CAMS-FCI Exam Topics Cover:

Knowledge of how the FCI program is set
up (e.g., governance structure) and how the
different elements (monitoring, investigation,
reporting, quality control, filing, escalations) of the program work together
Knowledge of how an institution determines/
categorizes its financial crime risk (e.g., types of
risk, national priorities, risk assessment, threat
assessment, risk appetite, products/channels/ customers/geo)
Knowledge of differences in risks and
corresponding processes of investigations
(e.g., client v. internal personnel or insider v.
law enforcement investigation of the financial
institution), determining who should participate
in different types of investigations
Ability to make risk-based decisions (e.g., how
tuning impacts risk, program feed, allocating
resources/time of investigators)
Ability to assess different relationship actions
(e.g., keep/exit client, hold transactions, freeze
account, monitor and prepare further SAR/STRs
update know your client (KYC) and customer
due diligence (CDD), change client risk rating)
and make effective argument for taking client
relationship actions in terms of risk to the
institution (e.g., client relationship decisions
have to go through financial institution (FI)
governance, so present the case to the Board or
risk committee to understand the risk the case presents)
Knowledge of the process and tools used in
customer profiling and transaction monitoring
process (e.g., processes like setting thresholds,
tuning, risk scoring of customers, integrating
systems, etc.; tools monitoring transactions,
screening customers, gathering adverse media tools, etc.)
Knowledge of what metrics are used to measure
risks and controls and ability to evaluate
what metrics are necessary to measure
effectiveness of financial crime investigations
program effectiveness, and how those should
be communicated to the Board or Senior
Management (e.g., metrics for board reporting).
Ability to identify gaps in the monitoring controls
that elevate risks (e.g., identifying a new pattern
of suspicious activity that is not flagged by the
monitoring system and suggesting new controls related to the pattern)
Ability to provide expert level recommendations
that help financial institutions determine
how to deal with particular clients, products,
services, and/or geographies to mitigate ML risk
(e.g., identifying and reporting trends in SARs indicating gaps in controls)
Ability to build investigative procedures, and
judge the quality of existing processes and
reports in light of policies, procedures, and
guidelines (e.g., review of process, quality control of process in retrospect)
Knowledge of legal context established by laws
and regulations in different jurisdictions and
for different regulated entities (e.g., laws and
regulations related to transaction monitoring)
Knowledge of boundaries of obligations
between FI, financial intelligence unit (FIU)
law enforcement, and regulatory examiners
(e.g., FI’s responsibility is to identify suspicious
activity and make decisions about customer;
FIU’s responsibility is to filter through the SARs
to pass to law enforcement; law enforcement’s
responsibility is to determine how to make a prosecuting case).
Knowledge of the kinds of law enforcement
requests made to financial institutions (e.g.,
getting information, warrants, freezing accounts, unexplained wealth orders, etc.)
Knowledge of how FIs address law enforcement
requests throughout the course of the
investigation (e.g., fulfilling requests while
maintaining client privacy, coordinating during
steps in law enforcement investigations)
Knowledge of private-public partnerships and
information sharing and how they work (e.g., 314
a and b in US, informal/formal partnerships, other countries)
Ability to adjust investigator training programs to
institutional specifics, roles, new financial crime
risks (e.g., new products, new risks, national
priorities, etc.), and identified knowledge and skill gaps
Knowledge of when criminal investigation
needs to be escalated because of sensitivity
(e.g., investigations into internal staff, politically
exposed persons (PEPs)) or complexity
Ability to craft relevant information-gathering
strategies from subject or client to support an
investigation (e.g., developing questions and
approach for relationship managers, conducting
probe without tipping off, submitting request for information (RFI))
Knowledge of privacy rules and regulations in
the given jurisdiction (e.g., sharing information
with legal entities within institution, external legal
entities, customers, or law enforcement)
Ability to retain comprehensive investigation files
to document and support investigative decisions
(e.g., notes on investigations into unusual activity,
enriching the KYC file on the customer to reflect
new understanding about client’s business,
decision making process about data points,
supporting documentation obtained, sources
used, and exception to the investigation process)
bility to identify what data and resources are
available for particular investigations (e.g.,
internal sources like KYC file, existing transaction
history, history in other parts of the business
/ other types of accounts; external sources
like ultimate beneficial owner (UBO) registers,
customer’s source of wealth / source of funds,
RFI process, customer contact [without tipping
off], customer’s business website, google earth,
staff visit to business premises, public/court
records, PEP public records, company ownership records, international holdings)
Ability to communicate effectively across
function and cultures (for cross-border
investigations) (e.g., how to access information
differentially across jurisdictions, knowledge
about different jurisdiction risks/reliability of
information, knowledge about protocols for
data gathering in jurisdictions, knowledge
how to match names/information in
different jurisdictions, knowledge of local
law enforcement and regulatory agencies,
knowledge of specialists in the locale, knowledge
of when to bring in specialists, knowledge of
jurisdictions with extra complexity, knowledge of
how jurisdictions regulate different recreational
activities (e.g. marijuana, gaming, adult industry))
Ability to evaluate and scope an investigation
