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合格させるCAMS試験一発合格保証2026問題集！
CAMS資格を取得するためには、マネーロンダリング、テロ資金提供、その他の金融犯罪の検出や防止を含む、幅広いトピックをカバーする厳しい試験に合格する必要があります。試験は、複数の選択式問題から構成され、世界中のテストセンターでオンラインまたは対面で実施されます。また、試験を受験するためには、特定の教育や経験要件を満たす必要があります。
ACAMS CAMS 認定試験の出題範囲：
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CAMS認定を取得すると、AMLコンプライアンスで働く専門家に多くの利点があります。知識とスキルを向上させ、仕事のパフォーマンスを向上させ、雇用市場での信頼性と市場性を向上させることができます。さらに、新しいキャリアの機会を開き、収益の可能性を高めることができます。全体として、CAMS認定は、AMLと金融犯罪防止の分野で優れていることを検討している専門家にとって不可欠な資格です。
質問 # 53
the Financing of Terrorism (CFT)]
Which statement about a multinational institution's ability to fully investigate unusual activity in all its foreign operations is correct?
- A. Certain account documents may be stored only in local language which will prohibit a global assessment.
- B. Local privacy and data protection laws may prevent an affiliate from sharing information.
- C. The institution should consult with the customer and request permission to conduct a full investigation into all the accounts.
- D. Enterprise-wide compliance oversight rules issued in the global institution's headquarters country will override any local limitations in other countries.
正解：B
解説：
A multinational institution may face challenges in conducting a full investigation of unusual activity across its foreign operations, due to the different legal and regulatory frameworks that apply in each jurisdiction. One of the main obstacles is the local privacy and data protection laws that may restrict the access, transfer, or disclosure of customer information, especially personal or sensitive data, to other entities within the same group or to external parties, such as law enforcement or regulators. Therefore, the institution should be aware of the local laws and regulations that govern the collection, processing, and sharing of customer data, and ensure compliance with them12.
:
ACAMS Study Guide, 6th Edition, page 191
Which statement about a multinational institution's ability to fully investigate unusual activity in all its foreign operations is correct? - Exam4Training Learn more
1blob:https://www.bing.com/12e36647-a7b4-48a5-9dff-13e7aab69e80
quizlet.com2blob:https://www.bing.com/2c9f865a-c41c-4acb-9e08-acb661cdbbe3 exam4training.com3blob:https://www.bing.com/2c9f865a-c41c-4acb-9e08-acb661cdbbe3 exam4training.com4blob:https://www.bing.com/12e36647-a7b4-48a5-9dff-13e7aab69e80 quizlet.com A multinational institution may face challenges in conducting a full investigation of unusual activity across its foreign operations, due to the different legal and regulatory frameworks that apply in each jurisdiction. One of the main obstacles is the local privacy and data protection lawsthat may restrict the access, transfer, or disclosure of customer information, especially personal or sensitive data, to other entities within the same group or to external parties, such as law enforcement or regulators. Therefore, the institution should be aware of the local laws and regulations that govern the collection, processing, and sharing of customer data, and ensure compliance with them12.
References:
ACAMS Study Guide, 6th Edition, page 191
Which statement about a multinational institution's ability to fully investigate unusual activity in all its foreign operations is correct? - Exam4Training
質問 # 54
the Financing of Terrorism (CFT)]
Financial institutions (FIs) perform AML risk assessments to ensure:
- A. satisfaction of the board of directors' approved risk appetite.
- B. internal audit assurance that all AML-related policy and procedures are board approved.
- C. a record for regulators indicating an AML risk assessment was completed at least once.
- D. proper controls surrounding higher-risk products, services, customers, and geographic locations.
正解：D
解説：
AML risk assessments are a key component of the risk-based approach to AML compliance, as required by the MLR 20171 and the FATF Recommendations2. AML risk assessments help FIs to identify, assess, and mitigate the money laundering and terrorist financing risks they face, taking into account their specific products, services, customers, and geographic locations. AML risk assessments also help FIs to allocate their resources and implement their AML policies and procedures in a proportionate and effective manner. AML risk assessments are not meant to be a one-off exercise, but rather an ongoing process that should be updated regularly to reflect changes in the FI's risk profile and the external environment.
