← CAMS guide
CAMS study flashcards
75 original cards on the fundamentals — first 15 free, full deck with a free account. Space flips, arrows move, K marks known.
Original study cards by FinCrime Desk — not actual exam content, not affiliated with ACAMS/ACFE.
0 of 75 marked known
No cards in this view — clear the topic filter or turn off “hide known”.
Printable deck
Checking your session…
Stages & methods
The three classic stages of money laundering
Placement, layering, integration. Placement introduces criminal proceeds into the financial system; layering obscures their origin through movement; integration returns them to the economy looking legitimate.
FinCrime Desk · CAMS deck
Stages & methods
Placement
The first stage: getting criminal proceeds — usually cash — into the financial system or into instruments. It is the stage at which launderers are most exposed, which is why cash-handling controls matter so much.
FinCrime Desk · CAMS deck
Stages & methods
Layering
Moving funds through transactions, accounts, entities or jurisdictions to break the audit trail between the money and its criminal source.
FinCrime Desk · CAMS deck
Stages & methods
Integration
Returning laundered funds to the legitimate economy in a form that appears to have a lawful origin — property, business revenue, investments, loans to oneself.
FinCrime Desk · CAMS deck
Stages & methods
Structuring
Deliberately breaking transactions into smaller amounts to stay below a reporting threshold. It is an offence in its own right in many jurisdictions, regardless of whether the underlying money is criminal.
FinCrime Desk · CAMS deck
Stages & methods
Smurfing
Structuring carried out by multiple people ("smurfs") making sub-threshold deposits across branches, institutions or days on behalf of one organiser.
FinCrime Desk · CAMS deck
Stages & methods
Trade-based money laundering (TBML)
Using trade transactions to move value: over- or under-invoicing, multiple invoicing, phantom shipments, or misdescribed goods. Value transfers even when the goods do not.
FinCrime Desk · CAMS deck
Stages & methods
Over-invoicing vs under-invoicing
Over-invoicing moves value to the exporter (buyer overpays for the goods); under-invoicing moves value to the importer (buyer underpays and receives excess value in goods).
FinCrime Desk · CAMS deck
Stages & methods
Hawala / informal value transfer system
A trust-based settlement network where value is transferred through brokers without funds crossing borders. Not inherently criminal, but the absence of a conventional audit trail creates laundering exposure.
FinCrime Desk · CAMS deck
Stages & methods
Commingling
Mixing criminal proceeds with legitimate revenue — classically through a cash-intensive business — so the illicit portion is hard to isolate.
FinCrime Desk · CAMS deck
Stages & methods
Terrorist financing vs money laundering
Laundering starts with criminal proceeds and seeks to disguise their origin. Terrorist financing can start with lawful funds and is defined by intended use; amounts are often small, which defeats value-based detection.
FinCrime Desk · CAMS deck
Stages & methods
Predicate offence
The underlying crime that generates the proceeds a launderer is trying to clean. Jurisdictions define which offences qualify; broad predicate lists widen the reach of laundering law.
FinCrime Desk · CAMS deck
Typologies & red flags
Why cash-intensive businesses are a laundering risk
Their legitimate revenue is hard to verify independently, so illicit cash can be declared as sales. Restaurants, car washes, parking and vending are recurring examples.
FinCrime Desk · CAMS deck
Typologies & red flags
Red flag: rapid movement through an account
Funds credited and withdrawn or transferred out almost immediately, leaving no balance. "Pass-through" or "funnel" behaviour suggests the account is a conduit, not a customer relationship.
FinCrime Desk · CAMS deck
Typologies & red flags
Funnel account
An account that receives deposits in many geographies and is drained in another, typically in short order — a common structure for moving proceeds across regions.
FinCrime Desk · CAMS deck
Typologies & red flags
Shell company
A legal entity with no meaningful operations or assets. Legitimate uses exist, but opacity of ownership makes shells a standard layering tool.
FinCrime Desk · CAMS deck
Typologies & red flags
Shelf company
A dormant entity incorporated and left "on the shelf" so it can later be sold with an aged registration date, lending false appearance of an established business.
FinCrime Desk · CAMS deck
Typologies & red flags
Correspondent banking risk
The correspondent serves the respondent's customers indirectly and cannot see them. Nested relationships — a respondent giving downstream banks access — compound the blind spot.
