CAMS Exam Dumps - Certified Anti-Money Laundering Specialist (CAMS7 the 7th edition)

A (Enhanced due diligence): EDD is a key control at onboarding for high-risk customers, involving deeper scrutiny, additional documentation, and approval layers to address increased ML/TF risk.

“High-risk customers must be subject to enhanced due diligence during onboarding to ensure a thorough understanding of potential ML/TF risks.”(CAMS 6th Edition, CDD/EDD for High-Risk Customers)

Cryptocurrencies and convertible virtual currencies present several well-documented money laundering and terrorist financing risks, as identified in FATF guidance and national AML frameworks. These risks largely stem from the pseudonymous nature, speed, and borderless design of virtual asset transactions.

One key risk is the ability to obscure the source of illicit funds. Criminals can move value through wallets and exchanges in ways that make tracing the origin of funds more difficult, particularly when using privacy-enhancing technologies or poorly regulated platforms.

Another significant risk is the facilitation of payments for illicit goods and activities, including drugs, cybercrime services, ransomware, and sanctions evasion. Virtual currencies can be used to settle transactions outside the traditional financial system.

Additionally, criminals frequently engage in layering transactions, rapidly transferring funds across multiple wallets, platforms, or blockchains to hide the origin of illicit proceeds.

Difficulty converting into physical currency is not a recognized AML risk, as most convertible virtual currencies can be exchanged through regulated platforms. Theft of funds is a cybersecurity concern but is not itself a core AML risk indicator.

Financial institutions should have a standardized process for terminating customer relationships, including conducting risk assessments and documenting the reasons for termination. A final review of the customer’s transaction history helps address any outstanding concerns or unresolved issues. Keeping thorough records of the termination process ensures compliance and provides documentation in case of any future inquiries or disputes.

Lawyers, accountants, and TCSPs are considered gatekeepers because they serve as an entry point to the financial system and act as a first line of defense in preventing illicit funds from being integrated into the legitimate economy through their services and professional expertise.

FATF Recommendation 29 states that an FIU should serve as a national center for the receipt and analysis of suspicious transaction reports and other information relevant to money laundering and terrorist financing.

“The FIU should serve as a national center for the receipt and analysis of suspicious transaction reports (STRs) and other information relevant to ML/TF, and for the dissemination of the results of that analysis.”

(CAMS 6th Edition, Role of the FIU; FATF Recommendation 29)

The documentation should include evidence that the residual risk remains within the bank’s risk appetite, analysis of resources spent and costs associated with the current lower threshold, and historical data showing the high false positive rate to justify altering the threshold while maintaining effective risk management.