:
1: The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations
2017
2: The FATF Recommendations - International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation Reference: https://www.wolfsberg-principles.com/sites/default/files/wb/pdfs/faqs/17.%20Wolfsberg-Risk- Assessment-FAQs-2015.pdf
質問 # 55
Who meets the standard to perform the AML audit? (Select Two.)
- A. A consultant previously employed in the AML department within the past 2 years
- B. An internal auditor with a family member employed in the AML department
- C. A consultant with limited knowledge and experience in AML but many years of internal audit experience
- D. Qualified bank staff if not involved in the AML function being tested
- E. An internal auditor with the requisite knowledge and expertise of AML
正解：D、E
解説：
Explanation
An internal auditor with the requisite knowledge and expertise of AML: An internal auditor with sufficient knowledge and expertise in AML regulations and compliance requirements can perform the AML audit.
Qualified bank staff if not involved in the AML function being tested: Qualified bank staff who are not involved in the AML function being audited can perform the AML audit.
質問 # 56
Which is a FATF characteristic used to assess a country's effectiveness of its AML regime?
- A. Supervisors appropriately supervise, monitor, and regulate financial institutions (Fls).
- B. FIs adequately apply preventive measures.
- C. Legal persons are prevented from misuse for money laundering or terrorist financing.
- D. Funds supporting and proceeding from crime or terrorism are prevented from entering the financial sector.
正解：B
解説：
The FATF is an inter-governmental body that sets standards and promotes effective implementation of legal, regulatory, and operational measures for combating money laundering, terrorist financing, and other related threats to the integrity of the internationalfinancial system. The FATF conducts mutual evaluations of its members and other jurisdictions to assess their compliance with the FATF Recommendations and the effectiveness of their AML/CFT regimes1.
The FATF defines effectiveness as "the extent to which a country's AML/CFT regime is achieving the defined outcomes of an effective regime that allows them to mitigate their risks and threats of ML/TF"2. The FATF assesses effectiveness based on 11 immediate outcomes, which are grouped into three thematic goals:
financial system integrity, legal system and operational issues, and international cooperation2.
One of the immediate outcomes under the financial system integrity goal is that "FIs adequately apply preventive measures commensurate with their risks, and report suspicious transactions" (IO.4)2. This outcome measures how well FIs implement the FATF Recommendations on customer due diligence, record-keeping, internal controls, risk assessment, and suspicious transaction reporting. These preventive measures are essential for FIs to identify and mitigate the risks of being misused for money laundering or terrorist financing, and to provide useful information to the authorities for investigation and prosecution2.
Therefore, the correct answer is D. FIs adequately apply preventive measures, as this is one of the FATF characteristics used to assess a country's effectiveness of its AML regime.
FATF Methodology for assessing compliance with the FATF Recommendations and the effectiveness of AML
/CFT systems
An effective system to combat money laundering and terrorist financing
質問 # 57
Which type of sanctions are most likely to be used in order to avoid escalating violent conflicts and/or proliferation of weapons?
- A. Financial prohibitions
- B. Asset freeze
- C. Export and import restrictions
- D. Arms and related materials embargo
正解：D
解説：
Arms and related materials embargo is a type of sanction that prohibits the supply, sale, transfer, or export of arms and related materials to a targeted country, entity, or individual. This type of sanction is most likely to be used in order to avoid escalating violent conflicts and/or proliferation of weapons, as it aims to reduce the availability and access of weapons and ammunition that could fuel violence and instability. Arms and related materials embargo can also prevent the transfer of weapons of mass destruction and their delivery systems to non-state actors or rogue states. According to the UN, arms and related materials embargo is one of the most common and effective forms of sanctions that the Security Council imposes to address threats to international peace and security12.
