最新の[2026年09月04日]ACAMS CAMS試験練習テスト最高成績で最速合格をゲットせよ！
これを使えば必ず合格させる問題集でACAMS CAMS
質問 # 242
When an institution receives a document request from law enforcement with regard to an STR that the institution has filed, what should institution do?
- A. It should request a written subpoena or court order before turning over any documents
- B. It should have its outside counsel review the request and the documents before doing anything
- C. It should turn over the documents that were previously collected to support the STR
- D. It should politely decline to provide the requested documents until the law enforcement agency can explain the nature and purpose of its inquiry
正解：C
解説：
According to the BSA/AML Manual1, one purpose of filing SARs is to identify violations or potential violations of law to the appropriate law enforcement authorities for criminal investigation. Therefore, when an institution receives a document request from law enforcement with regard to an STR that the institution has filed, it should cooperate and provide the documents that were previously collected to support the STR. This will help the law enforcement agency to conduct its investigation and follow up on the suspicious activity reported by the institution. The institution should also maintain the confidentiality of the STR and the document request, and avoid tipping off the customer or any other person involved in the suspicious activity.
References:
* BSA/AML Manual1
* Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations2
* Suspicious Transaction Report STR3
質問 # 243
After several months of research, the Director of Marketing and the Managing Director of Business Development received approval to launch a branded, stored-value card that will be marketed to the diverse, primarily non-resident population that comprises the bank's current customer demographics. The Chief Credit Officer and the Risk Officer have also been involved in the efforts to develop the card. After the card is launched, the anti-money laundering officer is consulted. The anti-money laundering officer should advise the bank that compliance should have been involved
- A. During product development to develop reports for the Board.
- B. After product development to confer with the legal department.
- C. During product development to perform a risk assessment of the product.
- D. After product development to perform an assessment of the product.
正解：C
解説：
The anti-money laundering officer should advise the bank that compliance should have been involved during product development to perform a risk assessment of the product. This is because stored-value cards are considered high-risk products for money laundering and terrorist financing, as they can be used to store, transfer, or access funds anonymously, across borders, or through third parties. A risk assessment would help the bank identify and mitigate the potential vulnerabilities and threats associated with the product, such as customer due diligence, transaction monitoring, record keeping, reporting, and training. A risk assessment would also help the bank comply with the regulatory requirements and expectations for offering such products, as well as the industry best practices and standards.
Reference:
ACAMS CAMS Certification Study Guide, 6th Edition, Chapter 5, Section 5.3.2, p. 140-1411 ACAMS CAMS Certification Exam Outline, 6th Edition, Domain 1, Task 1.1, p. 42 FATF Guidance on the Risk-Based Approach for Prepaid Cards, Mobile Payments and Internet-Based Payment Services, June 2013, p. 9-103
質問 # 244
Which is a key aspect in the FATF Recommendations that best describes the essential foundation for allocating resources in AML/CFT regimes for countries and financial institutions (FIs)?
- A. Applying a risk-based approach
- B. Implementing targeted financial sanctions
- C. Performing country peer-to-peer evaluations
- D. Enforcing mutual legal assistance
正解：A
解説：
Reference: https://www.fatf-gafi.org/media/fatf/documents/PF-Public-Consultation-Draft-Amendments.docx
質問 # 245
Suspicious activity triggered a suspicious transaction report filing on a company that holds an account at a large commercial bank. Investigations revealed that a member of the bank's Board of Directors is the major shareholder of the company. Further review revealed the bank had no reasonable explanation for the activity, but could not confirm if criminal activity occurred. Which of the following is the next best course of action for the compliance officer?
- A. Ask the Board member to explain the transaction.
- B. Maintain standard summary statistical reporting to the Board.
- C. Prevent the suspicious transaction report from government filing.
- D. Include a detailed presentation of this case in the Board report.
正解：D
解説：
The compliance officer should report the suspicious activity to the Board of Directors, as they are ultimately responsible for the bank's compliance program and oversight. The Board should be informed of the potential conflict of interest and reputational risk involved in the case, as well as the steps taken by the compliance officer to investigate and file the suspicious transaction report. The compliance officer should not prevent the filing of the report, as this would violate the legal obligations of the bank and expose it to regulatory sanctions and penalties. The compliance officer should not ask the Board member to explain the transaction, as this could compromise the integrity and independence of the investigation and the reporting process. The compliance officer should not maintain standard summary statistical reporting to the Board, as this would not adequately address the seriousness and complexity of the case.
