CAMS Reviews Questions

BSA/AML compliance staff should report to the compliance function or another second line of defense internal control function to maintain independence from business line management, ensuring objective oversight and effective compliance controls.

Virtual Asset Service Providers (VASPs) are considered higher-risk customers due to their exposure to anonymity, speed, and cross-border transactions. FATF guidance highlights several red flags indicative of potential money laundering activity.

The use of shell companies to move funds into and out of a VASP is a strong indicator of attempts to conceal beneficial ownership and obscure transaction flows. Similarly, frequent use of mixers and tumblers is a well-recognized technique used to break transaction trails and hinder blockchain tracing.

Receiving funds from jurisdictions with weak AML frameworks significantly increases geographic risk, particularly when combined with other red flags.

By contrast, peer-to-peer infrastructure use and market volatility are inherent features of the virtual asset ecosystem and do not, on their own, indicate money laundering.

FATF standards require organizations to adopt a risk-based approach (RBA) that is informed by both internal risk factors and national and sectoral risk assessments. These assessments provide critical insight into prevalent money laundering and terrorist financing threats within specific jurisdictions and industries.

Organizations should integrate relevant findings from these assessments into their internal risk assessments to ensure that policies, controls, and monitoring systems are aligned with identified risks. This enables institutions to tailor enhanced due diligence (EDD) measures and allocate compliance resources effectively.

Ignoring national or sectoral assessments would weaken the organization’s ability to respond to known threats and would be inconsistent with regulatory expectations. These assessments are not limited to worst-case scenarios nor intended solely for regulators; they are a foundational input for private-sector AML programs.

Technology plays a critical role in strengthening AML/CFT programs by improving efficiency, consistency, and scalability. Regulators encourage the responsible use of technology while maintaining governance and oversight.

One major benefit is processing large volumes of data efficiently, helping institutions eliminate investigative backlogs and manage increasing transaction volumes. Technology also automates repetitive tasks, reducing human error and improving data accuracy, allowing compliance professionals to focus on higher-value investigative work.

Technology does not eliminate privacy concerns, and front-end search tools alone are not sufficient to drive effectiveness. Human oversight remains essential for decision-making, investigations, and regulatory reporting.