CAMS Exam Dumps - ACAMS AML Certifications Questions and Answers

This scenario presents multiple classic money laundering red flags, particularly within the life insurance sector, which is recognized by FATF as vulnerable to misuse due to its investment and payout features.

The use of an offshore trust in a jurisdiction with no clear link to the customer raises concerns about concealment of beneficial ownership and layering. Criminals frequently use trusts and offshore structures to obscure the origin and destination of illicit funds.

The client’s request to split premium payments into multiple transactions to avoid bank charges is indicative of structuring, a known money laundering technique used to evade monitoring and reporting thresholds.

Furthermore, the lack of a legitimate source of wealth or income consistent with the high-value policy is a significant red flag. Purchasing high-value insurance products with no apparent financial means is a common placement method for laundering illicit proceeds.

While fraud or sanctions evasion could be relevant in other contexts, the combination of structuring, unexplained wealth, offshore structures, and non-residency most strongly indicates money laundering risk.

Corruption risks in the supply of goods and services often arise when contractors receive preferential treatment, enabling inflated margins, and when procurement processes lack sufficient oversight, making it easier for bribes or kickbacks to influence tender outcomes.

Many jurisdictions lack robust sanctions frameworks, requiring international cooperation and education to improve compliance.

Option B (Correct):Educational initiatives such as AML/sanctions training and workshops help raise awareness and build capacity.

Option D (Correct):Bilateral cooperation allows knowledge-sharing and technical assistance between regulatory authorities.

Why Other Options Are Incorrect:

Option A (Incorrect):Trade restrictions may pressure non-compliant nations, but they do not directly improve sanctions awareness.

Option C (Incorrect):Enforcing fines without prior education or assistance is ineffective and may create diplomatic tensions.

Best Practices for Sanctions Awareness & Compliance:

Develop international AML/sanctions training programs for emerging markets.

Encourage diplomatic engagement to strengthen legal frameworks.

Leverage FATF’s Mutual Evaluation process to assess progress.

Financial Intelligence Units (FIUs) play a central role in national and international AML/CFT frameworks. According to FATF standards, FIUs are responsible for the receipt, analysis, and dissemination of financial intelligence related to suspected money laundering, terrorist financing, and predicate offenses.

One core function of an FIU is receiving and analyzing SARs submitted by financial institutions and other obliged entities. Through analysis of reported information, FIUs identify suspicious patterns, trends, and networks that may indicate financial crime.

Another key function is disseminating intelligence and typologies to competent authorities and, where appropriate, to the private sector. This includes sharing insights on emerging risks, new money laundering methods, and evolving threat trends, which enhances system-wide financial integrity.

FIUs do not design financial products for institutions, nor do they supervise AML programs—that responsibility lies with AML supervisory authorities. Their role is intelligence-focused rather than regulatory or commercial.

Hawala operatives rely on informal networks outside the regulated banking system, allowing funds to move across borders without the usual AML controls.

Because hawala transactions are settled on trust rather than recorded through formal channels, it’s often impossible to trace who originated or ultimately received the funds.

Using multiple sanctions lists ensures that financial institutions meet international regulatory obligations and can identify sanctions-related risks across different jurisdictions. This comprehensive approach strengthens compliance and reduces the likelihood of exposure to sanctioned individuals or entities.