Reference:
ACAMS CAMS Certification Study Guide, 6th Edition, Chapter 5, page 1271 ACAMS CAMS Certification Video Training Course, Module 5, Lesson 22 ACAMS CAMS Certification Exam Outline, Domain 5, Task 13
質問 # 246
A bank maintains a number of United States (U.S.) dollar correspondent accounts for foreign financial institutions. Upon a routine review of a U.S. dollar correspondent account owned by Foreign Bank A, a number of transactions appear to have been originated by Foreign Bank B outside the expected activity for this account. These transactions appear suspicious and a suspicious transaction report was filed by the compliance officer.
Which step should the compliance officer take?
- A. Notify Foreign Bank A of the discovery and seek documentation supporting Foreign Bank A was collusive and a willing partner with Foreign Bank B in the activity
- B. File a report with the appropriate tax authorities in the jurisdictions of Foreign Bank A and Foreign Bank B
- C. Notify other U.S. financial institutions who maintain U.S. dollar correspondent accounts for Foreign Bank A and Foreign Bank B in an effort to shut down the activity
- D. Notify senior management of the money laundering risks by allowing Foreign Bank A to maintain its
- E. S. dollar correspondent account
正解：A
解説：
According to the FFIEC BSA/AML Manual1, a U.S. bank should have policies, procedures, and processes to monitor and report suspicious activity associated with U.S. dollar drafts, which are bank drafts or checks denominated in U.S. dollars and made available at foreign financial institutions. These drafts are drawn on a
U.S. correspondent account by a foreign financial institution and can be used to facilitate money laundering or terrorist financing. The manual states that "[t]he potential for facilitating money laundering or terrorist financing, OFAC violations, and other serious crimes increases when a U.S. bank is unable to identify and adequately understand the transactions of the ultimate users (all or most of whom are outside of the United States) of its account with a foreign correspondent."2 Therefore, the compliance officer should notify Foreign Bank A of the discovery and seek documentation supporting Foreign Bank A was collusive and a willing partner with Foreign Bank B in the activity, as this would indicate a breach of the correspondent banking agreement and a possible violation of U.S. laws and regulations. The compliance officer should also document the findings and actions taken, and escalate the matter to senior management and the board of directors as appropriate.
The other options are not the best steps for the compliance officer to take. Option A is not relevant, as the issue is not related to tax evasion, but to money laundering or terrorist financing. Option B is premature, as the compliance officer should first verify the nature and extent of the suspicious activity and the involvement of Foreign Bank A before deciding whether to terminate or restrict the correspondent relationship. Option D is not feasible, as the compliance officer does not have the authority or the means to notify other U.S. financial institutions who maintain U.S. dollar correspondent accounts for Foreign Bank A and Foreign Bank B, and this could also interfere with ongoing investigations or law enforcement actions.
References:
* FFIEC BSA/AML Manual, Risks Associated with Money Laundering and Terrorist Financing, U.S.
Dollar Drafts
* Denting Dirty Dollar-Clearing: US Court of Appeals Upholds Money-Laundering Convictions Based on the Use of US Correspondent Banking Accounts, Freshfields Blog
* AMLA Expands DOJ Grand Jury Subpoena Power Over Correspondent Bank Accounts and Foreign Banks, Money Laundering News
質問 # 247
Which is a red flag for funds transfers?
- A. Funds transfers are repetitive and within expected patterns.
- B. Funds transfers are received in numerous small quantities from entities that are in related industries.
- C. Funds transfers are to a higher-risk geographic location with a known supplier within the same industry as the originator.
- D. Funds transfers are repeatedly sent to the same beneficiary out of line with the business purpose.
正解：D
解説：
Funds transfers are electronic payments that move money from one account to another, either within the same financial institution or across different institutions, countries, or currencies1. Funds transfers are commonly used for legitimate purposes, such as remittances, trade, or investment, but they can also be abused by money launderers, terrorists, or fraudsters to move illicit funds or conceal their origin or destination2. Therefore, financial institutions and other entities that offer funds transfer services are required to apply anti-money laundering and counter-terrorism financing (AML/CFT) measures, such as customer due diligence, transaction monitoring, record-keeping, and reporting of suspicious activities2.
