CAMS Questions Bank

AML compliancemust be balanced with data protection lawssuch asGDPR (EU), CCPA (U.S.), and local banking secrecy laws.

Option B (Correct):Data minimization ensures financial institutions only collect and retain essential customer dataneeded for AML compliance.

Option C (Correct):Regularly updating data processing policies ensures compliance with evolving data protection regulations.

Why Other Options Are Incorrect:

Option A (Incorrect):Unrestricted access to customer data increases privacy risksand canviolate GDPR and other data protection laws.

Option D (Incorrect):AML data must not be repurposed without regulatory justification, asGDPR requires data usage to align with its original collection purpose.

Best Practices for Managing Data Privacy in AML Compliance:

Restrict access to AML data on a need-to-know basis.

Implement strong encryption and security controls for customer data.

Ensure all AML-related data collection aligns with privacy regulations.

 the U.S. government has the authority to seize and forfeit funds in a correspondent account of a non-U.S. bank if the funds are involved in or traceable to a money laundering offense, regardless of where the offense occurred. This is based on the USA PATRIOTAct, which expanded the definition of “proceeds of specified unlawful activity” to include any property that is derived from or traceable to a foreign offense that would be a predicate offense if committed in the U.S12

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1: ACAMS Study Guide for the CAMS Certification Examination, 6th Edition, Chapter 4, page 137

2: USA PATRIOT Act, Title III, Section 319(b)

A compliance officer should consider the following three factors as part of the approach to implement an enterprise-wide anti-money laundering program for a bank that operates in multiple countries:

The types of customers serviced by the bank: Different types of customers may pose different levels of money laundering risk, depending on their nature, source of funds, geographic location, transaction patterns, and other factors. A compliance officer should identify and assess the money laundering risk associated with each customer type and segment, and apply appropriate due diligence measures, monitoring systems, and risk mitigation strategies accordingly12.

The extent of anti-money laundering regulations in the various countries: A compliance officer should be aware of the legal and regulatory requirements and expectations for anti-money laundering compliance in each country where the bank operates, and ensure that the bank’s policies and procedures are consistent with them. A compliance officer should also monitor any changes or updates in the anti-money laundering laws and regulations in the various countries, and adjust the bank’s program accordingly34.

The anti-money laundering risk posed by the products and services offered by the bank: Different products and services may have different features and functionalities that could be exploited by money launderers, such as anonymity, cross-border transfers, cash transactions,complex structures, or new technologies. A compliance officer should evaluate the money laundering risk associated with each product and service offered by the bank, and implement appropriate controls, safeguards, and oversight mechanisms to prevent and detect money laundering activities5 .

1: ACAMS, CAMS Study Guide, 6th Edition, Chapter 2: Risk Assessments

2: FATF, Guidance for a Risk-Based Approach: The Banking Sector

3: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT)

4: Deloitte, AML Program Effectiveness Reform

5: ACAMS, CAMS Study Guide, 6th Edition, Chapter 4: AML Program Design

[6]: OCC, Money Laundering: A Banker’s Guide to Avoiding Problems