% of the exam.
5. B: In general, the three phases of money laundering are said to be: Placement:
A. Structuring and manipulation. B. Layering and integration. C. Layering and smur ng. D. Integration and in ltration.
6. A: Which of the following is the most common method of laundering money through a legal money services
business?
A. Purchasing structured money instruments. B. Smuggling bulk-cash. C. Transferring funds through Payable Through
Accounts (PTAs). D. Exchanging Colombian pesos on the black market.
7. A: 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 smur ng is a signi cant money laundering technique identi ed by the Financial
Action Task Force, where a form of structuring uses nested accounts with shell banks in secrecy havens. C. In its
40 Recommendations, the FATF issued a list of "designated categories of offense" that asserts crimes for a money
laundering prosecution. D. E-cash is not attractive to the money launderer because it cannot be completely anonymous
and does not allow for large amounts to be "transported" quickly and easily.
8. BCD: Which three of the following is an indication of possible money laundering in an insurance industry
scenario? A. Insurance products sold through intermediaries, agents or brokers. B. Single-premium insurance bonds,
redeemed at a discount. C. Policyholders who are unconcerned about penalties for early cancellation. D. Policyholders
who make full use of the "free look" period.
9. AC: Which two activities are typically associated with the black market peso exchange (BMPE) money laundering
system? 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.
10. D: What is the Right of Reciprocity in the eld of international cooperation against money laundering? A. The legal
principle that nancial institutions that have referred customers to other nancial institutions can share information
about these customers with the other institutions. B. A rule of the Basel Committee allowing properly regulated nancia
institutes of another member state of the Basel Committee to do business without additional supervision to the degree
that the other state grants the same right. C. The right of each FATF member country to delegate prosecution of a case
of money laundering to another member that is already investigating the same case. D. A rule in the law of a country
, ACAMS Practice
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allowing its authorities to cooperate with authorities of other countries to the degree that their law allows them to do
the same.
11. C: The greatest risk for money laundering is for casinos that A. Provide their customers with a wide array of
gambling services. B. Operate in a non-Egmont member country. C. Allow customers with credit balances to withdraw
funds by check in another jurisdiction. D. Only send suspicious transaction reports to the nancial intelligence unit of
the country it operates in.
12. B: Which statement is true regarding the risk of Politically Exposed Persons (PEPs)? A. PEPs provide access to third
parties on whom the nancial institution has not conducted suf cient due diligence. B. PEPs have signi cantly greater
exposure to the politically corrupt funds, including accepting bribes or misappropriating government funds. C. PEPs
are foreign customers who inherently present additional risk as they are engaged in cross-border transactions. D. PEPs
generally do not pose enhanced risks to an institution due to their political standing; rather, PEPs increase the prestige
of an institution.
13. B: Dirty money, derived from criminal activities of Belgian Criminal A, is sent to a foreign bank account of Corpora-
tion B. Then in Belgium, a new investment Company C is incorporated. Criminal A is appointed as a director of Company
C. Company C borrows money from the foreign Company B and buys real estate in Belgium. The real estate is rented
to third parties. Director (Criminal) A also rents an apartment in the building. With the funds generated by the rent,
Company C pays off the loan to Corporation B, and the salary of Director A. Criminal A now converted his dirty money
in legal funds. This laundering method is commonly referred to as what? A. Offsetting real estate transactions. B. Loan
back. C. Cuckoo smur ng. D. Loan manipulation.
14. ACD: A new customer approaches a bank to open a commercial account. The customer provides an address for
the account located across the city from the branch. When asked by the account representative if the customer requires
any additional banking services, the customer responds she is also interested in opening a personal investment account.
The account representative refers the customer to their broker-dealer. The customer tells the rm representative she has
never had a brokerage account before and has a few questions about how an investment account works. The customer
asks how deposits can be made into her account, if there are any reporting requirements, and how to go about moving
balances out of the account using wire transfers. No questions are asked about fees associated with these transactions.
Which three items would be considered suspicious? A. The customer asks many questions about the brokerage account,
but none of them are related to investing. B. The customer is opening a commercial account and at the same time a
personal investment account. C. The address of the account holder and the branch where the customer came to open
the account are not close to each other. D. That the customer appears unconcerned about the fees.
15. A: International trade in goods and services can be used as either a cover for money laundering or as the
laundering mechanism itself. What is MOST important for the launderer when engaging in this method? The ability: A.
