Free CAMS Questions Attempt

This scenario describes the risk assessment element of an anti-financial crime (AFC) compliance program. FATF standards require organizations to regularly assess and reassess their money laundering and terrorist financing risks, particularly when there are material changes to business models, geographic exposure, or regulatory environments.

The MLRO’s review of the company’s expansion into high-risk jurisdictions and identification of vulnerabilities reflects a dynamic and forward-looking risk assessment process. Updating the compliance framework to address identified risks ensures that controls remain proportionate and effective.

Risk assessments form the foundation of the risk-based approach and directly inform decisions on enhanced due diligence, monitoring, governance, and resource allocation. This process is distinct from transaction monitoring, governance arrangements, or training activities, although those elements may be updated as a result of the risk assessment.

A risk-based approach is central to AML/CFT programs and includes:

A: Creating detailed risk profiles for customers based on their behaviors and connections.

C: Applying controls that are tailored to the actual risk (not a one-size-fits-all approach).

D: Performing a thorough risk assessment, considering customer, transaction, and geographic factors.

“A risk-based approach involves risk profiling, tailored controls, and comprehensive risk assessment across key risk factors.”

(CAMS 6th Edition, Risk-Based Approach and Risk Assessment)

Incorrect:

B: Monitoring only flagged customers is not sufficient.

E: Equal allocation of resources ignores differing risk levels.

The suspicion increases when the beneficiary is a foreign company whose shareholders and director are other companies, as this can indicate the use of layered corporate structures to obscure the ultimate beneficial owner and conceal illicit fund flows.