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| Section | Weight | Objectives |
|---|---|---|
| Topic 1: Understanding Risks and Methods of Financial Crime | 30% | - Financial Crime Risks related to real estate - Financial Crime Risks related to gaming and gambling - Financial Crime Risks related to insurance products - Financial Crime Risks related to gatekeepers - Financial Crime Risks related to Politically Exposed Persons (PEPs) and high-risk customers - Financial Crime Risks related to MSBs, PSPs, and ecommerce platforms - Financial Crime Risks related to trusts and company service providers - Financial Crime Risks related to products within other financial sectors - Financial Crime Risks related to VASPs, cryptoassets, and related products |
| Topic 2: Tools and Technologies to Fight Financial Crime | ||
| Topic 3: Global AFC Frameworks, Governance and Regulations | - AML Regulatory Framework (Elective options: Canada, EU, UK, USA) | |
| Topic 4: Building an AFC Compliance Program |
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질문 # 93
During a routine periodic KYC refresh of a policyholder and client of an insurance company, updated business registry documentation has highlighted that the policyholder's business has changed addresses five times during the last year and that the ultimate beneficial owner (UBO) changed two weeks ago. What actions should be taken immediately?
정답：D
설명：
The combination of frequent address changes and a recent change in the ultimate beneficial owner raises potential red flags that warrant immediate investigation. To mitigate risk, the insurance company should investigate these changes and temporarily decline any payment or withdrawal instructions until the review is complete and appropriate steps are agreed upon. This ensures both regulatory compliance and protection against potential misuse of the policy.
질문 # 94
Which of the following entities could potentially pose a higher money laundering risk and require additional review prior to onboarding? (Select Two.)
정답：C,D
설명：
Higher-risk customer profilesoften include businesses that:
Regularly handle large volumes of cash
Operate in sectors withhistorical vulnerabilities to money laundering
Are involved invirtual assets or unregulated financial activities
Option C - A local used car sale lot that allows cash payments:
This business type is consideredcash-intensive, and accepting monthly payments in cash raises concerns about the source of funds, potential structuring, or placement of illicit proceeds.
Option D - A Virtual Asset Service Provider (VASP):
VASPs involved inpeer-to-peer crypto transactionspresent elevated AML risks due to theanonymity, speed, and borderless natureof virtual assets. These institutions are often subject toenhanced due diligence requirements.
Option Ais incorrect: A large multinational with documented transactions and transparency typically poseslower inherent risk, though still subject to review.
Option Bmay be reviewed, buton-site ATM replenishment using store cashis not automatically a red flag without other risk indicators.
Reference: ACAMS CAMS Study Guide - 6th Edition, Chapter:Customer Risk Profiling- Section:Higher- Risk Business Types and Entities
질문 # 95
Technology has the potential to increase the efficiency and effectiveness of AML/CFT workflows by: (Select Two.)
정답：B,D
설명：
Technology plays a critical role in strengthening AML/CFT programs by improving efficiency, consistency, and scalability. Regulators encourage the responsible use of technology while maintaining governance and oversight.
One major benefit is processing large volumes of data efficiently, helping institutions eliminate investigative backlogs and manage increasing transaction volumes. Technology also automates repetitive tasks, reducing human error and improving data accuracy, allowing compliance professionals to focus on higher-value investigative work.
Technology does not eliminate privacy concerns, and front-end search tools alone are not sufficient to drive effectiveness. Human oversight remains essential for decision-making, investigations, and regulatory reporting.
질문 # 96
What are the common financial crime risks posed to the e-commerce business model? (Select Three.)
정답：B,D,E
설명：
E-commerce business models are exposed to several financial crime risks that are clearly identified in Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) regulatory guidance, including publications from the Financial Action Task Force (FATF) and national supervisory authorities.
One key risk is the use of stolen bank card or payment data to purchase goods or services online.
E-commerce platforms are particularly vulnerable to card-not-present fraud, where criminals exploit remote payment channels to generate illicit proceeds.
Another common risk is fraud against customers through non-delivery of goods or services. In these cases, fraudulent merchants accept payments without any intention of fulfilling orders. This form of consumer fraud is recognized as a predicate offense to money laundering under AML frameworks.
Additionally, online marketplaces may be abused to move or disguise criminally obtained funds.
Criminals may conduct fake transactions, self-purchases, or repeatedly buy and resell goods to legitimize illicit funds. This activity aligns with recognized typologies such as transaction laundering and trade-based money laundering.
Although export control evasion and bribery and corruption are serious financial crimes, they are not typically considered common or inherent financial crime risks specific to standard e- commerce business models in AML/CFT guidance.
질문 # 97
Which of the following are AML risks associated with onboarding a high-risk customer? (Select Two.)
정답：A,D
설명：
High-risk customers present elevated money laundering and terrorist financing risks, requiring careful consideration before onboarding. FATF guidance emphasizes that higher-risk relationships demand stronger controls due to their increased vulnerability to misuse.
One key risk is the greater potential for laundering illicit proceeds. High-risk customers may operate in sectors, jurisdictions, or business models that are frequently abused for financial crime, increasing the likelihood that illicit funds could pass through the institution.
Another significant risk is the increased likelihood of involvement in financial crimes, either directly or indirectly. This may include exposure to corruption, fraud, sanctions evasion, or organized crime networks.
Enhanced due diligence is not a risk but rather a risk-mitigating control imposed by regulators.
Reduced regulatory scrutiny is incorrect, as high-risk customers are subject to greater--not lesser-
-oversight.
질문 # 98
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