An effective AML transaction monitoring system must align withthe bank's operational complexity, risk exposure, and analytical capabilities.
* Option A (Correct):The system must be tailored to the bank's specific risk profile to ensure effectiveness.
* Option D (Correct):A strong AML system should support trend analysis to identify long-term suspicious behaviors.
Why Other Options Are Incorrect:
* Option B (Incorrect):While vendor controls are important, they do not determine system suitability.
* Option C (Incorrect):User access settings should be based on the bank's internal risk framework, not industry standards alone.
Best Practices for Implementing an AML Monitoring System:
* Ensure scalability to adapt to evolving financial crime risks.
* Leverage AI and machine learning to enhance detection accuracy.
* Integrate real-time screening and transaction trend analysis.
Reference:
FATF Recommendation 10 (Customer Due Diligence & Monitoring)
Wolfsberg Group Guidance on AML Technology Implementation
Basel Committee's Guidelines on Transaction Monitoring System Effectiveness

Money laundering can have serious consequences for financial institutions. They may face increased investigation costs and fines from regulators and law enforcement agencies for failing to detect or prevent money laundering activities. Additionally, money laundering can result in a loss of profitable business as customers and counterparties may no longer want to do business with the institution due to its reputation for being associated with illicit activity.
Reference: Certified Anti-Money Laundering Specialist (CAMS) Study Guide, 6th Edition, page 76.

According to the Wolfsberg Principles on Correspondent Banking1, an institution should consider the following three elements in its enhanced due diligence process for higher risk respondent bank customers:
* The quality of the respondent's AML and client identification controls: The correspondent should assess the adequacy and effectiveness of the respondent's AML policies, procedures, and systems, as well as its compliance with applicable AML laws and regulations. The correspondent should also verify that the respondent has implemented appropriate customer identification and verification measures, and that it maintains sufficient records of its customers and transactions.
* A risk-based determination as to whether or not the respondent is a shell bank: The correspondent should ensure that the respondent is not a shell bank, which is defined as a bank that has no physical presence in any country and is not affiliated with a regulated financial group. The correspondent should also avoid establishing or maintaining relationships with banks that are known to allow their accounts to be used by shell banks.
* Whether a Politically Exposed Person (PEP) has an interest or management role in the respondent: The correspondent should identify and assess the potential risks associated with any PEPs who have an ownership or management interest in the respondent, or who are customers of the respondent. The correspondent should apply enhanced scrutiny and monitoring to such relationships, and obtain senior management approval before establishing or continuing them.
Wolfsberg Correspondent Banking Principles 2022 by the Wolfsberg Group, October 2022.
Reference:http://www.fatf-gafi.org/media/fatf/documents/reports/RBA%20Guidance%20for%20Real%
20Estate%20Agents.pdf(page
20, second paragraph)

The activities that could be considered a potential spear phishing scam are:
A courier delivers a duplicate invoice to a business that contains updated payment details of an existing supplier. This could be a way of diverting funds to a fraudulent account by impersonating a legitimate vendor and exploiting the trust relationship between the business and the supplier1.
Payroll receives an external email from an employee looking to update their bank account information. This could be a way of stealing money from the employee or the employer by pretending to be the employee and requesting a change in the payment method or destination2.
An employee receives an email that asks to download an attachment, but the attachment is a malware. This could be a way of infecting the employee's computer or network with malicious software that could compromise sensitive data, disrupt operations, or demand ransom3.
The other options are not necessarily spear phishing scams, although they may be other types of fraud or deception. For example:
An employee receives a phone call requesting that money be sent to assist someone in trouble. This could be a vishing scam, which is a form of voice phishing that uses phone calls to solicit personal or financial information or to request money transfers4.
A business sends its employees an email warning that email passwords must be changed to prevent cyber- fraud. This could be a legitimate security measure, or it could be a phishing scam, which is a form of email phishing that targets a broad audience and tries to trick them into revealing their credentials or clicking on malicious links.
Members of a religious organization receive a donation request by email claiming to be from their leader. This could be a genuine appeal, or it could be a social engineering scam, which is a form of manipulation that exploits the human factor and relies on the victim's emotions, trust, or sympathy.
References:
ACAMS CAMS Certification Video Training Course - Exam-Labs3
Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)4 ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 3, page 53: https://www.acams.
org/wp-content/uploads/2019/08/ACAMS-Study-Guide-6th-Edition-Chapter-3.pdf ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 3, page 54: https://www.acams.
org/wp-content/uploads/2019/08/ACAMS-Study-Guide-6th-Edition-Chapter-3.pdf ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 3, page 55: https://www.acams.
org/wp-content/uploads/2019/08/ACAMS-Study-Guide-6th-Edition-Chapter-3.pdf ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 3, page 56: https://www.acams.
org/wp-content/uploads/2019/08/ACAMS-Study-Guide-6th-Edition-Chapter-3.pdf

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.
Reference:
OFAC Sanctions Guidelines & Compliance Framework
EU Sanctions Regulations
FATF Recommendation 6 (Targeted Financial Sanctions Related to Terrorism & Proliferation)