ACAMS PREP-MOCK EXAM ACTUAL EXAM 2026 | ASSOCIATION OF CERTIFIED ANTI-MONEY
LAUNDERING SPECIALISTS EXAM | ALL QUESTIONS AND CORRECT ANSWERS | VERIFIED
ANSWERS | UPDATED VERSION
Question 1
Which of the following are three indicators of money laundering associated with electronic funds
transfers (EFTs)?
A) Transfers to secrecy havens, transfers between unrelated accounts, and constant small balance
maintenance
B) Funds transfers to/from secrecy havens without business reason, multiple accounts for the
same person, and payments with no link to legitimate contracts
C) Use of a single account for all business, large round-sum deposits, and frequent ATM
withdrawals
D) High volume of international transfers, low volume of domestic transfers, and use of credit
cards
E) Automated clearing house (ACH) transfers, use of debit cards, and local payroll deposits
Correct Answer: B) Funds transfers to/from secrecy havens without business reason,
multiple accounts for the same person, and payments with no link to legitimate contracts
Rationale: Electronic funds transfers are highly vulnerable to layering. Key red flags
include moving money to jurisdictions known for banking secrecy (havens) without an
underlying commercial logic, using different accounts to mask the trail of the same
individual, and payments that do not correlate with the movement of actual goods or
services.
Question 2
On whom does the ultimate responsibility for an institution's anti-money laundering (AML)
program rest?
A) The Anti-Money Laundering Officer
B) The Internal Audit Department
C) The Financial Intelligence Unit (FIU)
D) The Institution’s Board of Directors
E) The Front-line Tellers
Correct Answer: D) The Institution’s Board of Directors
Rationale: While the Compliance Officer manages the day-to-day operations of the
program, international standards (FATF) and local regulations (such as the USA PATRIOT
Act) dictate that the Board of Directors is ultimately responsible for ensuring the
institution has an effective, risk-based AML program and sufficient resources to maintain
it.
Question 3
Under federal law, how many years must a U.S. financial institution maintain records and
, 2
supporting documentation related to suspicious activity reporting?
A) 1 year
B) 3 years
C) 5 years
D) 7 years
E) 10 years
Correct Answer: C) 5 years
Rationale: Record-keeping is a fundamental pillar of AML. Most jurisdictions, including
the U.S. under the Bank Secrecy Act (BSA), require that records of transactions and SAR
filings be kept for a minimum of five years to allow law enforcement to reconstruct the
financial trail.
Question 4
When a business plan targets "Politically Exposed Persons" (PEPs), what is a mandatory step
according to Wolfsberg and FATF?
A) Immediately report all deposits to the police
B) Investigate the source of funds and seek senior management approval
C) Only allow the account to be opened in a foreign currency
D) Limit the account balance to less than $10,000
E) Deny all PEPs as a matter of institutional policy
Correct Answer: B) Investigate the source of funds and seek senior management approval
Rationale: PEPs pose a high risk of corruption and bribery. Enhanced Due Diligence (EDD)
is required, which includes verifying the source of wealth and funds, and requiring senior
management approval before establishing or continuing the relationship.
Question 5
Banking regulatory agencies in many jurisdictions have the authority to obtain information from
regulated institutions. Which statement is true?
A) Agencies always need a court-ordered warrant to see files
B) Regulatory examination authority negates the need for a warrant or subpoena
C) Agencies can only see files if the customer gives written permission
D) Regulators must notify the customer before looking at their account
E) Regulators can only view accounts involved in active criminal trials
Correct Answer: B) Regulatory examination authority negates the need for a warrant or
subpoena
Rationale: Financial institutions operate under licenses that grant regulators the right to
inspect books and records at any time. This "administrative" access is distinct from law
enforcement "investigative" access, which usually requires a subpoena.
Question 6
A customer appears ill-at-ease in the teller line and asks to cash a large cashier's check into $100
, 3
bills. What is the most appropriate next step?
A) Refuse the transaction and call the police immediately
B) Complete the transaction and then file a Suspicious Activity Report (SAR)
C) Complete the transaction and tell the customer you are filing a SAR
D) Ask the customer to wait while you call their employer
E) Ignore the behavior as long as the check is valid
Correct Answer: B) Complete the transaction and then file a Suspicious Activity Report
(SAR)
Rationale: Suspicious behavior (nervousness, unusual requests for cash) should be reported.
However, "tipping off" the customer that a report will be filed is a crime in many
jurisdictions. The institution should process the transaction and report it via the SAR
process afterward.
Question 7
What is the term for an individual generating offsetting profits and losses through multiple
accounts that do not appear to be commonly controlled?
