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

For willful BSA violations, FinCEN can assess civil money penalties of up to $25,000 per day per violation, and criminal penalties can be even higher.

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

Smurfing is a form of structuring where a large sum is broken into multiple smaller transactions, each below the $10,000 CTR threshold, to evade currency reporting requirements.

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

AML policies describe frameworks and procedures but do not list individual customer names; high-risk customers are managed through systems and processes, not named in policies.

Question 4

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

Accepted Answer

$10,000

Answer

Financial institutions must file a CTR for any cash transaction exceeding $10,000 in a single business day, whether in one or multiple related transactions.

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

A gap analysis compares the institution's existing AML controls and procedures against regulatory requirements and best practices to identify areas needing improvement.

CAMS - Certified Anti-Money Laundering Specialist Certification Practice Test

CAMS - Certified Anti-Money Laundering Specialist Certification Practice Test

CAMS AML Compliance Programs 2