plan using initial data and risk-based approach
(e.g., determine gaps in data, assess which data gaps are relevant)
Ability to assess the information to differentiate
between unusual, suspicious, and/or unknown
behavior, and identify the knowledge/
information gaps required to make a
determination (e.g., identify unusual transactions
and determine whether it should be considered
suspicious, following activity and relationships
within and across institutions)
Knowledge of how large databases are used to
distill patterns into clear and concise conclusions
Ability to use analytical software to provide data
and visualizations to understand investigation
(e.g., network analysis, complex company
structures, payment message analysis, wire
stripping, transaction monitoring, business account reviews, previous SARs)
Ability to assess reliability of information and
sources as part of the investigation process
(e.g., internal sources like KYC file, existing
transaction history, history in other parts of the
business / other types of accounts; external
sources like UBO registers, customer’s source of
wealth / source of funds, RFI process, customer
contact [without tipping off], customer’s
business website, google earth, staff visit to
business premises, public/court records, PEP
public records, company ownership records, international holdings)
Ability to search for additional or different
information that is beyond the standard
investigative sources to strengthen the
understanding and conclusion of the underlying
transaction activity (e.g., basic to complex opensource research,
working across siloes within an institution)
Ability to evaluate whether to continue or
conclude on an investigation (e.g., evaluate
decision in light of risk to institution, constraints to
continuing investigation, coming to a conclusion about the investigation)
Ability to see the possibility of more complex
or sophisticated financial crime scheme in a
pattern of transactions (e.g., receive alert and
gather data and can see possibilities of larger ML schemes)
Knowledge of the difference between a client related investigation, internal investigation of an
insider of the institution, and a law enforcement
investigation of the financial institution (e.g.,
sensitivities of different investigations, differences
in thresholds of evidence, differences in focus
(obligations to institution v. law enforcement requirements))
Knowledge of how high-risk, complex products
and services (correspondent banking, trusts,
private banking, wealth management, etc.) can
be used to launder illicit proceeds or exploited.
Knowledge of how high-risk customers/
businesses (e.g., gatekeepers, corporations with
complex structures, Designated Non-Financial
Businesses and Professions, Money Service
Businesses (MSBs), Trust Company Service
Providers, cash-intensive businesses) misuse
legal entities/persons to launder illicit proceeds or evade taxes.
Knowledge of bribery and corruption typologies
(e.g., layers of complex shell companies, PEPs, offshore accounts)
Knowledge of predicate crimes for money
laundering (e.g., terrorism, fraud, cyber-crime,
human trafficking, tax evasion, narcotics trafficking, corruption, etc.)
Knowledge of financing techniques for
proliferation, weapons of mass destruction
(WMD) (e.g., WMD supply chain; methods of
exploiting business for WMD; funding methods
for obtaining WMD materials / evading
sanctions; types of banking products, services,
geographics, or customer base exploited for proliferation financing)
Knowledge of terrorism financing through
FIs, MSBs, Virtual Asset Service Provider (e.g.,
financing methods terrorists use – crowd
funding, payment flows tied to digital assets;
basic understanding of terrorist ideologies and
corresponding methods of financing; techniques
to exploit non-governmental or non-profit
organizations to access funds and humanitarian efforts)
Knowledge of cyber-related financial crimes
(e.g., identifying red flags indicating preparation
for cyber heists, business email compromise,
identifying proceeds tied to Ransomware
payment, key sectors targeted for Ransomware,
tracing ransomware payments/interdiction of
virtual currency (mixers/tumblers), methods
used to rapidly move funds through cyber controlled accounts)
Knowledge of transnational criminal
organizations (TCOs) and transnational drug trafficking organizations (TDOs)
TCO/TDO, nexus between TCOs/TDOs and
other crimes, payment flows from Mexican
TDOs to Chinese citizens in US, payment flows
tied to fentanyl, major cartel financing methods,
narcotics routes in Europe, opiate routes from
Afghanistan through Iran, Turkey into Europe, etc.)
Knowledge of human trafficking typologies
Knowledge of environmental crime typologies (e.g., wildlife trafficking)
Knowledge of how criminals leverage online
marketplaces, social media, and gaming platforms to launder money
Knowledge of the SAR/STR process for law enforcement
Ability to determine what is necessary and
unnecessary to include in the narrative of a SAR/ STR
Ability to convey financial industry knowledge to
law enforcement in digestible way (e.g., simplify
complex data, describe what is normal and what
is unusual, describe bank products and their use)
Ability to clearly convey the bottom line of the
financial crime investigation in the SAR (e.g.,
reader should know what bank is uncomfortable with, what remains unknown)
Ability to differentiate facts from analysis
from judgment (e.g., facts as relevant, explicit
information, analysis as identifying connections
between data points, judgment as conclusions drawn from facts and analysis)
Ability to chronologically relate the financial
crime narrative from various perspectives (e.g.,
transactions, customer history, customer shared information)
Ability to communicate the meaning of complex data sets
Ability to evaluate and improve a SAR for its
quality of usefulness to law enforcement (e.g.,
review SARs to see whether they include the
appropriate approach and consideration)
Ability to apply different jurisdictional laws
and regulations to decision-making process
for SAR-filing (e.g., initial filing and repeat filing
(affirmative obligation to review after a certain amount of time)).
Ability to write standards for filling out SARs (e.g.,
guide for best practices in writing a SAR)