1: Different types of sanctions - Consilium1
2: UN Sanctions and the Prevention of Conflict - United Nations University2 Reference: https://collections.unu.edu/eserv/UNU:6431/UNSanctionsandPreventionConflict-Aug-2017.pdf (3)
質問 # 58
A junior account manager within an international private bank in Country A was asked by one of his valued customers, who has held an account for several years in the institution, about depositing a large sum of cash into her account. The junior account manager informed his customer that his bank does not accept cash. The junior account manager later reviewed a customer activity report and noticed a number of smaller dollar wires from banks in neighboring Country B, which has lax currency controls, that totaled about as much as the customer intended to deposit.
What should the junior account manager do?
- A. Offer the customer a more secure method of depositing in the hope of learning something more during the conversation
- B. Close the account
- C. Notify the anti-money laundering specialist of his bank, but do not call the customer
- D. File a suspicious transaction report with the Financial Intelligence Unit
正解：C
質問 # 59
As a result of an audit, a policy exception was identified that had been approved by the compliance officer.
The auditor determined that the policy exception is a violation of a regulatory requirement.
What should the auditor do?
- A. Advise the compliance officer on how to appropriately respond to policy exceptions.
- B. Include the regulatory violation in the audit report and report it to the board of directors.
- C. Include the regulatory violation in the audit report and recommend the compliance officer be subject todisciplinary action by the board of directors.
- D. Consult with legal counsel to determine if the approval of the policy exception was acceptable.
正解：B
解説：
The auditor should include the regulatory violation in the audit report and report it to the board of directors.
This is because the auditor has the responsibility to report any findings of non-compliance or material weaknesses in the institution's internal controls, policies, and procedures. The auditor should also provide recommendations for corrective actions and follow-up on their implementation. The board of directors has the ultimate oversight and accountability for the institution's compliance program and should be informed of any significant issues or risks that may affect the institution's reputation, operations, or regulatory status12.
1: CAMS Certification Package - 6th Edition | ACAMS, Chapter 6: Developing an Effective Anti-Money Laundering Program, p. 125-126 2: The Wolfsberg Group, The Wolfsberg Anti-Money Laundering Principles for Correspondent Banking, October 2014, p. 7, https://www.wolfsberg-principles.com/sites/default/files/wb
/pdfs/Wolfsberg-Correspondent-Banking-Principles-2014.pdf
質問 # 60
An anti-money laundering specialist has been asked to establish a compliance program to detect and prevent money laundering and terrorist financing. Which of the following should the anti-money laundering specialist consider in developing the program?
1. Funds for money laundering and terrorist financing are derived from illegal sources.
2. Related practices are used to conceal the nature of the funds.
3. The source and disposition of funds are similar.
4. Similar techniques are used to move funds.
- A. 3 and 4 only
- B. 1 and 2 only
- C. 1 and 3 only
- D. 2 and 4 only
正解：D
解説：
Money laundering and terrorist financing are both forms of financial crime that involve the movement of illicit funds. However, they differ in the source and purpose of the funds. Money laundering is the process of disguising the origin, ownership, or destination of funds that are derived from illegal activities, such as drug trafficking, fraud, or tax evasion. Terrorist financing is the provision or collection of funds, by legitimate or illegitimate means, for the purpose of carrying out terrorist acts. Therefore, the anti-money laundering specialist should consider the following factors in developing a compliance program:
Related practices are used to conceal the nature of the funds. Both money launderers and terrorist financiers use similar methods to hide the true identity, source, or destination of the funds, such as using shell companies, front organizations, complex transactions, cash couriers, or cryptoassets. A compliance program should include measures to identify and verify the customers, beneficial owners, and counterparties involved in the transactions, as well as to monitor and report any suspicious or unusual activities.
Similar techniques are used to move funds. Both money launderers and terrorist financiers use the same stages of placement, layering, and integration to move funds through the financial system. Placement is the introduction of illicit funds into the legitimate financial system, such as by depositing cash, purchasing assets, or transferring funds electronically. Layering is the separation of the funds from their source, such as by using multiple accounts, jurisdictions, or intermediaries. Integration is the re-entry of the funds into the legitimate economy, such as by investing in businesses, real estate, or securities. A compliance program should include measures to detect and prevent the movement of illicit funds through the financial system, such as by applying risk-based due diligence, record-keeping, and transaction limits.