FinCrime Desk · CAMS deck
Typologies & red flags
Nested / downstream correspondent
A third-party institution using a respondent's correspondent account, often without the correspondent's knowledge, so the correspondent's controls never see who is actually transacting.
FinCrime Desk · CAMS deck
Typologies & red flags
Real-estate laundering red flags
All-cash purchases, prices far off market, rapid resale (flipping) at distorted values, purchases through opaque entities, and third parties paying with no clear relationship to the buyer.
FinCrime Desk · CAMS deck
Typologies & red flags
Casino / gaming red flags
Minimal play relative to chips bought, chip-walking, requests to cash out on another patron's behalf, and asking for winnings in a different form or currency than the funds came in.
FinCrime Desk · CAMS deck
Typologies & red flags
Securities-sector laundering red flags
Trading with no economic logic, matched or wash-style trades between related parties, journal transfers between unrelated accounts, and accounts used mainly to receive and remit funds rather than invest.
FinCrime Desk · CAMS deck
Typologies & red flags
MSB / money remitter risk
High volumes of small cross-border transfers, frequently non-face-to-face and cash-funded, make customer identification and pattern detection harder than in deposit banking.
FinCrime Desk · CAMS deck
Typologies & red flags
Virtual-asset red flags
Use of mixers or tumblers, chain-hopping across assets, transfers to or from high-risk exchanges with weak controls, and structuring transfers below an exchange's identification tier.
FinCrime Desk · CAMS deck
Typologies & red flags
Third-party / mule account indicators
Account activity inconsistent with a stated profile, another person controlling the account, sudden inbound transfers followed by cash withdrawal, and account holders unable to explain their own transactions.
FinCrime Desk · CAMS deck
AML programme pillars
The core pillars of an AML programme
Internal policies, procedures and controls; a designated compliance officer; ongoing training; independent testing — with risk-based customer due diligence added as the modern fifth element.
FinCrime Desk · CAMS deck
AML programme pillars
Role of the BSA/AML officer
A designated, empowered individual accountable for the programme: control design, escalation, reporting and board communication. Authority and resourcing matter as much as the title.
FinCrime Desk · CAMS deck
AML programme pillars
Independent testing
Periodic review of the AML programme by a party independent of the function tested — internal audit or an external firm — assessing design and operating effectiveness, not just documentation.
FinCrime Desk · CAMS deck
AML programme pillars
Risk-based approach
Allocating controls in proportion to assessed risk: heavier due diligence and monitoring where risk is higher, lighter where it is demonstrably lower. It must be documented to be defensible.
FinCrime Desk · CAMS deck
AML programme pillars
Enterprise-wide risk assessment (EWRA)
A documented assessment of inherent risk across products, customers, geographies and channels, the controls applied, and the residual risk that remains. It drives programme design.
FinCrime Desk · CAMS deck
AML programme pillars
Inherent vs residual risk
Inherent risk is exposure before controls; residual risk is what remains after controls operate. Programmes are judged on whether residual risk sits within stated appetite.
FinCrime Desk · CAMS deck
AML programme pillars
Three lines of defence
First line owns and manages risk in the business; second line (compliance, risk) sets policy and challenges; third line (internal audit) independently assures. Blurring the lines undermines all three.
FinCrime Desk · CAMS deck
AML programme pillars
Purpose of transaction monitoring
To detect activity inconsistent with expected customer behaviour or matching known typologies, generating alerts for human review — not to prove wrongdoing by itself.
FinCrime Desk · CAMS deck
AML programme pillars
Model tuning and threshold setting
Adjusting rule parameters using production data so alerts stay productive: below-the-line testing checks what a threshold is missing, above-the-line testing checks whether it is generating noise.
FinCrime Desk · CAMS deck
AML programme pillars
Recordkeeping's role in AML
Retained records let investigators and regulators reconstruct transactions and decisions after the fact. A decision without an audit trail is treated, in practice, as a decision not made.
FinCrime Desk · CAMS deck
AML programme pillars
AML training expectations
Training should be role-relevant and recurring: front-line staff need typologies and escalation routes, operations need process, the board needs enough to exercise oversight.
FinCrime Desk · CAMS deck
AML programme pillars
Culture of compliance
Tone from the top, no revenue override of control decisions, adequate resourcing, and escalation that is safe to use. Regulators read weak culture as the root cause behind most programme failures.
