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In the AFC (Anti-Financial Crime) Risk Management framework, what is the primary distinction between AFC and traditional AML?

AFC focuses only on cash transactions while AML covers all transactions

AFC is broader, covering AML, sanctions, fraud, and anti-bribery and corruption

AFC applies only to non-bank financial institutions

AFC replaces all prior AML obligations under the BSA

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Practice Pages

CAMS Practice200 questions CGSS Certified Global Sanctions Specialist Practice200 questions ACAMS Advanced CAMS — Audit Practice100 questions ACAMS Advanced CAMS — Financial Crimes Investigations Practice100 questions ACAMS Certified AML FinTech Compliance Associate (CAFCA) Practice100 questions ACAMS Certified Anti-Fraud Specialist (CAFS) Practice100 questions

CAMS Exam Guide 2026: FREE ACAMS Study Plan + Practice28 min read

2026 Statistics

Key Facts: CAMS-RM Exam

100-200 hrs

Typical Preparation Time

Advanced AFC scope; depends on prior experience

$2,500-$3,500

Program Cost

ACAMS (member discount applies)

4 + 1

Four Online Courses + Proctored Final

ACAMS (practice exam included)

2024 Rebrand

From Advanced CAMS-RM to Certified AFC Risk Manager

ACAMS (broader AFC scope)

CAMS required

Prerequisite

CAMS designation or substantial AFC experience

Scaled

Cut Score (Not Publicly Disclosed)

ACAMS

ACAMS rebranded the Advanced CAMS-Risk Management to Certified AFC Risk Manager in 2024 to reflect a broader AFC scope (AML, sanctions, fraud, ABC). The program is four online courses plus a proctored final exam (practice exam included), takes most candidates 100-200 hours of preparation, and costs approximately $2,500-3,500 with the ACAMS member discount. Pre-requisite is the CAMS designation or substantial AFC experience. ACAMS does not publish pass rates or scaled cut scores.

Sample CAMS-RM Practice Questions

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1In the AFC (Anti-Financial Crime) Risk Management framework, what is the primary distinction between AFC and traditional AML?

A.AFC focuses only on cash transactions while AML covers all transactions

B.AFC is broader, covering AML, sanctions, fraud, and anti-bribery and corruption

C.AFC applies only to non-bank financial institutions

D.AFC replaces all prior AML obligations under the BSA

Explanation: AFC (Anti-Financial Crime) is a broader umbrella concept that encompasses AML, sanctions compliance, fraud, and anti-bribery and corruption (ABC). The ACAMS rebrand of CAMS-Risk Management to Certified AFC Risk Manager reflects this broader risk lens that institutions are expected to apply across financial crime typologies, not just money laundering.

2Under the Three Lines of Defense model, which line owns and manages risk in the day-to-day business activities?

A.First line (business and operations)

B.Second line (compliance and risk)

C.Third line (internal audit)

D.Fourth line (external regulators)

Explanation: The first line of defense (business units and operations) owns and manages risks day-to-day. The second line (compliance and risk) sets policy and provides independent oversight. The third line (internal audit) provides independent assurance. There is no formal 'fourth line' — regulators are external supervisors, not part of the model.

3Which of the following best describes the role of the second line of defense in an AFC program?

A.Conducting independent audits of the AML program

B.Owning customer onboarding and transaction execution

C.Setting risk policy, providing oversight, and challenging the first line

D.Filing SARs directly with FinCEN on behalf of the business

Explanation: The second line (compliance, financial crime risk) is responsible for setting policy, framework standards, oversight, and independent challenge of first-line activities. It does not perform audit (third line) or own day-to-day risk (first line). SAR filing is typically operationalized by financial intelligence units that may sit in either the first or second line depending on operating model.

4The 5th BSA pillar, added by the 2018 FinCEN CDD Final Rule, requires institutions to:

A.File CTRs for all cash transactions over $5,000

B.Maintain risk-based CDD procedures including beneficial ownership identification

C.Conduct independent testing every six months

D.Designate a separate sanctions compliance officer

Explanation: The CDD Final Rule (effective May 11, 2018) added a fifth BSA pillar requiring covered institutions to maintain risk-based customer due diligence procedures, including identifying and verifying beneficial owners (25% equity prong and one control prong) of legal entity customers. The original four pillars are internal controls, BSA officer, training, and independent testing.

5What is the key role of the Board of Directors in an AFC risk management program?

A.Reviewing every SAR before filing

B.Approving the AFC risk appetite, framework, and receiving periodic reports

C.Conducting transaction monitoring alert reviews

D.Managing OFAC screening false positives

Explanation: The Board's primary AFC governance responsibilities are approving the institution's AFC risk appetite and framework, ensuring adequate resourcing, and receiving periodic reports on the program's effectiveness, key risks, and material issues. Operational tasks (alert review, SAR filing, screening) sit with the first and second lines, not the Board.

6Which document typically codifies the Board-approved tolerance for residual financial crime risk?

