ACAMS CKYCA Exam (page: 1)
ACAMS Certified Know Your Customer Associate
Updated on: 11-Dec-2025

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A legal entity applies to open an account in a financial institution. The owners of the entity are 20 individuals with equal shareholding.
Who should be identified as the Ultimate Beneficial Owner (UBO), per Financial Action Task Force (FATF) guidelines?

  1. Any six shareholders whose collective shareholding exceeds 25%
  2. All 20 shareholders, because none exceeds the 25% threshold
  3. No one; this is an orphan legal entity because it has no UBOs
  4. The person(s) exercising control and/or acting as a senior management official(s)

Answer(s): D

Explanation:

FATF guidelines require identifying UBOs as individuals owning more than 25% or, if no one meets that threshold, those who exercise control through other means. In this case, no shareholder owns more than 25%, so the UBO is identified based on control, typically the person(s) in senior management.



Assets under management show an increase of investors whose income originates from high-risk jurisdictions. This indicates higher risk in which area?

  1. Customer
  2. Geographical
  3. Political
  4. Economic

Answer(s): B

Explanation:

FATF considers jurisdictions with weak AML/CFT controls as high-risk. An increase in investors from such regions raises geographical risk, since the customers' funds originate from locations with elevated money laundering or terrorism financing threats.



During a routine CDD update in a financial institution, a junior member of the compliance department identifies that the spouse of the reviewed client was elected as a member of government.
Which action should the junior member take?

  1. Inform the relationship manager about the election of the client's spouse
  2. Make a note on the client's account of this fact and continue operations as usual.
  3. File a suspicious transaction report because the client did not notify the financial institution.
  4. Update the client's information to reflect that the client is related to a politically exposed person.

Answer(s): D

Explanation:

FATF guidelines require enhanced due diligence when a client becomes a Politically Exposed Person (PEP) or is related to one. Since the client's spouse is now a government member, the client must be classified as related to a PEP, and the institution's records must be updated accordingly.



A KYC analyst is onboarding a high-net-worth client and, during the screening process, notices that the prospective client is the parent of a government minister. After the analyst performs a source of wealth analysis, whose approval is needed before opening the account?

  1. Relationship management
  2. Senior management
  3. Team management
  4. Project management

Answer(s): B

Explanation:

FATF requires that the decision to establish or continue a business relationship with a Politically Exposed Person (PEP), or their close family members, must be approved by senior management after appropriate enhanced due diligence has been completed.



A politically exposed person (PEP) is eager to open a private account with an international bank. In addition to performing the normal CDD, which measure should be required from the AML officer?

  1. Conduct enhanced ongoing monitoring of the business relationship each quarter.
  2. Obtain senior management approval for establishing such business relationships.
  3. Contact law enforcement, as PEPs pose enhanced risks to an institution.
  4. Make a note of a PEP business relationship and file a suspicious transaction report to the local financial intelligence unit.

Answer(s): B

Explanation:

FATF requires that before establishing a business relationship with a PEP, financial institutions must obtain senior management approval, along with applying enhanced due diligence measures such as verifying the source of wealth and funds.



Which factor would be a reason for concern when corroborating the source of wealth of an individual client?

  1. The client amends their narrative as they are unable to provide supplementary information.
  2. The client is unable to provide bank statements relating to a redundancy pay-out 15 years ago.
  3. The client has no online presence, despite significant wealth.
  4. The client's online career profile does not mention their significant property investments.

Answer(s): A

Explanation:

Inconsistent or changing explanations from a client when asked for supplementary information about their wealth can indicate potential misrepresentation or concealment, making it a key red flag during source of wealth verification.



In automated screening, a "false positive" match is a match which:

  1. after review is found to be incorrect.
  2. during review is incorrectly dismissed as being a hit.
  3. is generated by the screening tool and confirmed to be a hit.
  4. was not flagged by the screening tool.

Answer(s): A

Explanation:

In automated screening, a "false positive" occurs when the system flags a potential match to a sanctions list, PEP list, or adverse media, but upon manual review it is determined that the match is incorrect.



An owner of several trading companies worldwide is advised to register a new company for the legitimate purpose of controlling foreign assets of their trading companies. This new company is commonly referred to as a:

  1. subsidiary company.
  2. special purpose vehicle.
  3. shell company.
  4. holding company.

Answer(s): A

Explanation:

A holding company is established to own and control shares or assets of other companies, often for organizational, tax, or asset protection purposes, without engaging directly in the day-to-day operations of those businesses.



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