One of the red flags for funds transfers that may indicate money laundering or other criminal activity is when funds transfers are repeatedly sent to the same beneficiary out of line with the business purpose3. This could suggest that the originator and the beneficiary are colluding to layer or integrate illicit funds, or to evade reporting or sanctions requirements. For example, a business may send multiple funds transfers to the same supplier, but the amounts or frequencies do not match the invoices or contracts, or the supplier is located in a high-risk jurisdiction or is subject to sanctions. Alternatively, an individual may send frequent funds transfers to the same person, but the relationship or the reason for the transfers is unclear or inconsistent, or the person is associated with a criminal or terrorist organization. In such cases, the financial institution or the funds transfer service provider should conduct enhanced due diligence, verify the source and purpose of the funds, and report any suspicious activity to the relevant authorities.
1: Wire Transfer Definition - Investopedia
2: International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation - The FATF Recommendations | FATF
3: Wire Transfer Red Flags: Money Laundering & Fraud Risks - Alessa1
Reference: https://www.fmu.gov.pk/docs/Red-flags-for-banks.pdf
質問 # 248
What three attributes do havens for money laundering and terrorist financing typically have? Choose 3 answers
- A. Absence of an effective FIU
- B. Little enforcement of the laws, weak penalties or provisions that make it difficult to confiscate or freeze assets related to money laundering
- C. Limited types of institutions and persons covered by money laundering laws and regulations
- D. A large number of predicate crimes for money laundering
正解：A、B、C
解説：
Havens for money laundering and terrorist financing are jurisdictions that offer a high degree of anonymity, secrecy, and protection to criminals who seek to conceal or move their illicit funds. These havens typically have the following three attributes12:
* Limited types of institutions and persons covered by money laundering laws and regulations. This means that only a narrow range of financial activities or entities are subject to anti-money laundering (AML) and combatting the financing of terrorism (CFT) obligations, such as customer due diligence,
* record-keeping, reporting, and supervision. For example, some havens may exclude lawyers, accountants, trust and company service providers, or non-bank financial institutions from AML/CFT requirements.
* Little enforcement of the laws, weak penalties or provisions that make it difficult to confiscate or freeze assets related to money laundering. This means that the authorities in these havens lack the political will, resources, or capacity to effectively implement and enforce the AML/CFT laws and regulations. They may also impose low sanctions or fines for non-compliance, or create legal barriers or obstacles for the confiscation or freezing of assets that are the proceeds of, or used in, or intended or allocated for use in, money laundering, terrorist financing, or other crimes.
* Absence of an effective FIU. This means that these havens do not have a central agency that is responsible for receiving, analyzing, and disseminating financial intelligence related to money laundering, terrorist financing, and other crimes. An effective FIU is essential for facilitating domestic and international cooperation and information exchange, as well as for supporting investigations and prosecutions of money laundering and terrorist financing cases.
References:
1: The IMF and the Fight Against Money Laundering and Terrorism Financing, 1 2: IX Special Recommendations, 2
質問 # 249
Which of the following customer activities poses the highest risk of money laundering?
- A. Making multiple cash deposits slightly below a required reporting limit.
- B. Transferring funds to pay for flight training lessons.
- C. Conducting business in a country that represents a high risk of money laundering.
- D. Paying a supplier of precious metals at regular quarterly intervals.
正解：A
解説：
The customer activity that poses the highest risk of money laundering is making multiple cash deposits slightly below a required reporting limit. This could indicate a practice known as structuring or smurfing, which is a method of breaking down large amounts of cash into smaller transactions to avoid detection or reporting by financial institutions12. Structuring is a common technique used by money launderers to conceal the source, ownership, or destination of illicit funds3.
The other options are not necessarily indicative of money laundering, although they may require further due diligence or monitoring depending on the customer profile and the nature of the transaction. For example:
* Transferring funds to pay for flight training lessons could be a legitimate educational expense, or it could be related to terrorist financing or other criminal activities. The financial institution should verify the identity and background of the customer and the recipient, and check for any red flags or suspicious indicators4.
* Paying a supplier of precious metals at regular quarterly intervals could be a normal business practice, or it could be a way of moving or storing value in an alternative asset class. The financial institution should assess the customer's source of funds, business rationale, and market conditions, and monitor for any changes or inconsistencies.
* Conducting business in a country that represents a high risk of money laundering could be a legitimate commercial opportunity, or it could be a sign of involvement in illicit activities or tax evasion. The financial institution should apply enhanced due diligence measures, such asverifying the identity and reputation of the customer and the counterparties, obtaining information on the purpose and nature of the business relationship, and screening for any sanctions or adverse media.