A.The institution's AFC Risk Appetite Statement

B.The annual SAR narrative

C.The OFAC Sectoral Sanctions Identification list

D.The FinCEN Form 111

Explanation: The Risk Appetite Statement (RAS) is the formal Board-approved document expressing the level of residual AFC risk the institution is willing to accept in pursuit of its strategy. It is the cornerstone of governance and drives downstream policy thresholds, customer acceptance, and product approvals.

7Which of the following is a key governance principle when establishing the AFC compliance function?

A.The AFC officer should report to the head of the business they oversee

B.The AFC officer should have direct access to the Board and adequate independence

C.The AFC officer must hold a CPA license

D.The AFC officer must be a former regulator

Explanation: FFIEC, FATF, and the AML Act of 2020 emphasize that the BSA/AFC officer must have sufficient authority, independence from revenue-generating lines, and direct access to the Board (or a designated committee). Reporting to the business they oversee creates a conflict of interest and undermines the second line's independent challenge role.

8Under FFIEC guidance, the institution-wide AFC risk assessment should be refreshed:

A.Only when a new product is launched

B.At minimum every five years

C.Periodically, typically annually, and when material changes occur

D.Only after a regulatory examination

Explanation: FFIEC BSA/AML Examination Manual guidance is that the institution-wide AML/AFC risk assessment should be updated at least periodically — most institutions refresh annually — and on an event-driven basis when material changes occur (new products, M&A, geographic expansion, regulatory change). Five-year cycles are inadequate.

9Which of the following is the BEST description of the relationship between the institution's AFC risk appetite and product approvals?

A.Risk appetite is irrelevant to product approval decisions

B.Products that exceed defined risk appetite require enhanced controls or escalation/rejection

C.All new products automatically fall within risk appetite

D.Risk appetite only applies to existing products

Explanation: Risk appetite is operationalized through product, customer, and channel approval frameworks. New products that fall outside the Board-approved appetite must either be modified, supported by enhanced controls to bring residual risk within appetite, or escalated for Board exception/rejection. This is a common 2nd-line gating control.

10Which AFC governance committee typically reviews material AFC issues, emerging risks, and remediation status?

A.The Asset and Liability Committee (ALCO)

B.The Financial Crime / AFC Risk Committee

C.The Audit Committee on a daily basis

D.The Operational Resilience Committee

Explanation: Most institutions establish a dedicated Financial Crime or AFC Risk Committee (often a sub-committee of the Risk Committee) that reviews emerging risks, material issues, MRA/MRIA status, and significant remediation efforts. ALCO governs balance sheet risk; the Audit Committee meets less frequently and focuses on assurance.

About the CAMS-RM Exam

The ACAMS Certified AFC Risk Manager (formerly Advanced CAMS-RM) is an advanced specialist credential for AFC risk professionals. The program covers AFC framework and governance (3 lines of defense, BSA pillars, FFIEC), enterprise-wide risk assessment methodology (inherent vs residual, risk appetite, materiality), customer risk rating and EDD/SDD (CIP under PATRIOT Act §326, CDD Final Rule beneficial ownership 25%/control prong), product/geographic/channel risk (private banking, correspondent, trade finance, FATF high-risk, OFAC, PATRIOT Act §311, non-face-to-face), sanctions risk and screening (OFAC SDN, 50% rule, sectoral, fuzzy/phonetic matching, NYDFS Part 504), transaction monitoring (rule-based vs AI/ML, BTL/ATL tuning, SAR FinCEN Form 111 30-day filing), emerging risks (crypto VASPs, FATF Travel Rule, mixers, deepfake fraud, BEC, pig butchering, NFTs, DeFi), and validation/independent testing under SR 11-7 with Board risk reporting. Delivered via four online courses plus a proctored final exam.

Questions

100 scored questions

Time Limit

3-4 hours (proctored)

Passing Score

Scaled cut score by ACAMS

Exam Fee

~$2,500-3,500 (ACAMS member discount) (ACAMS)

CAMS-RM Exam Content Outline

15%

AFC Risk Management Framework & Governance

Three lines of defense, BSA five pillars (incl. 5th CDD pillar from 2018), FFIEC BSA/AML Examination Manual, AFC officer independence, Board governance, risk appetite statement, FATF risk-based approach, AML Act 2020 and FinCEN national priorities.

20%

Risk Assessment Methodology

Inherent vs residual risk, control effectiveness, risk appetite, materiality thresholds, EWRA dimensions (customers, products, geographies, channels), heat-map scoring, quantitative and qualitative inputs, jurisdictional overlay for global institutions.

15%

Customer Risk Rating & EDD/SDD

CIP under PATRIOT Act §326, CDD Final Rule (2018) beneficial ownership 25% equity prong + control person, foreign vs domestic PEPs and family/close associates (FATF R12), MSBs, charities, dynamic risk rating, EDD measures (source of wealth/funds, senior approval), Corporate Transparency Act status.

