ACAMS CAMS7 Exam
Certified Anti-Money Laundering Specialist (the 7th edition) (Page 8 )

Updated On: 7-Feb-2026

A compliance officer at an insurance company has been reviewing the transaction activity of several clients. Which transaction is considered a red flag for potential money laundering?

  1. A client paid the quarterly life insurance premium using money orders from two different banks.
  2. A client from a high-risk jurisdiction recently purchased property insurance for a real-estate development.
  3. A corporation owns several affiliates and recently opened separate group life insurance policies for each of the affiliates.
  4. A client established a $100, 000 charitable annuity with a non-profit organization that provides health and safety assistance internationally.

Answer(s): D



The branch manager notices that a number of customers come in weekly and always use the same teller to process their deposits. The manager notices that the customers and the teller, who are from the same ethnic group, are speaking in a foreign language and every once in a while the customers from local ethnic restaurants will bring the teller lunch. The commercial customers that visit the teller generally deposit the same amount of cash each time they come in.

How should the branch manager respond to this activity?

  1. Transfer the teller to another branch
  2. Conduct further investigation before taking any other action
  3. Encourage the teller to bring in more business from the ethnic community
  4. Suggest to the teller to send the customers to other tellers to avoid the opportunity for collusion

Answer(s): B



A law enforcement official calls a bank inquiring about a customer who is currently under investigation. The law enforcement official requests information about the customer.

How should the bank respond?

  1. Confirm the customer is either a current or former customer
  2. Inform the board of directors before responding to the request
  3. Provide the requested information to help aid in the investigation
  4. Request a formal letter be submitted to verify the validity of the request

Answer(s): D


Reference:

https://ico.org.uk/for-organisations/guide-to-freedom-of-information/receiving-a-request/



A bank compliance officer has implemented enhanced monitoring rules that have identified some unusual activity that may be indicative of human trafficking.

Which red flag should prompt additional transactional review?

  1. Wire transfer activity from countries with significant migrant populations
  2. Cash deposits that occur in cities where the customer resides and conducts business
  3. Cash deposits that occur in cities where the customer does not reside or conduct business
  4. Cash deposits that occur in cities where the customer does not reside or conduct business followed by same-day withdrawals

Answer(s): C



The compliance officer for a private bank has been tasked with writing a policy on how the bank will deal with intermediaries.

Which two aspects should be included in the policy in respect of intermediaries to align it with the Wolfsberg Anti-Money Laundering Principles for Private Banking? (Choose two.)

  1. When an intermediary introduces clients to the bank, it is not necessary for the bank to perform due diligence on the intermediary’s clients.
  2. Where an intermediary introduces clients to the bank, the bank must obtain the same type of information with respect to an introduced client that would otherwise be obtained by the bank, absent the involvement of the intermediary.
  3. Where an intermediary manages assets on behalf of a number of clients and is the account holder with the bank, but that intermediary does not conduct the same level of due diligence as the bank, it is necessary for the bank to undertake due diligence on the intermediary’s clients.
  4. Where an intermediary manages assets on behalf of a number of clients and arranges for the opening of accounts for its clients with the bank, and that intermediary is a financial institution subject to similar regulations, it is necessary for the bank to perform due diligence on the intermediary’s clients.

Answer(s): B,D


Reference:

https://www.wolfsberg-principles.com/sites/default/files/wb/pdfs/faqs/20.%20Wolfsberg-FAQs-on-Intermediaries-May-2012.pdf (2)






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