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Key Facts: CAFCA Exam

120

Practice Questions

OpenExamPrep CAFCA

90 minutes

Exam Time

ACAMS

70%

Passing Score

Of scored questions (ACAMS)

US$1,045

Exam Package

Private sector; membership extra

5 domains

Content Areas

ACAMS CAFCA Candidate Handbook

30-50 hrs

Recommended Study

4-6 weeks

CAFCA is ACAMS's associate-level FinTech AML credential. The exam has 60 multiple-choice questions (some unscored) in 90 minutes, at a Pearson VUE test centre or online. Candidates pass by answering 70% of scored questions correctly. The standard private-sector package costs US$1,045, and ACAMS membership is required. Five domains are tested: governance (20%), due diligence (20%), payment screening and monitoring (25%), investigations and reporting (20%), and scaling AFC strategies (15%).

Sample CAFCA Practice Questions

Try these sample questions to review concepts for the CAFCA exam. Each question includes a detailed explanation. Start the interactive quiz above for the full 120+ question experience with AI tutoring.

1A challenger bank like Chime, Revolut, or N26 typically operates without a physical branch network. Which AFC risk is MOST elevated by this digital-only model?
A.Cash-intensive structuring at teller windows
B.Speed of digital onboarding outpacing rigorous CDD
C.Physical robbery of branch vault assets
D.Inability to accept domestic ACH payments
Explanation: Neo-banks compete on near-instant onboarding (often under 10 minutes), which creates pressure to compress identification, verification, and risk-scoring steps. This 'speed vs. CDD' tension is the signature FinTech AFC risk.
2Under the Banking-as-a-Service (BaaS) model, who holds ultimate BSA/AML responsibility for monitoring transactions of a FinTech's end customers?
A.The FinTech program manager
B.The card network (Visa or Mastercard)
C.The chartered partner bank
D.Whichever entity collected the customer's PII
Explanation: In a BaaS arrangement, the chartered (sponsor) partner bank remains the regulated financial institution and bears ultimate BSA/AML responsibility, including SAR filing and CDD adequacy — even when day-to-day onboarding is performed by the FinTech.
3In 2024 the FDIC issued a consent order against a small partner bank (e.g., Lineage Bank, Choice Bank) for AML/BSA failures tied to its FinTech program. What was the PRIMARY supervisory finding?
A.The bank failed to monitor proprietary trading activity
B.The bank did not perform adequate oversight or CDD on FinTech partners' end customers
C.The bank charged FinTech partners excessive fees
D.The bank's website lacked TLS encryption
Explanation: FDIC and OCC enforcement against BaaS sponsor banks (Lineage, Cross River, Choice, Blue Ridge) has consistently focused on inadequate third-party risk management and missed CDD on the FinTech partners' end customers — failures rolled up to the chartered bank.
4A Buy Now Pay Later (BNPL) provider such as Klarna, Afterpay, or Affirm offers split-pay installments at point of sale. Which AFC risk is MOST distinctive to the BNPL model versus traditional credit cards?
A.Cash-back rewards programs
B.Synthetic identity fraud paired with quick-merchant cash-out abuse
C.Foreign-exchange conversion fees
D.Mortgage default risk
Explanation: BNPL onboarding is fast and lightweight, making it attractive for synthetic identity fraud and merchant-collusion abuse where stolen or fabricated identities take the goods or refunds before the lender catches up. Mule and synthetic ID risks are top BNPL AFC concerns.
5A payment processor (e.g., Stripe, Adyen, Square) acquires merchants and routes card transactions. Under FinCEN guidance, when does a payment processor itself become a Money Services Business (MSB)?
A.Whenever it accepts credit-card payments for merchants
B.When it accepts and transmits funds for persons other than its bank-affiliated merchants outside narrow exemptions
C.Only if it accepts cryptocurrency
D.Only when it operates internationally
Explanation: FinCEN's payment-processor exemption is narrow: a processor is generally not an MSB if it operates under bank-clearance arrangements, processes through clearing/settlement systems, only serves bona fide merchants, and uses formal agreements. Stepping outside those bounds (e.g., person-to-person transfers) makes it an MSB money transmitter.
6Embedded finance lets a non-financial brand (e.g., a ride-share app) offer banking through a BaaS partner. Which CDD risk is MOST elevated when the end-user opens an account inside a non-financial app?
A.The user may not realize they are opening a bank account, weakening informed consent and intent signals
B.The user automatically becomes a PEP
C.The user gains exemption from OFAC screening
D.The user's funds are not FDIC-insured at the partner bank
Explanation: In embedded-finance flows, the customer experience is branded by the non-financial app, so users frequently do not realize a bank account is being opened. This weakens KYC intent signals and complicates Reg E disclosures and CDD purpose-of-account assessments.
7Which is the BEST description of a digital wallet (e.g., Cash App, Venmo, Apple Cash)?
A.A virtual currency exchange
B.A stored-value or money-transmitter service holding funds and enabling P2P transfers
C.A securities broker-dealer
D.A correspondent bank
Explanation: Digital wallets like Cash App and Venmo function as stored-value / money-transmitter services. They are typically registered as MSBs with FinCEN and are state-licensed money transmitters; some have added crypto and stock features under separate registrations.
8A peer-to-peer lending FinTech (LendingClub, Prosper) connects retail investors and borrowers. Which AFC concern is MOST acute in this model?
A.Use of investor funds to launder borrower-supplied illicit money via early-payoff schemes
B.Excessive interest rate caps
C.Inability to file SARs
D.Mandatory cryptocurrency settlement
Explanation: P2P lending platforms can be abused via 'borrower as launderer' schemes — illicit funds are used to repay loans early, converting illicit cash into clean lender repayments. Detection requires monitoring early payoff patterns, source-of-funds anomalies, and circular flows.
9Which statement BEST captures why FinTech partner-bank ownership chains (the FinTech, its program manager, multiple BIN sponsors, and processors) raise AFC risk?
A.Multiple parties create regulatory ambiguity and gaps in CDD ownership
B.The chains improve KYC accuracy through redundancy
C.FinCEN exempts complex chains from BSA
D.Customers automatically become higher risk
Explanation: Layered FinTech-bank chains create ambiguity over who performs and owns CDD, monitoring, and SAR-filing — the very gaps regulators have been citing in BaaS enforcement. Each handoff is a potential control failure.
10A neo-bank advertises 'open an account in 90 seconds.' From an AFC perspective, what is the MOST important compensating control for such speed?
A.Eliminate CDD entirely
B.Layered, automated risk scoring and post-onboarding monitoring with rapid step-up review
C.Charge a higher monthly fee
D.Require customers to mail in paper documents
Explanation: Where onboarding is intentionally fast, the compliant approach is layered automated risk scoring (device, behavioral, document, sanctions, PEP, adverse media) plus aggressive post-onboarding monitoring and a rapid step-up to manual review when signals fire.

