ACAMS CAMS - Certified Anti-Money Laundering Specialist (CAMS7 the 7th edition)

Open-source tools offer cost-effective access to diverse data sources, making them valuable for financial crime investigations. They also support partial automation of data collection and analysis, reducing manual effort and improving efficiency in identifying suspicious patterns or links.

Trust and Company Service Providers (TCSPs) pose the greatest financial crime risks when they use trusts to obscure beneficial ownership, promote complex corporate structures that make tracing ownership difficult, and establish shell companies that can be used to hold and move illicit funds. These activities can facilitate money laundering, tax evasion, and other financial crimes by concealing the true origin and control of assets.

Regulatory frameworks and enforcement actions consistently emphasize individual accountability at the highest levels of governance when AML/CFT compliance programs are deficient in design or implementation.

The board of directors is ultimately responsible for oversight of the institution’s AML/CFT framework. This includes approving policies, setting risk appetite, and ensuring that adequate resources and governance structures are in place. Failure to fulfill these responsibilities can result in regulatory findings and personal accountability.

Senior management is responsible for implementing the board-approved AML/CFT strategy and ensuring that controls operate effectively in practice. This includes overseeing compliance functions, addressing identified weaknesses, and ensuring timely remediation. Deficiencies in program design—such as inadequate risk assessments or ineffective controls—often lead regulators to hold senior management accountable.

While the compliance department plays an important role in execution and advisory functions, accountability for program design and effectiveness rests with the board and senior management, not committees or individual departments.

UN sanctions regimes are not punitive but aim to:

B: “Support peaceful resolution of conflicts.”

D: “Deter non-democratic and unconstitutional changes of government.”

E: “Promote respect for human rights and humanitarian law.”(CAMS 6th Edition, United Nations Sanctions; UN Security Council Mandates)

Incorrect:

A: The UN does not impose sanctions to force regime type.

C: Sanctions are not for punishing weak AML controls.

When setting a fuzzy matching threshold for sanctions screening, it is crucial to consider the reliability and accuracy of the data being screened. High-quality, verified data supports more effective matching and reduces both false positives and the risk of missing true matches.

Trade-based money laundering red flags include third-party involvement in transactions, amended letters of credit without clear justification, and non-standard settlement arrangements, all of which can indicate attempts to disguise illicit fund movements or the true nature of the trade.