Reference:
CAMS Certification Package - 6th Edition | ACAMS
CAMS Certifications: How to Get CAMS Certified | ACAMS
ACAMS CAMS Certification Video Training Course - Exam-Labs
Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)
質問 # 61
Under which two circumstances may law enforcement be given access to a financial institution customer's financial records? (Choose two.)
- A. If the person is named in a suspicious transaction report
- B. If the investigation of a customer is made public in the media
- C. If law enforcement serves a legal summons or subpoena
- D. If law enforcement has circumstantial evidence to suspect money laundering
正解：C、D
解説：
Q Law enforcement may be given access to a financial institution customer's financial records if they serve a legal summons or subpoena, or if they have circumstantial evidence to suspect money laundering. These are two of the exceptions to the general rule that financial institutions must protect the privacy of their customers' financial information under the Right to Financial Privacy Act (RFPA) of 19781. The RFPA alsoallows access to customer records in other situations, such as with the customer's consent, in response to judicial orders, or for certain intelligence or counterintelligence purposes1.
Option A is incorrect because a suspicious transaction report (STR) does not automatically grant law enforcement access to the customer's financial records. The STR is a confidential document that is filed by the financial institution to the Financial Intelligence Unit (FIU) of the country, and the FIU may decide to share the information with law enforcement if it deems appropriate2. However, law enforcement still needs to follow the RFPA procedures to obtain the customer's records from the financial institution.
Option C is incorrect because the investigation of a customer being made public in the media does not give law enforcement the right to access the customer's financial records. The media exposure may raise the public interest or the urgency of the investigation, but it does not override the RFPA requirements. Law enforcement still needs to obtain a legal summons, subpoena, or other valid authorization to access the customer's records from the financial institution.
References:
1: Right to Financial Privacy Act of 1978, 12 U.S.C. §§ 3401-3422
2: ACAMS Study Guide for the CAMS Certification Examination, 6th Edition, Chapter
3: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), p. 47
質問 # 62
An anti-money laundering specialist has been hired by an independently-owned community bank to implement an anti-money laundering compliance program. This bank has recently seen a dramatic increase in the number of international electronic fund transfers from its commercial clients. The first thing the anti- money laundering specialist should do is
- A. develop a new account questionnaire to quantify the level of risk for new international accounts.
- B. close all accounts which have had a dramatic increase in international electronic fund transfer activity.
- C. file a suspicious transaction report on international customers receiving large electronic fund transfers.
- D. conduct a risk assessment of the bank's international electronic fund transfer activity.
正解：D
解説：
The first thing the anti-money laundering specialist should do is to conduct a risk assessment of the bank's international electronic fund transfer activity. This is to identify and measure the potential money laundering and terrorist financing risks associated with the bank's products, services, customers, and geographic locations. A risk assessment can help the anti-money laundering specialist to:
* Understand the nature and extent of the bank's exposure to money laundering and terrorist financing threats and vulnerabilities.
* Establish a risk-based approach to the design and implementation of the anti-money laundering compliance program, including policies, procedures, controls, monitoring, reporting, and training.
* Allocate appropriate resources and prioritize actions to mitigate the identified risks and enhance the effectiveness of the anti-money laundering compliance program.
* Demonstrate to the regulators and auditors that the bank has a sound and comprehensive anti-money laundering compliance program that is commensurate with its risk profile and business activities.
:
CAMS Study Guide - 6th Edition, Chapter 6, pages 167-168
CAMS Certification Exam Outline, Domain 3, Task 3.1, Skill 3.1.1
Anti-Money Laundering Bulletin November 2021 - Central Bank of Ireland, pages 4-5 Money Laundering through Money Remittance and Currency Exchange Providers, FATF, June 2010, pages 7-
8
REGULATIONS - FIU, Part III, Regulation 9, pages 9-10
質問 # 63
A client is a wholesale auto business that operates as a used car lot. The client regularly ships vehicles internationally. In a four-month period, the client received wires totaling $ 1,250,000 from a dealer in Benin in West AfricA. All wires originated from Benin and were in increments of $50,000.
