CAMS-RM study plan
CAMS-RM · Give each week a clear focus.
8 weeks · About 7 hours per week
AML/CFT Risk Management Fundamentals and Governance
Map the four pillars of an AML/CFT program (policies and procedures, designated compliance officer, training, independent testing) to the exam's governance objectives and write a one-page outline for each
Distinguish the roles of the board, senior management, the MLRO/compliance officer, and the first and second lines of defense, and draft a RACI matrix showing who owns each AML decision
Explain the risk-based approach in your own words, including how customer, product, channel, geographic, and delivery-channel factors combine into an institutional risk assessment
Summarize the FATF Recommendations that anchor governance expectations (notably Recommendations 1, 18, and 26-27) and note how they translate into supervisory expectations
Draft a 10-question self-check on governance concepts and score yourself, logging every miss with the correct concept
Your checkpoint
A one-page governance map plus a completed 10-question self-quiz with a written correction note for each wrong answer
Risk Identification, Assessment and Risk Appetite
Build an institutional risk assessment from scratch for a hypothetical mid-sized bank, scoring each inherent risk category and justifying every score in one sentence
Differentiate inherent, residual, and control risk, and calculate residual risk for three sample scenarios by applying control effectiveness ratings
Draft a risk appetite statement with explicit quantitative thresholds (for example, tolerance limits on high-risk customers and on unresolved alerts) and qualitative statements
Distinguish risk assessment from risk appetite and explain how each feeds the other in a governance cycle
List the key risk indicators you would track monthly and state the trigger point for escalation for each
Your checkpoint
A completed institutional risk assessment with scored categories, a one-page risk appetite statement, and a table of at least eight key risk indicators with thresholds
Customer Due Diligence, Beneficial Ownership and Enhanced Due Diligence
Apply the four-step customer due diligence process (identification, verification, understanding purpose and intended nature, ongoing monitoring) to five customer profiles of varying risk
Trace beneficial ownership through a three-layer corporate structure and identify the ultimate beneficial owner using both the ownership-percentage and control tests
Select between simplified, standard, and enhanced due diligence for each of ten scenarios and justify the choice in two sentences
Identify red flags that require enhanced due diligence, including unusual source of funds, complex structures with no apparent commercial purpose, and reluctance to provide identification
Explain when a customer relationship must be declined or exited and how to document that decision
Your checkpoint
A case workbook covering ten customer scenarios, each with the CDD tier applied, the beneficial ownership conclusion, and a documented rationale
Transaction Monitoring, Screening and Detection Scenarios
Design a transaction monitoring rule set for a retail bank, specifying the scenario logic, data fields required, and threshold rationale for at least six rules
Distinguish rule-based, threshold-based, and behavior-based monitoring and explain the trade-offs in false positive rate and coverage
Walk through alert triage end to end: alert generation, initial review, escalation, investigation, and disposition, naming the decision criteria at each stage
Analyze five sample alert narratives and write a defensible disposition for each, including what additional information you would request
Explain the difference between transaction monitoring and name screening, and describe how sanctions and PEP screening fit into the detection workflow
Your checkpoint
A monitoring rule specification document with six rules plus five written alert dispositions with supporting rationale
Transaction Monitoring, Screening and Detection Scenarios & Sanctions, PEPs and Proliferation Financing Risk
Apply sanctions screening concepts to ten scenarios, deciding whether a potential match requires escalation and documenting the match-resolution logic
Distinguish targeted sanctions from comprehensive embargoes and explain how ownership-based (50 percent rule) and control-based designation extensions affect screening
Classify ten public figures as PEP, relative or close associate of a PEP, or not a PEP, using the definition of a politically exposed person and the source-of-wealth requirement
Explain proliferation financing risk, how it differs from terrorist financing, and which red flags (dual-use goods, trade-based discrepancies, front companies) signal it
Identify trade-based money laundering red flags in a set of invoice and shipping records and explain the discrepancy in each case
Your checkpoint
A screening and sanctions decision log covering ten scenarios with match outcomes, PEP classifications, and proliferation-financing red flag annotations
Reporting, Investigation and Escalation
Draft a suspicious activity report narrative for a constructed case that states who, what, when, where, why, and how, without conclusory language, in under 400 words
Explain the reporting timeline, confidentiality obligations, and prohibition on tipping off the customer, and describe the consequences of each violation
Distinguish internal escalation from external reporting and map the decision path from alert to filed report with the approval gate at each step
Describe how to handle a law enforcement inquiry or subpoena, including documentation, scope limitation, and escalation to legal
Evaluate three weak SAR narratives and rewrite each to meet a defensible standard
Your checkpoint
One polished SAR narrative plus a rewritten version of each of three weak sample narratives, with a short note on what was fixed
Risk Mitigation, Controls and Testing
Map the control environment across prevention, detection, and reporting layers and identify at least two controls per layer with the risk each mitigates
Design a testing plan for three key controls, specifying sample size logic, testing method, evidence to retain, and pass/fail criteria
Distinguish a control design deficiency from an operating effectiveness deficiency and write an issue with a remediation owner, action, and target date
Explain the independent audit or testing function's role and how testing results feed back into the institutional risk assessment
Draft a training program outline with audience tiers, frequency, content, and a method for measuring comprehension
Your checkpoint
A control testing plan for three controls plus one written issue with root cause, remediation plan, and owner
Data, Technology and Model Risk in AML & Emerging Risks and Typologies
Explain model risk in AML systems, including model validation, tuning, threshold calibration, and documentation of assumptions, and describe the consequences of an unvalidated model
Identify data quality risks in AML (incomplete customer records, fragmented sources, inconsistent screening lists) and describe controls that mitigate each
Summarize at least five emerging typologies, such as virtual assets and mixers, synthetic identity fraud, and misuse of fintech payment rails, with the red flag for each
Explain how new products, delivery channels, and technologies trigger a risk assessment update before launch
Complete a timed 60-question mixed-domain practice set and review every missed item against the source domain
Your checkpoint
A one-page emerging risk brief with five typologies and their red flags, plus a timed practice score with a written review log of every missed question
Milestones
Week 2: Can build an institutional risk assessment and write a risk appetite statement with quantitative thresholds without notes
Week 4: Scores at least 70 percent on a 40-question set drawn from domains 1 through 4, with every miss logged and corrected
Week 6: Writes a defensible SAR narrative in under 400 words and correctly classifies PEP and sanctions scenarios at 80 percent or better
Week 8: Scores at least 80 percent on a timed 60-question mixed-domain set and has a correction note for every missed item