A) Churning
B) Structuring
C) Wash Trading
D) Smurfing
E) Cuckoo Smurfing
Correct Answer: C) Wash Trading
Rationale: Wash trading in the securities sector involves an individual or group acting in
concert to buy and sell the same security to create the illusion of volume or to transfer
value between accounts while masking the beneficial owner.
Question 8
When performing an AML risk analysis, which four factors must a financial institution primarily
review?
A) Net profit, employee count, advertising budget, and stock price
B) Customer base, geographic location, products, and services
C) The amount of cash in the vault and the number of teller stations
D) The local crime rate and the proximity to a police station
E) The interest rates of competitors and the bank's own overhead
Correct Answer: B) Its customer base, location, products and services.
Rationale: A risk-based approach requires assessing who the customers are (PEPs, cash-
intensive businesses), where they are located (high-risk havens), and which products (wire
transfers, private banking) they use.
Question 9
How should a financial institution deter money laundering through new accounts?
, 4
A) Only open accounts for local residents
B) Document the identity, determine beneficial owners, and determine the source of funds
C) Require a $10,000 minimum deposit for all accounts
D) Photograph every customer who enters the bank
E) Check the customer’s credit score before opening the account
Correct Answer: B) Document the identity, determine beneficial owners, and determine the
source of funds
Rationale: "Know Your Customer" (KYC) standards require more than just a name.
Identifying the true beneficial owner (the person who ultimately controls the account) and
the source of funds is essential to prevent shell companies and proxies from being used.
Question 10
Which mechanism is used by Financial Intelligence Units (FIUs) to obtain information from
another country?
A) A public Google search
B) A direct request under the Egmont Group principles
C) A personal email to the bank manager overseas
D) A request through the World Bank
E) An advertisement in a local newspaper
Correct Answer: B) An FIU request under the EGMONT principles
Rationale: The Egmont Group is a global network of FIUs that provides a secure platform
for the exchange of financial intelligence. This cooperation allows FIUs to track money
across borders informally and rapidly.
Question 11
What is the primary function of the European Union Directives on Money Laundering?
A) To create a single European bank
B) To require members to implement laws to prevent money laundering
C) To eliminate the use of cash across Europe
D) To arrest money launderers directly
E) To provide insurance for all European bank accounts
Correct Answer: B) They require members to implement certain laws to prevent money
laundering.
Rationale: EU Directives provide a framework that member states must translate into their
own national legislation. They ensure a harmonized level of AML/CFT defense across the
European Union.
Question 12
If law enforcement asks a bank to keep a suspicious account open for an investigation, what
should the bank require?
A) A verbal promise from the officer
LAUNDERING SPECIALISTS EXAM | ALL QUESTIONS AND CORRECT ANSWERS | VERIFIED
ANSWERS | UPDATED VERSION
Question 1
Which of the following are three indicators of money laundering associated with electronic funds
transfers (EFTs)?
A) Transfers to secrecy havens, transfers between unrelated accounts, and constant small balance
maintenance
B) Funds transfers to/from secrecy havens without business reason, multiple accounts for the
same person, and payments with no link to legitimate contracts
C) Use of a single account for all business, large round-sum deposits, and frequent ATM
withdrawals
D) High volume of international transfers, low volume of domestic transfers, and use of credit
cards
E) Automated clearing house (ACH) transfers, use of debit cards, and local payroll deposits
Correct Answer: B) Funds transfers to/from secrecy havens without business reason,
multiple accounts for the same person, and payments with no link to legitimate contracts
Rationale: Electronic funds transfers are highly vulnerable to layering. Key red flags
include moving money to jurisdictions known for banking secrecy (havens) without an
underlying commercial logic, using different accounts to mask the trail of the same
individual, and payments that do not correlate with the movement of actual goods or
services.
Question 2
On whom does the ultimate responsibility for an institution's anti-money laundering (AML)
program rest?
A) The Anti-Money Laundering Officer
B) The Internal Audit Department
C) The Financial Intelligence Unit (FIU)
D) The Institution’s Board of Directors
E) The Front-line Tellers
Correct Answer: D) The Institution’s Board of Directors
Rationale: While the Compliance Officer manages the day-to-day operations of the
program, international standards (FATF) and local regulations (such as the USA PATRIOT
Act) dictate that the Board of Directors is ultimately responsible for ensuring the
institution has an effective, risk-based AML program and sufficient resources to maintain
it.
Question 3
Under federal law, how many years must a U.S. financial institution maintain records and
, 2
supporting documentation related to suspicious activity reporting?
A) 1 year
B) 3 years
C) 5 years
D) 7 years
E) 10 years
Correct Answer: C) 5 years
Rationale: Record-keeping is a fundamental pillar of AML. Most jurisdictions, including
the U.S. under the Bank Secrecy Act (BSA), require that records of transactions and SAR
filings be kept for a minimum of five years to allow law enforcement to reconstruct the
financial trail.
