How to Pass the CISI Combating Financial Crime Exam

Combating Financial Crime is a standalone CISI Level 3 Award for people whose job is to spot, stop or report criminal money. The same paper doubles as a technical unit of the Investment Operations Certificate and as an optional unit of the Level 6 Diploma in Investment Compliance, which is why candidates arrive at it from three quite different directions. Unlike the broader compliance papers, this one does not divide its attention: all fifty questions are about financial crime, and the level of detail rises accordingly.

The exam is 50 multiple-choice questions in 60 minutes, with a 70% pass mark, which means 35 correct answers. It is computer based, with no negative marking, so answer every question, and up to 10% of the paper can be additional trial questions that are not scored, though you will not know which ones. Sixty minutes for fifty questions is about seventy seconds each, which is the tightest ratio of any paper in the catalogue apart from the Introduction.

Candidates typically come from compliance and financial crime teams, operations, onboarding and client due diligence functions, internal audit, and increasingly from front-office roles where firms now expect a working knowledge of the reporting obligations. It is also a sensible first regulatory paper for someone who wants a recognised qualification without committing to a hundred-hour syllabus.

Know the weightings before you revise

Fifty questions across eight elements produces the most uneven split of any paper we cover, and the shape of it is not what most candidates assume.

Financial Crime Risk Management is 13 of the 50 marks, more than a quarter of the paper in a single element, and it is the last chapter of the workbook. Money Laundering and Bribery and Corruption are eight each. At the other end, Terrorist Financing and Economic Sanctions are three marks apiece and Fraud and Market Abuse and Tax Evasion are four. That tail is easy to dismiss and adds up to 14 marks, 28% of the paper.

What each element tests

The Background and Nature of Financial Crime (7 questions)

What financial crime is, the scale of it, and who polices it. The Financial Action Task Force and its Recommendations, the role of national regulators and law enforcement, and the difference between a criminal offence and a regulatory breach. It also covers why firms are targeted, the reputational and prudential cost of getting it wrong, and the idea of a risk-based approach that runs through the rest of the syllabus.

Money Laundering (8 questions)

Placement, layering and integration, and the ability to recognise which stage a described transaction belongs to rather than simply reciting the three. The predicate offences, the UK offences of concealing, arranging and acquiring, tipping off and failure to disclose, and the mechanics of a suspicious activity report. Typologies matter here: cash-intensive businesses, trade-based laundering, money mules, shell companies and beneficial ownership.

Terrorist Financing (3 questions)

Small, and different enough from money laundering to be worth a separate evening. Terrorist financing can start with legitimate money and small sums, which inverts most of the money laundering red flags, and the reporting obligations and offences sit under separate legislation.

Bribery and Corruption (8 questions)

The UK Bribery Act offences, including the corporate offence of failing to prevent bribery and the adequate procedures defence, plus facilitation payments, gifts and hospitality, and third-party and agent risk. The US Foreign Corrupt Practices Act is examined alongside it, and the differences between the two regimes are exactly the sort of distinction the paper likes to test.

Fraud and Market Abuse (4 questions)

The fraud offences, common typologies from authorised push payment fraud to identity theft and internal fraud, and the market abuse regime: insider dealing, unlawful disclosure and market manipulation, and the difference between the criminal offences and the civil regulatory regime.

Tax Evasion (4 questions)

Evasion against avoidance, the corporate criminal offences of failing to prevent the facilitation of tax evasion, and the international reporting frameworks: the Common Reporting Standard and FATCA. Four marks, and the evasion-versus-avoidance distinction is the one candidates most often get the wrong way round under time pressure.

Economic Sanctions (3 questions)

How sanctions regimes are made and enforced, the difference between targeted, sectoral and comprehensive sanctions, asset freezes, screening and false positives, and the consequences of a breach. Small, self-contained and quick to learn properly.

Financial Crime Risk Management (13 questions)

The heaviest element and the most operational. Customer due diligence and enhanced due diligence, politically exposed persons, the risk-based approach and risk assessment, ongoing monitoring, the role and responsibilities of the money laundering reporting officer, internal reporting, record keeping, staff training, and the governance around all of it. This is the element that decides most results on this paper.

Where people slip

The first and largest problem is running out of energy before the last chapter. Financial Crime Risk Management is a quarter of the paper and it sits at the end of the workbook, so a candidate who reads front to back and then starts practising questions has usually given it the least attention and the least sleep.

The second is treating the three stages of money laundering as a memory item. They are, until the question describes a transaction and asks which stage it represents or which type of firm is most exposed to it. Layering is the stage candidates under-prepare, because it looks most like ordinary client activity.

The third is assuming the bribery regimes are interchangeable. The UK Bribery Act and the US Foreign Corrupt Practices Act differ on facilitation payments in particular, and a question that names a jurisdiction is testing whether you noticed.

The fourth is the small elements. Terrorist Financing, Economic Sanctions, Fraud and Market Abuse and Tax Evasion are 14 marks between them on a 50-question paper. Each is small enough to learn properly in an evening, which makes skipping them an expensive way to save time.

The fifth is precision about who does what. The regulator, the National Crime Agency, the money laundering reporting officer and the individual member of staff all have distinct obligations, and questions are frequently built on swapping one for another.

How long it takes to prepare

CISI suggests around 50 hours of study for this paper, which is roughly half what the 100-question compliance and risk awards ask for and reflects the shorter syllabus rather than an easier one. For someone already working in a financial crime or onboarding role, 30 to 40 hours is realistic; for someone meeting the material for the first time, budget the full 50 and expect Financial Crime Risk Management to take the largest single share of it.

Spread those hours in something close to the weightings. Thirteen hours on the risk management element, eight each on money laundering and bribery, seven on the background chapter and an evening on each of the four small elements leaves you room for two full timed mocks at the end, which is where the format rehearsal happens.

How to revise it

Start at the end. Read Financial Crime Risk Management first, while you are fresh, and come back to it last as well; a quarter of the paper justifies two passes. Then work forward through the crime types, and treat the four small elements as a single evening each rather than as optional.

Build a one-page table of offences: what the offence is, which legislation it sits under, who can commit it, and what the defence is if there is one. Most of the marks on this paper turn on keeping regimes apart, and a table you have drilled beats a chapter you have read.

Then revise by being tested rather than by rereading. Seventy seconds a question is not long enough to reason from first principles, so the gap between recognising a term and knowing it cold shows up only under a clock. Finish with timed 50-question mocks weighted like the real paper, and use repeated results alongside your timetable and remaining weak areas when deciding whether to book. No mock score can predict an individual result.

Hunting for past papers? Read Combating Financial Crime past papers: what actually exists.