ACAMS Updated CAMS Exam Questions and Answers by mimi

An auditor who performs an AML investigation should adhere to the principle that AML and Data Protection Privacy laws should not be mutually exclusive. This means that the auditor should respect and protect the personal data of the individuals involved in the investigation, while also complying with the AML obligations and requirements. The auditor should balance the legitimate interests of preventing and detecting money laundering and terrorist financing with the fundamental rights and freedoms of the data subjects, and apply the data protection principles of lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, and confidentiality.

The auditor should also take into account the relevant legal frameworks and guidance on data protection and AML, such as the EU General Data Protection Regulation (GDPR), the EU Anti-Money Laundering Directive (AMLD), the Council of Europe Convention 108+ on data protection, and the Guidelines on data protection for the processing of personal data for AML/CFT purposes issued by the Consultative Committee of the Convention 108+. The auditor should also cooperate and consult with the data protection authorities and the AML authorities, as appropriate, to ensure compliance and consistency.

The customer’s relocation and expansion to different jurisdictions constitutes a triggering event that requires ongoing due diligence on this client, as it may indicate changes in the customer’srisk profile, business activities, or beneficial ownership. The bank should update the customer’s information, verify the identity and legitimacy of the new entities, and assess the level of money laundering and sanctions risks associated with the new locations12. The other options are not triggering events, as they are either consistent with the customer’s normal business operations or do not affect the customer’s risk profile.

Vendors and third-party relationships pose financial crime risks, particularly when theyoperate in sanctioned jurisdictions. Organizations must ensure thatthey are not directly or indirectly violating economic sanctionswhen engaging with vendors.

Option D (Correct):If a vendor provides services tosanctioned entities or individuals, an organizationrisks violating OFAC, EU, or UN sanctions laws, potentially leading tofines, legal action, or reputational damage. Engaging in business in asanctioned regionrequires strictdue diligence and licensing.

Option A (Incorrect):Thepersonal backgroundof an employee isnot relevantunless theycurrently have direct ties to a sanctioned jurisdiction or person.

Option B (Incorrect):Alack of majority ownershipdoes not automatically indicateAML risk; however, organizations should still assessownership structures for opacity.

Option C (Incorrect):Privately held companiescan betransparentif theydisclose ownership and operate within compliance standards.

Why This Matters:

Failing toscreen vendors for sanctions riskscan result insevere penalties, reputational harm, and regulatory scrutiny.OFAC (U.S.), EU, and UN sanctions prohibit business transactions with specific countries, entities, and individuals. Organizations mustconduct thorough due diligencetoidentify and mitigate sanctions risks.

TheWolfsberg Group’s Principles on Private Bankingfocus onrisk management, transparency, and financial crime prevention.

Option C (Correct):Thecore principleis that banks shouldonly accept clients whose source of funds and beneficial ownership are well understoodto mitigateAML risks.

Option A (Incorrect):Whilemanaging reputational riskis important, thepriority is AML compliance, not just protecting client privacy.

Option B (Incorrect):The Wolfsberg Group encouragesenhanced due diligence (EDD) for PEPsbut doesnot establish specific rulesfor private bankers.

Option D (Incorrect):The focus is onAML compliance, not assisting banks innavigating high data privacy jurisdictions.