Question 4
When a business plan targets "Politically Exposed Persons" (PEPs), what is a mandatory step
according to Wolfsberg and FATF?
A) Immediately report all deposits to the police
B) Investigate the source of funds and seek senior management approval
C) Only allow the account to be opened in a foreign currency
D) Limit the account balance to less than $10,000
E) Deny all PEPs as a matter of institutional policy
Correct Answer: B) Investigate the source of funds and seek senior management approval
Rationale: PEPs pose a high risk of corruption and bribery. Enhanced Due Diligence (EDD)
is required, which includes verifying the source of wealth and funds, and requiring senior
management approval before establishing or continuing the relationship.
Question 5
Banking regulatory agencies in many jurisdictions have the authority to obtain information from
regulated institutions. Which statement is true?
A) Agencies always need a court-ordered warrant to see files
B) Regulatory examination authority negates the need for a warrant or subpoena
C) Agencies can only see files if the customer gives written permission
D) Regulators must notify the customer before looking at their account
E) Regulators can only view accounts involved in active criminal trials
Correct Answer: B) Regulatory examination authority negates the need for a warrant or
subpoena
Rationale: Financial institutions operate under licenses that grant regulators the right to
inspect books and records at any time. This "administrative" access is distinct from law
enforcement "investigative" access, which usually requires a subpoena.
Question 6
A customer appears ill-at-ease in the teller line and asks to cash a large cashier's check into $100
, 3
bills. What is the most appropriate next step?
A) Refuse the transaction and call the police immediately
B) Complete the transaction and then file a Suspicious Activity Report (SAR)
C) Complete the transaction and tell the customer you are filing a SAR
D) Ask the customer to wait while you call their employer
E) Ignore the behavior as long as the check is valid
Correct Answer: B) Complete the transaction and then file a Suspicious Activity Report
(SAR)
Rationale: Suspicious behavior (nervousness, unusual requests for cash) should be reported.
However, "tipping off" the customer that a report will be filed is a crime in many
jurisdictions. The institution should process the transaction and report it via the SAR
process afterward.
Question 7
What is the term for an individual generating offsetting profits and losses through multiple
accounts that do not appear to be commonly controlled?
A) Churning
B) Structuring
C) Wash Trading
D) Smurfing
E) Cuckoo Smurfing
Correct Answer: C) Wash Trading
Rationale: Wash trading in the securities sector involves an individual or group acting in
concert to buy and sell the same security to create the illusion of volume or to transfer
value between accounts while masking the beneficial owner.
Question 8
When performing an AML risk analysis, which four factors must a financial institution primarily
review?
A) Net profit, employee count, advertising budget, and stock price
B) Customer base, geographic location, products, and services
C) The amount of cash in the vault and the number of teller stations
D) The local crime rate and the proximity to a police station
E) The interest rates of competitors and the bank's own overhead
Correct Answer: B) Its customer base, location, products and services.
Rationale: A risk-based approach requires assessing who the customers are (PEPs, cash-
intensive businesses), where they are located (high-risk havens), and which products (wire
transfers, private banking) they use.
Question 9
How should a financial institution deter money laundering through new accounts?
, 4
A) Only open accounts for local residents
B) Document the identity, determine beneficial owners, and determine the source of funds
C) Require a $10,000 minimum deposit for all accounts
D) Photograph every customer who enters the bank
E) Check the customer’s credit score before opening the account
Correct Answer: B) Document the identity, determine beneficial owners, and determine the
source of funds
Rationale: "Know Your Customer" (KYC) standards require more than just a name.
Identifying the true beneficial owner (the person who ultimately controls the account) and
the source of funds is essential to prevent shell companies and proxies from being used.
Question 10
Which mechanism is used by Financial Intelligence Units (FIUs) to obtain information from
another country?
A) A public Google search
B) A direct request under the Egmont Group principles
C) A personal email to the bank manager overseas
D) A request through the World Bank
E) An advertisement in a local newspaper
Correct Answer: B) An FIU request under the EGMONT principles
Rationale: The Egmont Group is a global network of FIUs that provides a secure platform
for the exchange of financial intelligence. This cooperation allows FIUs to track money
across borders informally and rapidly.
Question 11
What is the primary function of the European Union Directives on Money Laundering?
A) To create a single European bank
B) To require members to implement laws to prevent money laundering
C) To eliminate the use of cash across Europe
D) To arrest money launderers directly
E) To provide insurance for all European bank accounts
Correct Answer: B) They require members to implement certain laws to prevent money
laundering.
Rationale: EU Directives provide a framework that member states must translate into their
own national legislation. They ensure a harmonized level of AML/CFT defense across the
European Union.
Question 12
If law enforcement asks a bank to keep a suspicious account open for an investigation, what
should the bank require?
A) A verbal promise from the officer
