Adverse media screening seeks to identify reputational or financial crime risk by:

B: Identifying links to criminal activity or sanctions.

C: Monitoring regulatory actions and updates for risk associations.

D: Regularly scanning news and public records for negative information.

“Adverse media screening involves collecting and reviewing publicly available information, news, and regulatory actions to detect links to criminal activity or reputational risks.”

(CAMS 6th Edition, Adverse Media Screening; FATF Guidance)

Incorrect:

A and E: Customer sentiment and credit scores are not core to adverse media screening.

Cryptoassets, such as cryptocurrencies, pose specific ML/TF risks due to their technological characteristics and usage patterns:

Potential for anonymity (C): Cryptoassets allow users to make transactions without revealing their true identities, which hinders law enforcement from tracking illicit activity. The CAMS 6th Edition states:“Cryptoassets can be transferred or exchanged between users without the need for identification, presenting a significant risk due to the potential for anonymity.”(CAMS 6th Edition, Chapter: Risks and Methods of Money Laundering and Terrorist Financing, Virtual Assets section)

Global reach (D): Cryptoassets operate on a global scale, enabling rapid cross-border transfers without the limitations of traditional financial systems. This increases the complexity of monitoring and controlling illicit transactions.“The global nature of virtual assets makes it easy for criminals to move value across borders quickly, evading jurisdictional controls.”(CAMS 6th Edition; FATF Guidance on Virtual Assets 2019)

Use to layer illicit funds (F): The ability to move cryptoassets between numerous wallets and exchanges allows criminals to obscure the source of funds through layering, a key stage of money laundering.“Layering can be achieved by rapidly moving cryptoassets between wallets, exchanges, and across different jurisdictions, making tracing more difficult.”(CAMS 6th Edition, Chapter: Risks and Methods of Money Laundering and Terrorist Financing)

A, C, D:

“Trust and asset management services can facilitate the concealment of the source of funds (A), provide a layer of anonymity to transactions (C), and obscure the true legal and beneficial owners (D). These are well-established ML/TF risks in the private wealth sector.”(CAMS 6th Edition, ML/TF Risks in Trust and Asset Management)

B and E are normal aspects of asset management and are not in themselves ML/TF risks unless combined with other suspicious behaviors.

Case notes should document who made the decision and the rationale for not filing the SAR to ensure transparency, support auditability, and demonstrate compliance with regulatory expectations.

A robust transaction monitoring system is a core component of an effective Anti-Money Laundering (AML) and Counter-Financial Crime (AFC) program. Regulatory guidance from FATF and national supervisors emphasizes that the primary purpose of transaction monitoring systems is to detect unusual or suspicious activity by analyzing customer transactions and identifying anomalies or patterns that may indicate money laundering, terrorist financing, or other financial crimes.

These systems use predefined rules, thresholds, and increasingly advanced analytics to monitor transactions in real time or retrospectively. Alerts generated by the system are reviewed by compliance professionals, who determine whether further investigation or reporting is required.

While transaction monitoring systems may support the preparation of regulatory reports , such as SARs or CTRs, the actual filing of these reports typically requires human review and approval and is not the defining capability of the monitoring system itself. Features such as automatic document translation or integration of social media profiles are not considered core or necessary functions under AML regulatory expectations.

Therefore, the essential capability of a robust transaction monitoring system is its ability to monitor transactions and detect anomalies indicative of suspicious activity .

B: If a bank fails to demonstrate sustained improvement or cannot resolve identified deficiencies, it can face civil or even criminal penalties from regulators. Regulators expect not just policy changes, but proof of effectiveness and ongoing compliance improvements.

C: Even after addressing many concerns, if all issues are not resolved—such as outstanding transaction monitoring backlogs—regulators may issue orders to further remediate the AML program until full compliance is achieved.

CAMS 6th Edition and regulatory guidance clarify that “regulators may impose penalties, issue consent orders, or require further remediation where weaknesses persist.”

Incorrect:

A: Secondary sanctions generally apply to sanctions violations, not standard AML program weaknesses.

D: Regulatory actions can be public and do pose reputational risk.

E: While transparency is sometimes required, this is not a universal regulatory response.

Before opening for business, a bank must have independent compliance testing to ensure controls are functioning, qualified staff who understand AML/CFT requirements, and documented policies and procedures to guide day-to-day compliance. These are foundational elements of an effective AML/CFT framework.

E-commerce business models are exposed to several financial crime risks that are clearly identified in Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) regulatory guidance, including publications from the Financial Action Task Force (FATF) and national supervisory authorities.

One key risk is the use of stolen bank card or payment data to purchase goods or services online. E-commerce platforms are particularly vulnerable to card-not-present fraud, where criminals exploit remote payment channels to generate illicit proceeds.

Another common risk is fraud against customers through non-delivery of goods or services . In these cases, fraudulent merchants accept payments without any intention of fulfilling orders. This form of consumer fraud is recognized as a predicate offense to money laundering under AML frameworks.

Additionally, online marketplaces may be abused to move or disguise criminally obtained funds . Criminals may conduct fake transactions, self-purchases, or repeatedly buy and resell goods to legitimize illicit funds. This activity aligns with recognized typologies such as transaction laundering and trade-based money laundering.

Although export control evasion and bribery and corruption are serious financial crimes, they are not typically considered common or inherent financial crime risks specific to standard e-commerce business models in AML/CFT guidance.