:
ACAMS CAMS Certification Video Training Course - Exam-Labs3
Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)4 ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 2, page 29: https://www.acams.
org/wp-content/uploads/2019/08/ACAMS-Study-Guide-6th-Edition-Chapter-2.pdf ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 6, page 121: https://www.acams.
org/wp-content/uploads/2019/08/ACAMS-Study-Guide-6th-Edition-Chapter-6.pdf ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 7, page 139: https://www.acams.
org/wp-content/uploads/2019/08/ACAMS-Study-Guide-6th-Edition-Chapter-7.pdf ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 4, page 77: https://www.acams.
org/wp-content/uploads/2019/08/ACAMS-Study-Guide-6th-Edition-Chapter-4.pdf
質問 # 250
What is a key objective of the Egmont Group?
- A. To issue binding standards that establish consistently operated Financial Intelligence Units in member jurisdictions.
- B. To provide best practices for financial institutions on how to report suspicious activity to best share the information with law enforcement.
- C. To find ways to promote the development of Financial Intelligence Units and the sharing of expertise.
- D. To safeguard the financial system from illicit use and combat money laundering and promote national security.
正解：D
解説：
Explanation/Reference: https://egmontgroup.org/en
質問 # 251
A European Union (EU) bank has a correspondent banking relationship with a U.S. bank. Under USA PATRIOT Act Section 311, the U.S. government has enacted special measures against a designated entity that has a payable-through account with the EU bank. Which of the following actions might the U.S. bank be required to take regarding the EU bank's services for the designated entity?
- A. Verify that the EU bank serves the designated entity.
- B. Ensure the designated entity's confidential information is not shared with other entities.
- C. Perform enhanced due diligence on the EU bank.
- D. Obtain additional information about customers permitted to use this account.
正解：D
解説：
Under USA PATRIOT Act Section 311, the U.S. government can impose special measures against a foreign jurisdiction, institution, or transaction that is of primary money laundering concern1. These measures can range from requiring additional recordkeeping and reporting to prohibiting or restricting the opening or maintaining of correspondent or payable-through accounts for the designated entity2. A payable-through account is a type of correspondent account that allows customers of a foreign bank to access the U.S. financial system by writing checks or making wire transfers from the foreign bank's account at a U.S. bank3.
In this case, the U.S. government has enacted special measures against a designated entity that has a payable- through account with an EU bank, which in turn has a correspondent banking relationship with a U.S. bank.
One of the possible actions that the U.S. bank might be required to take regarding the EU bank's services for the designated entity is to obtain additional information about customers permitted to use this account. This is to ensure that the U.S. bank can identify and monitor the transactions and activities of the designated entity and its customers, and to prevent any money laundering or terrorist financing risks4.
The other actions listed are not likely to be required by the U.S. government under Section 311. Ensuring the designated entity's confidential information is not shared with other entities is not a special measure, but a general obligation of any financial institution under privacy laws. Verifying that the EU bank serves the designated entity is not a relevant action, since the U.S. government has already designated the entity as a primary money laundering concern. Performing enhanced due diligence on the EU bank is not a specific action related to the payable-through account, but a broader requirement for any correspondent account under Section 312 of the USA PATRIOT Act5.
1: USA PATRIOT Act | FinCEN.gov1 2: 311 Actions | U.S. Department of the Treasury2 3: Overview of Correspondent Banking and "De Risking" Issues - CRS Reports3 4: U.S. TREASURY DEPARTMENT OFFICE OF PUBLIC AFFAIRS4 5: Fact Sheet: Overview of Section 311 of the USA PATRIOT Act5
質問 # 252
the Financing of Terrorism (CFT)]
Which step should financial institutions take when complying with sanctions requirements?
- A. Freeze the funds or assets of designated persons and entities once this decision is approved by the Board.
- B. Adopt automatic screening systems to detect designated persons and entities.
- C. Change the risk profile to "high-risk" if an existing customer becomes a sanctioned entity and continue monitoring further transactions.
- D. Conduct enhanced due diligence for prohibited entities on the sanctions list.
正解：A
解説：
The financial institution should freeze the funds or assets of designated persons and entities once this decision is approved by the Board. This is to comply with the obligation to implement targeted financial sanctions imposed by the United Nations Security Council (UNSC) or other relevant authorities. Freezing means preventing any access, use, transfer, or disposal of the funds or assets by the designated persons and entities or by any other person on their behalf. The financial institution should also report the freezing action to the competent authority and the relevant sanctions committee12.
Option A is not a sufficient step to comply with sanctions requirements, but rather a tool to facilitate compliance. Adopting automatic screening systems to detect designated persons and entities can help the financial institution to identify potential matches and flag them for further investigation. However, screening systems are not infallible and may generate false positives or false negatives. Therefore, the financial institution should also conduct manual checks and verification of the screening results13.
