AML Certification CAMS Reddit Questions

Non-compliance with anti-money laundering (AML) laws and regulations can lead to severe consequences for both financial institutions and individuals. One of the indirect consequences is the imposition of punitive fines. These fines can vary based on the type of violation and the institution’s willingness to address the issue. Additionally, non-compliance may damage a company’s reputation, impacting its standing in the market and potentially leading to financial losses beyond the fines themselves123.

A subpoena is a legal order that requires a person or an entity to produce documents, information, or testimony related to a legal matter. A financial intelligence unit (FIU) is a specialized unit within a financial institution that is responsible for detecting, analyzing, and reporting suspicious activities and transactions. When a bank receives a subpoena regarding one of its clients, the FIU should review the subpoena and perform a transaction review to determine if there is any evidence of money laundering, terrorist financing, fraud, or other criminal activity involving the client. The FIU should also respond fully to the subpoena by providing the requested information and documents, unless there is a valid reason to object or seek a protective order. The FIU should not adjust the client’s risk score, file a SAR, or close the client’s account based solely on the receipt of the subpoena, as these actions may be premature, inappropriate, or illegal. Adjusting theclient’s risk score may require further investigation and due diligence. Filing a SAR may be unnecessary or misleading if the subpoena does not indicate any suspicious activity. Closing the client’s account may violate the bank’s contractual obligations, customer service standards, or anti-discrimination laws. Moreover, these actions may alert the client or the subject of the investigation to the existence of the subpoena, which may interfere with the legal process or jeopardize the safety of the bank or its employees.

According to the ACAMS Study Guide for the CAMS Certification Exam (6th edition), page 215, one of the best practices for banks to prevent and detect mortgage fraud is to conduct internal investigations when there are red flags or suspicions of fraud involving bank employees. The investigation should include reviewing the employee’s loan files, interviewing the employee and other relevant parties, verifying the information and documents provided by the employee, and documenting the findings and actions taken. Filing a suspicious activity report (SAR) may be appropriate after the investigation is completed and the bank has reasonable grounds to suspect fraud. Filing a police report or initiating civil litigation may also be options depending on the outcome of the investigation and the bank’s policies, but they are not the first steps to take when the bank suspects an employee of mortgage fraud.

TheFATF Immediate Outcomes (IOs)measure the effectiveness of AML/CFT frameworks in jurisdictions.

Option A (Correct):International cooperationis key to combating financial crime, as outlined inImmediate Outcome 2.

Option B (Correct):Effective regulation of financial institutionsis part ofImmediate Outcome 3, which ensures compliance with AML laws.

Option E (Correct):Investigation and prosecution of money laundering offensesalign withImmediate Outcome 7.

Option C (Incorrect):FATF itself does not conduct investigations; FIUs share intelligence with domestic and international agencies.

Option D (Incorrect):While financial criminals face legal consequences, there is no global mandate to restrict their access to banking.