CAMS AML Compliance Programs 2

Question 1

What is the minimum civil money penalty FinCEN can assess for a willful BSA violation per transaction?

Accepted Answer

$25,000

Answer

$1,000

Answer

$5,000

Answer

$1,000,000

Question 2

What is 'smurfing' in the context of money laundering?

Accepted Answer

Structuring large cash transactions into multiple smaller ones to avoid reporting thresholds

Answer

Using shell companies to hide beneficial ownership

Answer

Converting cash into virtual currency to obscure the audit trail

Answer

Using nominees to open bank accounts on behalf of criminals

Question 3

Which element is NOT required to be included in a written AML compliance policy?

Accepted Answer

Names of all customers identified as high risk

Answer

Procedures for identifying and reporting suspicious activity

Answer

A description of the institution's risk profile

Answer

Roles and responsibilities of AML compliance staff

Question 4

Under the BSA, what is the threshold amount that triggers mandatory Currency Transaction Report (CTR) filing?

Accepted Answer

$10,000

Answer

$5,000

Answer

$7,500

Answer

$15,000

Question 5

What is the purpose of a 'gap analysis' in an AML compliance program?

Accepted Answer

To identify weaknesses or deficiencies in the current AML program compared to regulatory expectations

Answer

To identify customers who have gaps in their account history

Answer

To measure the time gap between suspicious activity and SAR filing

Answer

To calculate the gap between reported and unreported income

Question 6

Which of the following best describes 'willful blindness' in AML compliance?

Accepted Answer

Intentionally avoiding knowledge of suspicious circumstances that a reasonable person would investigate

Answer

Deliberately failing to report known criminal activity

Answer

Refusing to implement AML policies due to cost concerns

Answer

Neglecting to update AML software for known vulnerabilities