Exam CAMS7 Topic 1 Question 269 Discussion

Actual exam question for ACAMS's CAMS7 exam
Question #: 269
Topic #: 1

A large international financial institution (FI) operates in both the United States and the European Union. A cross-border transaction involving a high-net-worth client with dual U.S. and French citizenship raises concerns due to a third-party intermediary in a high-risk jurisdiction.
Given that the transaction falls under the U.S. Bank Secrecy Act (BSA) and OFAC requirements, as well as the EU's 6th Anti-Money Laundering Directive (6AMLD) and European Banking Authority (EBA) regulations, what is the best approach for the compliance team to ensure compliance?

A. Follow EU regulations only, as the beneficiary is based in France B. Implement a dual-compliance approach satisfying both U.S. and EU AFC regulations C. Defer to the most stringent regulatory regime to streamline compliance D. Follow U.S. regulations only, as the transaction originates in the United States

Suggested Answer: B Vote an answer

For multinational financial institutions, regulatory expectations are clear: institutions must comply with all applicable laws and regulations in each jurisdiction where they operate or where a transaction has regulatory touchpoints.
In this case, the transaction is subject to both U.S. and EU AML/CFT frameworks, including BSA reporting obligations, OFAC sanctions screening, 6AMLD requirements, and EBA supervisory expectations.
Selecting only one regulatory regime would expose the institution to compliance failures and enforcement risk.
A dual-compliance approach ensures that reporting, sanctions screening, customer due diligence, and record- keeping obligations are met in both jurisdictions. This approach aligns with FATF principles on cross-border compliance and consolidated supervision.
Deferring to the "most stringent" regime is not sufficient, as different rules may apply to different aspects of the transaction. Therefore, simultaneous compliance is required.

by Oliver at Mar 08, 2026, 04:29 PM

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