Option B is not a relevant step to comply with sanctions requirements, but rather a measure to mitigate money laundering and terrorist financing risks. Conducting enhanced due diligence for prohibited entities on the sanctions list may be useful to obtain more information about the nature and purpose of the business relationship, the source and destination of the funds, and the beneficial ownership and control structure of the entity. However, enhanced due diligence does not replace the obligation to freeze the funds or assets of the designated persons and entities14.
Option C is not an appropriate step to comply with sanctions requirements, but rather a violation of the obligation to freeze the funds or assets of the designated persons and entities. Changing the risk profile to
"high-risk" if an existing customer becomes a sanctioned entity and continuing to monitor further transactions may expose the financial institution to legal and reputational risks, as well as potential sanctions evasion or circumvention. The financial institution should terminate the business relationship with the designated person or entity and freeze their funds or assets without delay1 .
References: 1: ACAMS (2020), Study Guide for the Certification Examination, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams-certification-package-6th-edition, pp. 47-49. 2: ACAMS (2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams- certification-package-6th-edition, Module 2, Section2.4.1. 3: ACAMS (2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams-certification-package-
6th-edition, Module 2, Section 2.4.2. 4: ACAMS (2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams-certification-package-6th-edition, Module 2, Section
2.4.3. : ACAMS (2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams-certification-package-6th-edition, Module 2, Section 2.4.4.
質問 # 253
When a financial institution is requested to provide data and information to a law enforcement agency for matters related to financing of terrorism, assistance:
- A. cannot be refused on the grounds of tipping-off.
- B. can be refused on the grounds of tipping-off.
- C. cannot be refused on the grounds of bank secrecy.
- D. can be refused on the grounds of bank secrecy.
正解：A
解説：
When a financial institution is requested to provide data and information to a law enforcement agency for matters related to the financing of terrorism, assistance cannot be refused on the grounds of tipping-off.
Tipping-off refers to disclosing to a customer or any third party that a suspicious activity report (SAR) has been filed. However, in this specific context, the obligation to provide information to law enforcement takes precedence over any concerns related to tipping-off. Financial institutions must cooperate fully with law enforcement agencies in such cases to combat money laundering and terrorist financing12.
References:
31 CFR 1010.520 (a) (2)
FinCEN: Fact Sheet on the Rapid Response Program (RRP)
FinCEN.gov
Federal Financial Institutions Examination Council (FFIEC) BSA/AML Examination Manual
質問 # 254
Which of the following are key AML measures that a regulated asset management company in the European Union (EU) should implement? (Select Two.)
- A. Producing financial stability reports on interesting customers.
- B. Performing negative news checks of prospective customers.
- C. Understanding the source and origin of assets.
- D. Rejecting any politically exposed persons (PEPs) as customers.
- E. Inviting prospective customers for an onboarding interview.
正解：B、C
解説：
Asset management companies handle large amounts of funds, making them prime targets for money launderers.
Option A (Correct): Negative news (adverse media) screening is essential for identifying potential financial crime risks.
Option D (Correct): Understanding the source and origin of assets ensures that funds come from legitimate sources.
Option B (Incorrect): PEPs should not be automatically rejected, but enhanced due diligence (EDD) is required.
Option C (Incorrect): While onboarding interviews help, they are not a mandatory AML measure.
Option E (Incorrect): Financial stability reports are useful, but not directly linked to AML compliance.
AML Risks in Asset Management:
High-value transactions that may mask illicit wealth.
Layering through investment portfolios to hide the origin of funds.
Use of offshore structures to evade regulatory scrutiny.
Best Practices for AML in Asset Management:
Conduct enhanced due diligence (EDD) on high-net-worth clients.
Monitor large and unusual transactions.
Screen customers against PEP, sanction, and adverse media databases.
Reference:
FATF Recommendation 22 (AML for Asset Management)
6th EU Anti-Money Laundering Directive (6AMLD)
Wolfsberg Group Asset Management AML Framework
質問 # 255
What national agency is responsible for analyzing and assessing the information it receives to substantiate possible existence of money laundering or terrorist financing activities?
