Controls, Investigations and the AFC Organization

High-risk scenario controls, employee and vendor due diligence, investigating and reporting suspicious activity, escalation, law enforcement requests, de-risking, customer communication, training and the structure of the financial crime function.

5 minutes 5 Questions

In the CAMS (Certified Anti-Money Laundering Specialist) framework, 'Controls, Investigations and the AFC Organization' describes how a financial institution operationalizes its anti-financial crime (AFC) program. Controls are the preventive and detective measures that mitigate money laundering, t…

Concepts covered
Responding to Subpoenas and Law Enforcement RequestsVendor and Third-Party Due DiligencePrivacy, Cybersecurity and Other Supporting FunctionsControls for Conflict Zones and Dual-Use GoodsTipping Off and Confidentiality of ReportsStructure and Roles of the Financial Crime TeamRed Flags from Staff Reports and External SourcesCustomer Offboarding Decisions and DocumentationControls for PEPs and Complex Ownership StructuresEU AML Regulation and COSMIC Information SharingEmployee Due Diligence and Insider ThreatsRequests for Information and Customer CommunicationEscalation Through the Governance StructureFront Office Roles in Detecting Financial CrimeWriting a Suspicious Activity ReportInvestigation Techniques and Information GatheringDe-Risking and Financial Inclusion Trade-OffsIdentifying Unusual and Suspicious ActivityAFC Training and Awareness ProgramsFinCEN 314(a) and 314(b) Information SharingControls for High-Risk Products and ChannelsInvestigation Timelines and Continuing Activity ReviewsDocumenting Investigations and the Decision to Report
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CAMS - Controls, Investigations and the AFC Organization Example Questions

Test your knowledge of Controls, Investigations and the AFC Organization

Question 1

Under a FinCEN section 314(a) request, what does a financial institution provide when its search of records identifies one of the named subjects?

Correct Answer: A match confirmation to FinCEN; records follow by subpoena

Under section 314(a), a financial institution that finds a match simply reports it to FinCEN through the secure system, confirming the subject's identity and the account or transaction involved. The requesting law enforcement agency must then use legal process, such as a subpoena, to obtain the underlying records.
Sending full account records directly is wrong because 314(a) does not authorize production of records without separate legal process. Filing a suspicious activity report is not required by a match, though the institution may file one independently if warranted. Sharing match notices with peer banks confuses 314(a) with voluntary 314(b) information sharing, and 314(a) requests are confidential.
Key concept: 314(a) government-to-institution information requests and their match-reporting limits.

Question 2

Some months after a suspicious activity report was filed, a financial crime investigator runs the continuing activity review on the same customer. The rapid pass-through transfers have persisted. A newly opened account held by the customer's relative now receives part of the funds. Which action BEST completes the review within the required timeline?

Correct Answer: Document both the persisting flows and the linked account, then refer the full period to the MLRO for a follow-up filing decision

A continuing activity review must capture everything that happened since the prior filing. The persisting pass-through transfers and the relative's newly linked account together make up the full picture, so both are documented and the whole review period goes to the MLRO for a timely follow-up filing decision.
Treating the persisting flows as covered by the prior report is wrong because ongoing activity needs its own follow-up filing. Opening a separate case with a fresh clock fragments the activity and delays action. Referring only the linked account leaves out the continuing transfers. Waiting for a KYC refresh misses the required filing timeline.
Key concept: continuing activity review and follow-up SAR filing.

Question 3

When the Monetary Authority of Singapore launched COSMIC for bank-to-bank sharing of customer risk information, which three financial crime risk areas did it initially prioritise?

Correct Answer: Misuse of legal persons, trade-based ML and proliferation financing

COSMIC (Collaborative Sharing of ML/TF Information and Cases), launched by MAS in 2024 with six major banks, initially focused on three priority risks: misuse of legal persons, trade-based money laundering and proliferation financing. These are areas where criminals exploit fragmented information across banks.
The answer naming money mule networks and terrorist financing swaps in two risks that were not COSMIC's initial priorities. The answer naming cross-border payment scams adds a fraud typology that was not in the initial scope and leaves out misuse of legal persons. The answer naming sanctions evasion replaces trade-based money laundering, which was one of the three priorities.
Key concept: Singapore's COSMIC platform and its initial priority risk areas for public-private and interbank information sharing.

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