About the CAFCA Exam

The ACAMS Certified AML FinTech Compliance Associate (CAFCA) is an associate-level credential for anti-financial crime staff at FinTechs such as neobanks, payment processors, BNPL lenders, digital wallets, BaaS programmes and crypto platforms. ACAMS launched it with FINTRAIL in December 2020. The exam covers five domains: governance, guidance and regulation; due diligence across customer types; payment screening and transaction monitoring; investigations, inquiries and reporting; and scaling anti-financial crime strategies.

Exam sponsor: ACAMS. The requirements and fees below concern the certification or admission exam, separate from our free practice resources.

Questions

60 questions

Time Limit

90 minutes (Pearson VUE test centre or OnVUE online)

Passing Score

70% of scored questions

Exam / Certification Fees

US$1,045 package (private sector) plus required ACAMS membership

Exam sponsor website

Reported exam pass rate: Not publicly disclosed. ACAMS does not publish official pass rates Exam sponsor website

Fees, eligibility, and exam policies can change. Confirm them with the exam sponsor before applying or paying.

Our practice resources: topics covered

We aim to reflect publicly available exam outlines and topic information in our study resources. Coverage, format, and difficulty may differ from the actual exam, and we cannot guarantee that every detail is accurate or current. Confirm exam requirements, fees, and policies with the official exam sponsor.

