Certified Transaction Monitoring Associate Free Sample Questions

Structuring (also known as smurfing) involves breaking down large amounts of cash into smaller deposits to avoid regulatory reporting thresholds (such as the $10,000 CTR limit in many jurisdictions). Consistently depositing amounts just below the threshold is a classic red flag for structuring.

The enterprise-wide risk assessment (EWRA) identifies the specific financial crime risks inherent to the institution's customers, products, and geographies. A risk-based TM program must map its scenarios and rules directly to the high-risk areas identified in the EWRA to demonstrate coverage aligned with risk appetite.

Behavior-based monitoring establishes a baseline of 'normal' activity for a customer (or peer group) and generates alerts when deviations from this baseline occur (e.g., a sudden spike in wire volume).

Because it looks for anomalies rather than specific known patterns, behavior-based monitoring is effective at catching new or evolving financial crime typologies that static rules might miss.

False. High false positive rates are common in TM systems and do not necessarily mean the system is broken. They often indicate a need for tuning thresholds or segmenting customers more effectively. Replacing the system is a last resort; optimization/tuning is the standard response.

Before taking drastic action like closing the account or filing a SAR, the investigator must determine if the partial match is a true positive. This involves gathering additional information (EDD) on the counterparty's address, ownership, and business activities to verify if it is indeed the sanctioned entity.

Non-productive alerts are those that provide no value to the investigation process, often caused by data errors, system glitches, or poor configuration (like flagging internal transfers). A 'false positive' usually refers to activity that correctly met the rule criteria but turned out to be benign after investigation.