ACAMS Study Guide 2026

MSBs are non-bank financial businesses that handle currency, money orders, wire transfers, and similar instruments. They require EDD because their cash-intensive, high-volume operations and often anonymous customers create significant ML/TF exposure.

The board of directors bears ultimate accountability for BSA/AML compliance. The board approves the AML program and policies, receives regular compliance reports, ensures adequate resources are allocated, and is held responsible by regulators for the effectiveness of the program.

The best resource for evaluating the effectiveness of an AML program is a qualified independent party/auditor. An independent auditor provides an objective and unbiased assessment of the program's design and operational effectiveness, identifying weaknesses and areas for improvement without internal conflicts of interest. This external review ensures the program meets regulatory requirements and effectively mitigates risks.

Transaction monitoring for VASPs uses blockchain analytics to detect suspicious patterns on public ledgers, but the pseudonymous nature of wallet addresses — where owners are not inherently identifiable — makes it significantly harder to link activity to real-world individuals than in traditional banking.

Institutions must respond to 314(a) inquiries confirming or denying whether the named individual has current accounts or conducted transactions, while simultaneously maintaining confidentiality of both the SAR investigation and the 314(a) response — they are separate, confidential processes.

Blocking under OFAC means freezing assets or transactions involving sanctioned persons or entities so they cannot be transferred, withdrawn, or used.