20%

Governance, Guidance, and Regulation

FinTech types and vulnerabilities, financial crime types, licensing and sandboxes, risk management framework, data privacy, risk-based approach, sources of guidance, bank partner relationships, insider threat, and risk types

20%

Due Diligence Across Customer Types

CIP, KYC, eKYC, CDD and EDD; identity verification; data sources and their reliability; device data; sanctions, PEP and fraud screening at onboarding; customer risk ratings; onboarding fraud red flags

25%

Payment Screening and Transaction Monitoring

Purpose of monitoring, payment screening, red flags, payment methods including crypto, alert investigation, audit trails, transaction risk characteristics, monitoring systems and thresholds, and KPIs and OKRs

20%

Investigations, Inquiries, and Reporting

Customer communication and tipping off, evidence review, analytical bias, SARs and STRs, working with law enforcement, bank partners and regulators, law enforcement requests, and bank partner terms of service

15%

Scaling Anti-Financial Crime Strategies

New product and feature risk assessment, refreshing the risk assessment as the business grows, triggers for review, record retention and data storage, and outsourcing, RegTech and independent testing

Preparing for the CAFCA Exam

What You Need to Know

  • Passing score: 70% of scored questions
  • Exam length: 60 questions
  • Time limit: 90 minutes (Pearson VUE test centre or OnVUE online)
  • Exam / certification fees: US$1,045 package (private sector) plus required ACAMS membership Official sources

Using Our Practice Resources

  • Work through all 120 available questions
  • Review every answer and explanation
  • Track weak areas and revisit them
  • Use our AI tutor for tough concepts

CAFCA: Suggested Study Strategy

1Use the five official domains as your outline and give payment screening and transaction monitoring (25%) the most practice time
2Know the US SAR thresholds and deadlines: US$5,000 for banks with an identified suspect (US$25,000 without one), US$2,000 for MSBs, 30 days from initial detection, with the 60-day extension only in the bank rule
3Learn the difference between unusual and suspicious activity, and how to request information from a customer without tipping off
4Study the BaaS enforcement pattern: the FDIC orders against Lineage Bank and Choice Financial, and the Federal Reserve order against Evolve, all for weak oversight of FinTech partners
5Remember that outsourcing moves the task, not the responsibility, and that independent testing must be done by people independent of the controls

Frequently Asked Questions

What is the CAFCA credential?

CAFCA (Certified AML FinTech Compliance Associate) is an ACAMS associate-level credential for anti-financial crime staff at neobanks, payment processors, BNPL lenders, digital wallets, BaaS programmes and crypto platforms. It sits alongside the broader CAMS credential and the CTMA, CKYCA and CCAS credentials.

How is the CAFCA exam structured?

The exam has 60 multiple-choice questions, some unscored, in 90 minutes. It is delivered at Pearson VUE test centres or through OnVUE online proctoring. Candidates pass with at least 70% of scored questions correct, and there is no penalty for guessing. The standard package includes an 8-hour digital course and a practice exam.

How much does the CAFCA exam cost?

The standard private-sector CAFCA package costs US$1,045. ACAMS membership is also required (US$375 private sector or US$245 public sector). A retake costs US$199 after a 30-day wait. Recertification is free each year with active membership and 2 credits.

Who should take the CAFCA exam?

CAFCA is well-suited to AML and financial-crime compliance staff at neo-banks (Chime, Revolut, N26), payment processors (Stripe, Adyen, Square), BNPL lenders (Klarna, Afterpay, Affirm), digital wallets (Cash App, Venmo), embedded-finance and BaaS programs, and crypto exchanges and custodians (VASPs/CASPs). It is also useful for product, risk, audit, and engineering partners working closely with compliance.

How is CAFCA different from CAMS, CTMA, and CCAS?

CAMS is ACAMS's broad AML specialist credential. CTMA focuses on transaction monitoring, CKYCA on KYC, and CCAS on crypto-asset financial crime. CAFCA covers the FinTech business model end to end: governance and partner banks, onboarding due diligence, payment screening and monitoring, investigations and SARs, and scaling controls as the firm grows.

How should I prepare for the CAFCA exam?

Plan for about 30-50 hours over 4-6 weeks. Work through the five domains in order and spend the most time on payment screening and transaction monitoring (25%). Learn CIP and the CDD Rule, OFAC screening and the 50% Rule, SAR deadlines and thresholds, tipping-off limits, 314(a) and 314(b), and record-retention periods. Then use the 120 free practice questions and the ACAMS practice exam.