Taking the CAMS Examination
The CAMS examination consists of 120 multiple choice and multiple selection questions.
All candidates have 3 1⁄2 hours to complete the exam. There is no penalty for guessing. Avoid leaving any questions unanswered to maximize your chances of passing. It is better to guess than to leave a question unanswered. Additional study and test-taking tips can be found in the CAMS Examination Study Guide that all candidates receive as part of the CAMS Examination package. For practice questions, please see Chapter 7 of the Study Guide.
CAMS Examination Content Outline
I.
RISKS AND METHODS OF MONEY LAUNDERING AND TERRORISM FINANCING
A. Money Laundering and Terrorism Financing Methods
1. Name economic and social effects and risks of money
laundering
2. Recognize methods used
a. in banks and other deposit-taking institutions (e.g., credit unions, other credit institutions – building societies)
b. in non-bank financial institutions (e.g., insurance companies, broker-dealers, casinos, precious metal dealers, dealers in real estate and high-value items, bureaux de change, money services businesses)
c. by gatekeepers (e.g., lawyers, notaries, accountants, auditors, investment advisors)
B. Recognition of Risks
1. Recognize risks associated with
a. new technologies (e.g., on-line banking, Internet casinos, on-line brokerage, e-commerce, secured payment processing, stored-value cards)
b. terrorist financing methods (e.g., charities, non- governmental organizations)
c. other known methods (e.g. FATF Typologies, FIU SAR reviews, Egmont Group’s showcases)
2. Recognize risks inherent to structures designed to hide beneficial ownership (e.g., companies not registered, trusts, shell corporations, off-shore companies, shelf companies, bearer shares, bonds or other certificates of ownership)
3. Identify differing jurisdictional risks dependent
on legislation, regulation, and secrecy laws, and government reports (e.g., FATF member countries, World Bank / IMF sanctions, corruption index, various governmental agency advisories, off-shore banking centers)
II.
COMPLIANCE STANDARDS FOR ANTI-MONEY LAUNDERING (AML) AND COMBATING THE FINANCING OF TERRORISM (CFT)
A. International
1. Articulate FATF recommendations and other FATF
initiatives
2. Articulate BASEL customer due diligence and KYC principles
3. Articulate Wolfsberg AML Principles for private and correspondent Banking, the financing of terrorism, and monitoring and screening for suspicious activity
B. Regional
1. Articulate EU Directives on Money Laundering
2. Articulate appreciation of key US legislative (e.g., USA PATRIOT Act) and regulatory initiatives applied to international transactions
III. AML COMPLIANCE PROGRAM
A. AML / CFT Compliance Program Design in Different Industry Settings
1. Assess risk (e.g., product, customer, geography) and
design a risk scoring model for the institution
2. Advise the institution and specific business units of any AML concerns and recommend appropriate mitigating factors
3. Develop internal AML policies, procedures, and controls
4. Conduct ongoing AML training
5. Obtain endorsement of senior management and / or board of directors
6. Implement account opening controls (e.g., KYC, enhanced due diligence, customer verification)
7. Evaluate, implement, and utilize Electronic AML Tools
8. Perform background investigations on customers and potential employees
9. Monitor and trace money or funds through a business
10. Identify suspicious behavior associated with
a. general client behavior (e.g., nervous demeanor, unusual questions, customer identification circumstances)
b. transactions or account activity in different settings (e.g., cash transactions, non-cash deposits, wire transfers, correspondent and commercial accounts, safe deposit box, credit transactions, trade financing and investment activity, non-financial and non-bank financial institution settings)
c. suspicious employee activity
11. Process SARs / STRs internally and externally
12. Report results to the competent authority
13. Cooperate with the competent authority after reporting suspicious activity
14. Manage regulatory or other legal implications of SARs / STRs
15. Apply and implement a consolidated AML program for institutions operating in multiple jurisdictions including
a. ongoing internal assessments of the AML program
b. independent assessments of the AML program
c. screening of high-risk and prohibited entities (e.g., PEPs, OFAC)
B. Maintenance of an Effective AML / CFT Compliance Program
1. Identify
a. best practices for embedding compliance into institutional culture
b. trends from SARs / STRs and adapt the program as necessary
2. Conduct and evaluate ongoing internal assessments of the current AML program
3. Implement necessary program changes (e.g., policy / procedure change, enhanced training)
4. Develop, implement, and document ongoing training
5. Assess the risk of new business products and services
6. Monitor and incorporate changes to legislation, regulations, and guiding principles
7. Communicate program effectiveness to management and / or the board of directors
8. Respond to AML audit findings, document the response, and adopt appropriate actions
9. Identify and apply relevant trends from international and national typologies and exercises
10. Ensure
a. timely conduct of independent examinations or audits of AML and CFT programs
b. institutional awareness of high-risk and prohibited entities (e.g., PEPs, OFAC, FEPs)
11. Coordinate with the Human Resources department to implement appropriate screening programs to ensure high standards when hiring employees
IV. CONDUCTING OR SUPPORTING THE INVESTIGATION PROCESS
A. SAR and STR Filing
1. Ensure senior management and the board of directors
are provided information regarding SARs / STRs including a
a. summary of all SARs / STRs
b. detailed listing of high-profile SARs / STRs (e.g., on
employees, PEPs)
2. Maintain an internal investigation log / diary
3. Report SARs / STRs to appropriate authorities in the prescribed manner
4. Maintain and secure all supporting documentation used to identify suspicious activity
5. Deliver records to law enforcement and government authorities on request
6. Provide evidential / expert statements on behalf of the institution
7. Recommend to an institution whether to maintain or close an account after
a. consulting legal counsel
b. an appropriate written request by a law enforcement
agency to leave an account open
B. Assistance of Institutional Investigations.
1.Contact and cooperate with enforcement agencies
2.Identify and provide records that are legally available to law enforcement officers without a court order / subpoena
3.Share information with other financial institutions or government agencies in accordance with applicable laws
4.Recommend whether to terminate or suspend an employee within the institution who may be involved in an activity under investigation
5.Coordinate an investigation of an employee or high-profile customer or transaction with internal management, legal advisors, and auditors
C. Assistance of Legal and Government Inquiries Domestically and Internationally Within Parameters of the Law
1. Identify appropriate interviewing techniques and
content
2. Interview customers and employees using appropriate techniques (e.g., body language, proximity)
3. Interpret information gathered during a customer or employee interview
4. Commence an investigation through the identification of research tools and sources of information
5. List methods by which law enforcement may request information from a financial institution
6. Deliver records to enforcement agencies in response to a subpoena or court order in accordance with the law
7. Identify and provide records that are legally available to law enforcement officers without a court order or subpoena
8. Explain
a. how authorities (e.g., FIUs, central banks, governments, regulatory bodies) can cooperate across jurisdictions and how they lend expertise in money laundering investigations and prosecutions
b. the role of authorities to guard against control or acquisition of significant participation in a financial institution by criminals or their confederates
c. the basis and means for cooperation between countries in anti-money laundering investigations including:
• freezing
• seizure
• confiscation
• mutual legal assistance • letters rogatory
• informed exchanges
• extradition
d. What a government FIU does, what the ideal set up looks like, and how it interacts with the private sector
9. Describe the role of strict safeguards on privacy and data protection