- A. The Basel Committee
- B. The Wolfsberg Group
- C. FATF
- D. The Financial Intelligence Unit (FIU)
正解：D
解説：
An FIU is a central, national agency responsible for receiving, analyzing, and disseminating to the competent authorities disclosures of financial information concerning suspected proceeds of crime and potential financing of terrorism or required by nationallegislation or regulation1. FIUs play a crucial role in the detection and prevention of money laundering and terrorist financing by collecting, processing, and analyzing financial intelligence and sharing it with domestic and foreign counterparts2. FIUs may have different organizational structures, functions, and legal frameworks, but they all adhere tothe international standards and best practices set by the Egmont Group of FIUs3.
:
What We Do | FinCEN.gov
Financial Intelligence Units: An Overview (June 2004) - IMF, page 1
[Egmont Group of Financial Intelligence Units]
Reference: https://www.fatf-gafi.org/media/fatf/content/images/National_ML_TF_Risk_Assessment.pdf
質問 # 256
During a routine periodic KYC refresh of a policyholder and client of an insurance company, updated business registry documentation has highlighted that the policyholder's business has changed addresses five times during the last year and that the ultimate beneficial owner (UBO) changed two weeks ago.
What actions should be taken immediately?
- A. Request the relationship manager set up a meeting with the policyholder to update their address and submit details of the new UBO in the name of good customer service
- B. Investigate the changes of address and change of UBO and in the meantime freeze the client's policy
- C. File a suspicious transaction report because the insurance company was not made aware of the business' change of UBO
- D. Investigate the changes of address and change of UBO and in the meantime decline payment and withdrawal instructions from the policy until completion of the investigation and next steps are agreed upon
正解：D
解説：
The combination of frequent address changes and a recent change in the ultimate beneficial owner raises potential red flags that warrant immediate investigation. To mitigate risk, the insurance company should investigate these changes and temporarily decline any payment or withdrawal instructions until the review is complete and appropriate steps are agreed upon. This ensures both regulatory compliance and protection against potential misuse of the policy.
質問 # 257
Which of the following AML/CFT arrangements should a bank have in place at minimum before opening for business? (Choose three.)
- A. Independent compliance testing
- B. Written policy and procedures
- C. Qualified and knowledgeable staff
- D. An automated monitoring system
- E. Third-party screening software
正解：A、B、C
解説：
Before opening for business, a bank must have independent compliance testing to ensure controls are functioning, qualified staff who understand AML/CFT requirements, and documented policies and procedures to guide day-to-day compliance. These are foundational elements of an effective AML/CFT framework.
質問 # 258
Which two actions should Financial Intelligence Units (FIUs) take when submitting a request to another FIU?
(Choose two.)
- A. Make best efforts to provide complete and factual information
- B. Provide feedback on how the information was used
- C. Send the same request to all FIUs
- D. Disclose the reason and purpose for the request
正解：B、D
解説：
According to the Egmont Group of Financial Intelligence Units, which is a global network of FIUs that promotes information exchange and cooperation, FIUs making requests to another FIU should disclose the reason and purpose for the request, and provide feedback on how the information was used12. These actions are intended to enhance mutual trust, transparency, and accountability between FIUs, and to facilitate the effective use of financial intelligence and information for combating money laundering, terrorist financing, and other financial crimes12. FIUs making requests should also respect the confidentiality and data protection requirements of the FIU receiving the request, and avoid imposing unreasonable or unduly restrictive conditions12.
FIUs making requests should not send the same request to all FIUs, as this would be inefficient, unnecessary, and potentially harmful. FIUs should only send requests to FIUs that are relevant and competent to provide the information they need, based on the nature and scope of the case12. Sending the same request to all FIUs could overload the system, create duplication, and compromise the security and confidentiality of the information12. FIUs making requests should also make best efforts to provide complete and factual information, but this is not an action they should take when submitting a request, but rather when responding to a request from another FIU12.
References:
* Egmont Group of Financial Intelligence Units Operational Guidance for FIU Activities and the
* Exchange of Information
* Principles for Information Exchange Between Financial Intelligence Units
質問 # 259
the Financing of Terrorism (CFT)]
Which are primary purposes of Financial Action Task Force {FATF)-Style Regional Bodies? (Select Two.)
- A. Imposing special measures for non-cooperative jurisdictions
- B. Providing due diligence for foreign correspondent banks
- C. Promoting effective implementation of FATF recommendations
- D. Providing expertise and input in FATF policy-making
- E. Acting as a prudential regulatory body for financial institutions
正解：C、D
解説：
The primary purposes of Financial Action Task Force (FATF)-Style Regional Bodies are to promote effective implementation of FATF recommendations and to provide expertise and input in FATF policy-making.
(CAMS Manual, 6th Edition, Page 180)
質問 # 260
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