CAMS ACAMS Certified Anti-Money Laundering Specialist (CAMS7 the 7th edition) Free Practice Exam Questions (2026 Updated)

Nominee shareholders may be used for legitimate commercial reasons; however, FATF guidance identifies nominee arrangements as a significant money laundering risk when they obscure beneficial ownership.

The greatest risk arises when nominee shareholders provide anonymity to the true beneficial owner, preventing transparency in public registers and complicating due diligence. Criminals may exploit this opacity to conceal ownership, evade sanctions, launder illicit proceeds, or avoid tax and regulatory scrutiny.

The ability to hide ownership undermines one of the core objectives of AML/CFT frameworks: identifying and verifying beneficial owners. As a result, regulators require enhanced due diligence and clear documentation when nominee shareholders are involved.

Other features—such as administrative efficiency, compliance with local laws, or ease of share transfer—do not inherently increase financial crime risk when transparency and disclosure requirements are met.

An effective AML/CFT compliance program must include several core elements outlined in FATF recommendations and national regulations. One of these essential elements is an independent and skilled audit function.

The purpose of independent audit is to test and validate the effectiveness of AML controls, identify weaknesses, and ensure compliance with regulatory requirements. Audits must be conducted by qualified personnel who are independent from the day-to-day AML operations to maintain objectivity.

While enterprise risk management frameworks and advanced technologies such as AI can enhance AML programs, they are not mandatory foundational elements. Regulators focus on governance, oversight, and accountability rather than technology sophistication.

An independent audit function ensures continuous improvement and provides assurance to senior management and regulators that the AML program is operating effectively.

FIUs rely on formal cooperation mechanisms to exchange information lawfully and efficiently across borders. One of the most widely used mechanisms is a Memorandum of Understanding (MOU) between FIUs in different jurisdictions.

MOUs establish the terms, scope, confidentiality protections, and procedures for sharing financial intelligence. They enable FIUs to exchange information directly, quickly, and securely while respecting data protection and domestic legal requirements. This structure significantly reduces bureaucratic delays and supports effective cross-border investigations.

FATF and regional bodies are standard-setters and evaluators, not operational information-sharing hubs. The Wolfsberg Group is a private-sector association and does not facilitate FIU-to-FIU communication. MLATs are used primarily by law enforcement and judicial authorities for criminal proceedings and arrests—not for FIU intelligence exchange.

Therefore, MOUs are the correct and most appropriate mechanism for FIU cooperation.

When a financial institution receives a grand jury subpoena, it is legally compelled to respond, but must do so in a controlled, lawful, and coordinated manner.

The first step is to consult with legal counsel to verify the subpoena’s validity, scope, deadlines, and confidentiality requirements. Legal counsel ensures the institution responds accurately, protects privileged information, and complies with applicable laws.

Notifying the customer would constitute tipping off, which is prohibited. Immediate disclosure without legal review may result in over-disclosure or violation of customer privacy laws. Filing a SAR may be appropriate depending on the facts, but it is not the first step and must not reference the subpoena.

This approach aligns with U.S. AML, BSA, and law enforcement cooperation requirements.

“Tipping off” is a serious offense under AML/CFT legislation in many jurisdictions and is consistently addressed in FATF standards. It occurs when confidential information relating to a suspicious transaction, SAR, or ongoing investigation is disclosed without authorization to a person who is the subject of the report or whose knowledge could compromise the investigation.

Such disclosures may alert criminals, allowing them to conceal evidence, move funds, or evade law enforcement. For this reason, tipping off is typically a criminal offense, not merely a breach of internal policy.

The prohibition applies broadly—not only to AFC professionals but to anyone with access to sensitive AML information. Making detailed or targeted inquiries with a customer after a transaction has been flagged can constitute tipping off if it reveals suspicion or investigative activity. Relationship managers must be carefully controlled and should not be instructed to probe customers in a way that signals suspicion.

Therefore, the correct statement is that tipping off is an unauthorized disclosure that can prejudice an investigation.

The FATF conducts mutual evaluations—a peer review process—whereby member countries assess each other’s AML/CFT systems. This includes on-site visits and reviews by international experts, with public reports containing recommendations for improvement. The process is not punitive and does not impose sanctions.

“FATF mutual evaluations are peer reviews in which experts from member countries assess another member's AML/CFT system and provide recommendations.”

(CAMS 6th Edition, International AML/CFT Standards; FATF Methodology, Recommendation 40)

The real estate sector is recognized by FATF as vulnerable to money laundering due to the high value of transactions and the ability to integrate illicit funds into legitimate assets.