FinCrime Desk · CAMS deck
CDD, EDD & ownership
Customer due diligence (CDD)
Identifying and verifying the customer, understanding the nature and purpose of the relationship, identifying beneficial owners, and monitoring on a risk basis over the life of the relationship.
FinCrime Desk · CAMS deck
CDD, EDD & ownership
CIP vs CDD
The customer identification programme is the identity-collection-and-verification step at onboarding. CDD is the broader, ongoing understanding of who the customer is and what their activity should look like.
FinCrime Desk · CAMS deck
CDD, EDD & ownership
Enhanced due diligence (EDD)
Deeper measures for higher-risk relationships: source-of-wealth and source-of-funds enquiry, senior approval, adverse-media and ownership research, and more frequent review.
FinCrime Desk · CAMS deck
CDD, EDD & ownership
Source of funds vs source of wealth
Source of funds is where the money in this transaction or account came from. Source of wealth is how the customer's overall net worth was accumulated. High-risk cases need both.
FinCrime Desk · CAMS deck
CDD, EDD & ownership
Ultimate beneficial owner (UBO)
The natural person who ultimately owns or controls a customer or on whose behalf a transaction is conducted. Ownership chains must be traced to people, never stopped at another entity.
FinCrime Desk · CAMS deck
CDD, EDD & ownership
Control prong of beneficial ownership
Alongside ownership percentage, programmes identify an individual with significant responsibility for managing the entity, because control can exist without an ownership stake.
FinCrime Desk · CAMS deck
CDD, EDD & ownership
Politically exposed person (PEP)
Someone entrusted with a prominent public function, plus close associates and family. PEP status is not a prohibition — it is a risk factor that calls for enhanced scrutiny of source of wealth.
FinCrime Desk · CAMS deck
CDD, EDD & ownership
Why PEP status extends to associates
Because influence and proceeds of corruption are routinely held through relatives and close business associates rather than in the official's own name.
FinCrime Desk · CAMS deck
CDD, EDD & ownership
Know your customer's customer (KYCC)
Understanding the customers of an intermediary customer — payment processors, correspondents, trust and company service providers — where their activity flows through your institution.
FinCrime Desk · CAMS deck
CDD, EDD & ownership
Customer risk rating
A documented score combining customer type, product, geography and channel risk, which drives due-diligence depth, monitoring intensity and review frequency.
FinCrime Desk · CAMS deck
CDD, EDD & ownership
Trigger event review
Refreshing due diligence when something changes — ownership change, adverse media, new high-risk product, unexpected activity — rather than waiting for the scheduled periodic review.
FinCrime Desk · CAMS deck
CDD, EDD & ownership
Adverse media screening
Screening customers and connected parties against negative news for financial-crime relevance. Findings are risk information to assess, not automatic grounds for exit.
FinCrime Desk · CAMS deck
CDD, EDD & ownership
Onboarding red flag: reluctance to provide ownership detail
A customer who resists identifying beneficial owners, offers inconsistent structures, or supplies documents that do not reconcile is signalling opacity that CDD exists to resolve.
FinCrime Desk · CAMS deck
Sanctions basics
What economic sanctions are
Restrictions imposed by governments or supranational bodies limiting dealings with designated persons, entities, sectors or jurisdictions to achieve foreign-policy or security aims.
FinCrime Desk · CAMS deck
Sanctions basics
Comprehensive vs targeted sanctions
Comprehensive programmes restrict nearly all dealings with a jurisdiction; targeted ("smart") sanctions hit named persons, entities or sectors while leaving the wider economy accessible.
FinCrime Desk · CAMS deck
Sanctions basics
Asset freeze
A prohibition on dealing with a designated party's funds or economic resources. Frozen assets are immobilised, not confiscated, and dealing includes making funds available indirectly.
FinCrime Desk · CAMS deck
Sanctions basics
Strict liability in sanctions
Many sanctions regimes impose liability regardless of intent or knowledge. Good faith is relevant to penalty mitigation, not to whether a violation occurred.
FinCrime Desk · CAMS deck
Sanctions basics
Ownership-and-control principle
Restrictions extend to entities owned or controlled by designated parties even when the entity itself is not listed, which is why ownership analysis is part of sanctions screening.
