Advanced-CAMS-Audit Advanced CAMS-Audit Certification Exam Questions and Answers

Enhancements to the CRA Process:

Risk Factors:Identify and document specific risk indicators for transparency and consistent assessment. This ensures alignment with the risk-based approach advocated by FATF​​.

Type of Customer:Differentiating customer types (trust, company, individual) is critical for tailoring due diligence measures to the unique risks associated with each type​​.

Residence (Country):Tracking customer jurisdiction ensures risk assessments reflect geopolitical and regulatory changes, fulfilling FATF compliance expectations​​.

Role of Additional Fields in Compliance:

These fields enhance traceability, accountability, and risk profiling, ensuring the CRA process is comprehensive and meets regulatory standards.

Advanced CAMS-Audit Guidance:

Documentation must be detailed and periodically reviewed to address evolving AML risks effectively, as recommended by CAMS-Audit guidelines​​.

Jurisdictional risk is critical in correspondent banking due to potential exposure to countries with weaker AML/CFT controls, high corruption levels, or sanctions.

Correspondent banking relationships with banks in high-risk jurisdictions are a key risk indicator, as these relationships often pose greater AML/CFT risks due to regulatory or operational deficiencies in those jurisdictions​​​.

Testing Internal Controls:

C. Gap Analysis: Ensures policies are compliant with local regulations and address identified risks​​.

D. Sample Testing: Verifies that processes are effectively implemented in practice for both new and existing customers​​.

Customer Identification Program (CIP) Requirements:

Account opening procedures define the baseline for customer identification, aligning with FATF Recommendation 10 on CDD​​.

Reason for Overvaluation/Undervaluation:

This technique is often used in trade-based money laundering to transfer funds or value disguised as legitimate trade transactions.

Auditor's Responsibility:

Auditors must ensure such discrepancies are detected, escalated, and adequately addressed to prevent money laundering​​.

CAMS-Audit Insight:

Advanced CAMS-Audit emphasizes vigilance in trade finance as a high-risk area for money laundering activities​​.

First Steps for Sampling:

Reviewing onboarding policies ensures the sampling aligns with established risk criteria, improving the relevance and accuracy of the audit findings​​.

Regulatory Emphasis:

FATF guidance stresses aligning audit sampling with organizational risk assessments and onboarding standards​​.

Comparison Against Past Suspicious Activity Reported:

This evaluates whether the new thresholds are identifying similar or improved patterns of suspicious activity compared to prior thresholds.

Helps validate that the updated thresholds align with the institution's AML risk profile and regulatory expectations.

Above-the-Line and Below-the-Line Testing:

Above-the-line tests verify that alerts generated by the thresholds include expected suspicious transactions.

Below-the-line tests assess transactions below the threshold to ensure no significant suspicious activities are missed.

CAMS-Audit Reference:

Advanced CAMS-Audit frameworks emphasize the importance of both historical comparison and robust testing methodologies to validate transaction monitoring system updates​​.

Characteristics of Effective AML Program Testing:

Tailored:Custom-designed to address specific organizational risks.

Risk-Based:Prioritizes high-risk areas to ensure optimal resource allocation and compliance.

Alignment with CAMS-Audit and FATF Principles:

Both emphasize the importance of a risk-based approach to AML program evaluation to mitigate the most significant threats​​.

Role of Internal Audit:

Internal audit is tasked with evaluating and improving the effectiveness of governance, risk management, and control processes within the organization.

Periodic evaluations ensure that AML/CFT processes remain robust and effective against emerging risks.

Alignment with CAMS-Audit Guidance:

Advanced CAMS-Audit training highlights the need for internal audit to focus on process effectiveness rather than operational responsibilities, such as quality assurance or corrective actions​​.

B. Periodic Checks: Regular monitoring ensures that implemented rules align with updated specifications and are functioning as intended, reducing the risk of deviation from compliance standardsints Before Release**: Establishing validation checkpoints ensures that all releases comply with documented specifications, mitigating risks of errors in the risk rating model

AML Policy Expectations:

Staff training is a fundamental component of an effective AML program. FATF Recommendations and Basel Committee guidelines require AML policies to address staff training to ensure compliance with AML/CFT laws​

Factors for External Audit:

C. Purpose of the Review: Determines the scope and focus of the audit to align with regulatory or organizational objectives​​.