Key red flags include the use of commercial properties in ways inconsistent with the declared business purpose, which may indicate the property is being used to park or disguise illicit funds rather than generate legitimate income.

The use of complex loans or credit financing arrangements can be employed to obscure the true source of funds and create artificial legitimacy. Similarly, corporate vehicles and complex ownership structures are frequently used to conceal beneficial ownership.

Unexplained cash payments are among the most common and serious indicators of money laundering in real estate transactions, particularly when inconsistent with the buyer’s profile or local market practices.

The mere use of mortgages or agricultural land does not inherently indicate money laundering risk.

Trust and company service providers (TCSPs) are classified as higher-risk entities under FATF guidance due to their role in forming and managing legal structures. As a result, TCSPs must implement robust AML controls to mitigate misuse for money laundering.

A key requirement is gathering and recording detailed client information, including the purpose of the legal entity and the identity of managers and ultimate beneficial owners (UBOs). This supports effective customer due diligence and transparency.

TCSPs must also apply additional safeguards when relying on instructions from another TCSP, particularly one located in a different jurisdiction. Reliance on intermediaries increases risk and requires enhanced scrutiny.

Additionally, TCSPs should document the basis on which they act as a registered officer and retain records of their involvement. This ensures accountability and traceability in line with record-keeping obligations.

Requiring clients to submit AML self-assessments to an FIU and conducting onsite evaluations are not standard or required practices under AML frameworks.

Effective sanctions screening depends heavily on strong list management governance, as emphasized in sanctions compliance guidance from regulators such as OFAC and FATF.

First, restricting list modification to authorized individuals is critical. This ensures proper governance, auditability, and control over updates, reducing the risk of errors, unauthorized changes, or manipulation of screening outcomes.

Second, sanctions and watchlists may be sourced internally or from reputable third-party vendors. Many financial institutions supplement regulatory lists with internal watchlists, law enforcement requests, or commercially curated databases to enhance detection capabilities. This flexibility supports a risk-based approach.

Using only regulatory lists may be insufficient for identifying broader sanctions evasion risks, while applying all lists in all jurisdictions may lead to legal conflicts and over-screening. Institutions must tailor list usage based on jurisdictional applicability and legal requirements.

Together, controlled access and flexible list sourcing form the foundation of effective sanctions list management.

Criminals may target accountants because they have the capability to create and structure companies, falsify accounts, and manipulate financial statements, which can be exploited to disguise illicit funds and facilitate money laundering.

The First Line of Defense (1LoD) consists of customer-facing business units (e.g., relationship managers, front-office staff, and operational teams). Their primary responsibility in financial crime risk management is to implement AML/CFT controls as part of daily operations. This includes Collecting complete customer information.

The First Line of Defense is responsible for conducting Know Your Customer (KYC) and Customer Due Diligence (CDD) during onboarding and throughout the customer relationship. Ensuring that all relevant customer details (e.g., identity, business purpose, ownership structure) are accurately collected and documented is crucial for mitigating financial crime risks.

Transaction monitoring governanceinvolves ensuring thatAML detection systems are effective, aligned with regulatory standards, and capable of identifying evolving threats.

Option B (Correct):Legal cooperation is essential for responding to subpoenas and law enforcement inquiries.

Option D (Correct):Regularly updating transaction monitoring scenarios ensures that the system adapts to emerging financial crime trends.

Why Other Options Are Incorrect:

Option A (Incorrect):SARs cannot be withdrawn unless an error was made—once filed, SARs remain confidential and must be retained.

Option C (Incorrect):Client profile updates are a CDD/KYC function, not directly related to transaction monitoring governance.

Best Practices for Transaction Monitoring Governance:

Regularly review system effectiveness through validation tests.

Collaborate with legal and compliance teams for risk mitigation.

Use AI and data analytics to refine detection accuracy.

The origin of the funds is a primary financial crime risk when dealing with a TCSP connected to a high-risk country. Funds originating from such jurisdictions may be linked to illicit activity, especially if source verification is weak or absent.

Trust and company service providers (TCSPs) are recognized by FATF as higher-risk gatekeepers due to the nature of services they provide, which can be misused to facilitate money laundering.

The use of nominee directors can obscure beneficial ownership, allowing criminals to hide their involvement behind third parties. This lack of transparency is a significant AML risk.

The sale of ready-made or shelf companies, particularly through offshore intermediaries, enables rapid creation of legal entities with no operating history, which are frequently used in layering schemes.

Additionally, minimal face-to-face interaction—especially in offshore service models—reduces the ability to verify customer identity and intent, increasing impersonation and misuse risks.

TCSPs do not market themselves to criminals and are subject to AML obligations in most jurisdictions, making those options incorrect.