10%

Product, Geographic & Channel Risk

Private banking, correspondent banking (Wolfsberg CBDDQ, PATRIOT Act §312), trade finance and TBML, FATF high-risk and grey-list jurisdictions, OFAC sanctioned countries, PATRIOT Act §311 primary money laundering concern, face-to-face vs non-face-to-face / digital onboarding channel risk.

10%

Sanctions Risk Management & Screening

OFAC SDN list and 50% rule, sectoral sanctions (Russia Directives 1-4), EU/UK OFSI/UN list overlay, name screening (Levenshtein, phonetic, fuzzy), customer/transaction/list-update screening, NYDFS Part 504 annual certification, threshold tuning and false-positive ratio governance, blocked transaction reporting.

15%

Transaction Monitoring & Suspicious Activity Risk

Rule-based vs AI/ML scenarios, structuring/smurfing/layering red flags, BTL/ATL tuning, scenario yield concentration, KRIs (alert volume, conversion, aging), SAR FinCEN Form 111 (30 days from detection plus 30-day extension if suspect unknown), 90-day continuing-activity SAR cadence, tipping-off prohibition.

10%

Emerging Risks (Crypto, FinTech, TBML, Sanctions Evasion)

VASPs and FATF Recommendation 16 (Travel Rule), crypto mixers (Tornado Cash) and chain-hopping, DeFi controlling-party identification, NFT wash trading, AI/deepfake-enabled identity fraud, BEC, romance scams / pig butchering, ATM cash-out, TBML over/under-invoicing and phantom shipments.

Validation, Independent Testing & Risk Reporting

Independent testing annually under BSA, model risk management per SR 11-7 (conceptual soundness, ongoing monitoring, outcomes analysis), risk-based stratified sampling, look-back reviews (typically 12-24 months), Board AFC risk reporting (residual vs appetite, KRIs, MRAs/MRIAs/Consent Orders), AMLA effective and reasonably designed program standard.

How to Pass the CAMS-RM Exam

What You Need to Know

Passing score: Scaled cut score by ACAMS
Exam length: 100 questions
Time limit: 3-4 hours (proctored)
Exam fee: ~$2,500-3,500 (ACAMS member discount)

Keys to Passing

Complete 500+ practice questions
Score 80%+ consistently before scheduling
Focus on highest-weighted sections
Use our AI tutor for tough concepts

CAMS-RM Study Tips from Top Performers

1Master the distinction between AML and the broader AFC scope (AML + sanctions + fraud + anti-bribery & corruption) — the rebrand is conceptually significant for the exam

2Internalize the inherent → control effectiveness → residual risk methodology and how it links to Board-approved risk appetite and materiality thresholds

3Memorize the BSA five pillars including the 5th CDD pillar (2018), the CDD Final Rule's 25% equity + control prong beneficial ownership, and PATRIOT Act §§ 312 and 326

4Know OFAC sanctions specifics: SDN, the 50% rule, sectoral sanctions (Russia Directives 1-4), and blocked transaction reporting timelines

5Study SR 11-7 model risk management as it applies to TM and sanctions screening models — conceptual soundness, ongoing monitoring, and outcomes analysis

Frequently Asked Questions

What is the Certified AFC Risk Manager and how does it relate to the former Advanced CAMS-RM?

ACAMS rebranded Advanced CAMS-Risk Management to the Certified AFC Risk Manager in 2024 to reflect a broader Anti-Financial Crime scope covering AML, sanctions, fraud, and anti-bribery and corruption — not AML alone. The program structure is four online courses plus a proctored final exam (practice exam included). Content remains advanced and aimed at experienced AFC risk practitioners.

How is the CAMS-RM (Certified AFC Risk Manager) exam structured?

The credential is delivered as four online courses plus a proctored final exam, with a practice exam included in the package. Candidates typically allow 3-4 hours for the proctored final. ACAMS does not publicly disclose the exact question count or scaled cut score; programs of this type are commonly around 100 advanced multiple-choice and scenario items.

What does the CAMS-RM program cost?

The full program (courses plus exam) costs approximately $2,500-$3,500 depending on package and the ACAMS member discount. Active ACAMS membership is required. Verify current pricing on acams.org/en/certifications/afc-risk-manager.

What are the prerequisites for CAMS-RM?

Candidates should hold the CAMS designation or have substantial AFC risk management experience. The program assumes advanced familiarity with AML, sanctions, and risk-based methodology — it is not an entry-level credential.

How long should I study for CAMS-RM?

Most candidates plan 100-200 hours over 8-16 weeks, working through the four online courses, the practice exam, and additional reading on FFIEC, FATF, OFAC, SR 11-7, and current FinCEN advisories. Heavier reading is needed if the candidate's prior experience is concentrated in only one AFC sub-domain (e.g., AML but not sanctions).

What is the passing score for CAMS-RM?

ACAMS uses a scaled cut score for CAMS-RM and does not publicly disclose the percentage equivalent. The proctored final exam is graded on a pass/fail basis. There are no publicly published first-time pass rates.