FinCrime Desk · CAMS deck
Sanctions basics
Screening vs filtering
Customer screening checks parties against lists at onboarding and periodically; transaction filtering checks payment messages in real time against the same lists before release.
FinCrime Desk · CAMS deck
Sanctions basics
Fuzzy matching in screening
Approximate name matching to catch transliteration, spelling and word-order variants. Loosening it raises false positives; tightening it raises the risk of missed true matches.
FinCrime Desk · CAMS deck
Sanctions basics
False positive vs false negative
A false positive is a non-match flagged as a hit — costly but survivable. A false negative is a genuine match missed — the failure regulators penalise.
FinCrime Desk · CAMS deck
Sanctions basics
Stripping
Removing or altering identifying information in payment messages so a filter cannot detect a sanctioned party. It is treated as deliberate evasion, not a processing error.
FinCrime Desk · CAMS deck
Sanctions basics
Facilitation
Enabling a prohibited transaction by another party — approving, financing, referring or providing services — which can breach sanctions even where you never touch the funds.
FinCrime Desk · CAMS deck
Sanctions basics
General licence vs specific licence
A general licence authorises a defined class of otherwise prohibited activity for anyone meeting its conditions; a specific licence is granted to a named applicant for a named transaction.
FinCrime Desk · CAMS deck
Sanctions basics
Sanctions evasion indicators
Newly formed intermediaries in permissive jurisdictions, sudden re-routing of long-standing trade flows, opaque ownership changes just after a designation, and vague goods descriptions on dual-use items.
FinCrime Desk · CAMS deck
Investigations & bodies
Purpose of a suspicious activity report
To give authorities intelligence about activity that raises suspicion. The reporting institution is not required to prove a crime — suspicion, documented and reasoned, is the standard.
FinCrime Desk · CAMS deck
Investigations & bodies
Tipping off
Disclosing to a customer or third party that a suspicion report has been made or an investigation is under way. It is prohibited in most regimes because it defeats the intelligence.
FinCrime Desk · CAMS deck
Investigations & bodies
What makes a strong SAR narrative
Who, what, when, where, why suspicious and how the activity happened — written plainly, tied to the underlying records, and explaining the pattern rather than restating alert data.
FinCrime Desk · CAMS deck
Investigations & bodies
Alert vs case vs report
An alert is a system flag; a case is the human investigation that consolidates alerts and evidence; a report is the regulatory filing made when suspicion survives that investigation.
FinCrime Desk · CAMS deck
Investigations & bodies
Why a no-file decision must be documented
Closing without filing is a judgement examiners will test. The written rationale — what was reviewed and why the activity was explained — is the only defence available later.
FinCrime Desk · CAMS deck
Investigations & bodies
Link analysis
Mapping relationships between accounts, parties, devices, addresses and counterparties to reveal networks that individual transaction review would miss.
FinCrime Desk · CAMS deck
Investigations & bodies
Continuing activity review
Where suspicious behaviour persists after a filing, institutions revisit the relationship on a set cycle, filing continuing reports and deciding whether to exit.
FinCrime Desk · CAMS deck
Investigations & bodies
Financial intelligence unit (FIU)
The national body that receives, analyses and disseminates suspicious activity reports to law enforcement. It is the bridge between private-sector reporting and investigation.
FinCrime Desk · CAMS deck
Investigations & bodies
FATF
The Financial Action Task Force: the inter-governmental standard-setter for AML/CFT. It issues Recommendations, publishes typologies, and evaluates countries through mutual evaluations.
FinCrime Desk · CAMS deck
Investigations & bodies
FATF Recommendations
The international AML/CFT standard that countries implement in domestic law. They are not directly binding on institutions; national law is what binds.
FinCrime Desk · CAMS deck
Investigations & bodies
FATF mutual evaluation
A peer review of a country's compliance with the Recommendations, assessing both technical compliance and effectiveness of outcomes in practice.
FinCrime Desk · CAMS deck
Investigations & bodies
Egmont Group
The global network of financial intelligence units, providing a secure channel for FIU-to-FIU information exchange and shared operational practice.
FinCrime Desk · CAMS deck
Investigations & bodies
Wolfsberg Group
An association of international banks that publishes industry guidance and standard questionnaires — notably for correspondent banking due diligence.
FinCrime Desk · CAMS deck