D. Type of Risk Assessment Needed: Tailors the audit methodology to the identified risks​​.

E. Users of the External Report: Ensures the audit addresses the needs of regulators, stakeholders, or management​​.

In follow-up strategies, the focus should be on ensuring accountability and tracking progress. Establishing a target completion date and regularly updating the status of remedial actions ensures timely and effective resolution of deficiencies.

CAMS-Audit emphasizes tracking timelines and milestones for corrective actions to align with regulatory expectations and internal compliance frameworks​​.

Reporting to the Head Office Board Committee:

Independent testing reports must be submitted to the highest governance body to ensure proper oversight and alignment with global AML/CFT policies.

This ensures that findings are addressed at the appropriate organizational level.

CAMS-Audit and FATF Guidelines:

Governance frameworks outlined in CAMS-Audit and FATF recommendations emphasize the importance of board-level oversight for critical compliance functions​​

Deficiency in Reporting Metrics:

AML compliance frameworks require metrics to track trends and unusual patterns in suspicious activity reports (SARs). A lack of such metrics is a deficiency that undermines monitoring and oversight​​.

Why This is the Appropriate Step:

Identifying and documenting deficiencies ensures accountability and facilitates corrective action, aligning with AML audit standards.

Answer:B. Improper identification and assessment of risk creates deficiencies resulting in an overall weakened AML compliance program.

Answer:A. Management took appropriate and timely action to address any violations and other deficiencies.

Incorporating Comprehensive Risk Factors

By including an assessment of channel, credit, and transaction risks, the client’s overall risk profile is accurately determined. This aligns with risk-based approaches emphasized by FATF and CAMS-Audit standards.

These risk factors provide a granular view of the client’s risk level, ensuring proper classification into Standard or Enhanced Due Diligence categories​​.

Regulatory Alignment

FATF Recommendations mandate that client risk assessments consider the products, services, and delivery channels used, as well as geographic and transactional risks​.

ConclusionImplementing composite AML and sanctions risk scores ensures the institution is compliant with regulatory standards and adequately mitigates risks associated with different client profiles.

Significance of Finding 4 in Scenario and Threshold Calibration:

Finding 4typically points to issues with the alignment of customer segmentation or risk profiling. Incorrect segmentation or categorization directly impacts the assignment of scenarios and thresholds, leading to clients being subjected to inappropriate monitoring settings​​.

For example, placing a low-risk client in a high-risk threshold group can cause unnecessary alerts, while the opposite scenario might miss genuine suspicious activities​​.

Other Options Evaluated:

Finding 2:May relate to broader systemic issues but does not specifically highlight misalignment with thresholds or scenarios.

Finding 5:Typically involves data accuracy concerns but does not directly result in the application of incorrect scenarios or thresholds.

Finding 7:Often pertains to gaps in coverage or monitoring rather than specific issues in the calibration of scenarios and thresholds.

Advanced CAMS-Audit Context:

Advanced CAMS-Audit emphasizes the importance of precise customer segmentation and scenario calibration to ensure transaction monitoring systems operate efficiently and effectively. Findings pointing to misalignments in these areas are critical indicators of potential weaknesses​​.

Regulatory Relevance:

FATF and Basel Committee standards require risk-based monitoring tailored to the risk profile of each customer. Misaligned thresholds violate this principle, potentially leading to regulatory scrutiny​​.

Conclusion:The correct answer isB. Finding 4, as it identifies the misalignment of scenarios and thresholds with customer risk profiles, which is a critical issue in ensuring effective AML monitoring systems.

Filing an SAR based on reasonable grounds for suspicion ensures compliance with AML obligations and demonstrates the effectiveness of the investigative process.

Understanding the Vertical Approach:

A vertical audit focuses on reviewing the entire process or function within a single area or department, such as testing KYC files for compliance and effectiveness in a specific customer group or business line.

Application in AML Examinations:

Vertical audits are particularly useful for examining KYC processes as they allow auditors to trace the end-to-end workflow, from customer onboarding to risk assessment and ongoing monitoring​​.

Alignment with Advanced CAMS-Audit Guidelines:

The vertical approach provides detailed insights into compliance gaps within the KYC function, helping auditors identify root causes and systemic issues, which is emphasized in CAMS-Audit training​​.

Payable through accounts allow foreign banks' customers direct access to the correspondent account, which can increase the risk of money laundering due to less direct oversight.

Identifying inherent risks linked to the bank’s products and services is critical to tailor the audit scope and address high-risk areas comprehensively​​.