Account debits made to the account were payable to various transport companies. All incoming checks reference various vehicles purchased. Dock shipping receipts produced by the client to support account activity identify the vehicles but cannot easily be tied to the wires receives.
What is the suspicious behavior?
- A. Vehicles are regularly shipped internationally
- B. The dock shipping receipts match the vehicles
- C. Account debits are payable to transport companies
- D. Wires received are in large, even dollar amounts
正解：D
解説：
The correct answer is C. Wires received in large, even dollar amounts are a suspicious behavior, as they may indicate an attempt to avoid reporting thresholds or to conceal the source of funds. Large and round numbers are often used by money launderers to simplify calculations or to avoid arousing suspicion12. The other options are not necessarily suspicious, as they may reflect the normal business operations of a wholesale auto business that ships vehicles internationally. The dock shipping receipts match the vehicles (A), vehicles are regularly shipped internationally (B), and account debits are payable to transport companies (D) are all plausible and legitimate activities for such a business.
References:
ACAMS CAMS Certification Video Training Course3, Module 3: Risks and Methods of Money Laundering and Terrorism Financing, Lesson 2: Methods of Money Laundering ACAMS CAMS Certification Study Guide1, Chapter 3: Risks and Methods of Money Laundering and Terrorism Financing, Section 3.2: Methods of Money Laundering, pp. 79-80
質問 # 64
The vice president of the foreign correspondent banking department at a large United States bank has been notified that a foreign bank with an offshore license wants to open a correspondent account.
Which two things must the vice president acquire under the USA PATRIOT Act? (Choose two.)
- A. Information relating to the foreign bank's anti-money laundering program
- B. A list of the types of businesses served by the correspondent bank
- C. A list of all the customers of the correspondent bank
- D. The identity of 10% owners of the correspondent bank, unless it is publicly traded
正解：A、D
解説：
According to section 312 of the USA PATRIOT Act, U.S. financial institutions that maintain correspondent accounts for foreign financial institutions must apply due diligence to such accounts. The due diligence must include obtaining information relating to the foreign bank's anti-money laundering program, as well as the identity of any person who owns 10% or more of the foreign bank, unless the foreign bank is publicly traded.
These requirements are intended to prevent the use of correspondent accounts by foreign shell banks or other entities that may pose a high risk of money laundering or terrorist financing.
References:
USA PATRIOT Act | FinCEN.gov
FACT SHEET for Section 312 of the USA PATRIOT Act Final Regulation and Notice of Proposed Rulemaking | FinCEN.gov US PATRIOT ACT | State Street CAMS Exam: USA PATRIOT Act Requirements for Opening a Correspondent Account
質問 # 65
Which of the following describes a role of the Financial Action Task Force (FATF)?
- A. Oversight of the Financial Intelligence Units in FATF Member countries
- B. Regulation of financial markets through directives and executive orders
- C. Enhancement of international cooperation to foster anti-money laundering efforts via recommendations and guidance
- D. Providing a unique platform for information exchange regarding anti-money laundering efforts
正解：C
解説：
* The FATF's core role is to enhance international cooperation against money laundering and terrorist financing through setting global standards ("Recommendations") and issuing guidance.
* "The FATF is an intergovernmental body whose purpose is the development and promotion of national and international policies to combat money laundering and terrorist financing."
* The FATF does not have authority to oversee FIUs, nor does it regulate financial markets directly.
References:
CAMS 6th Edition, FATF's Role and Structure
FATF Recommendations (Introduction section)
質問 # 66
Since its last regulatory examination, a financial institution has aggressively grown by adding profitable new products and services. The institution has not historically received regulatory criticism regarding its anti- money laundering compliance program. However, a recent regulatory examination cited significant deficiencies in the anti-money laundering program that were attributed primarily to the lack of oversight by the institution's leadership in implementing adequate controls over the new products and services.
Which area of international control should leadership first address to correct the weaknesses in the program?
- A. Anti-money laundering training
- B. Anti-money laundering compliance staff
- C. Money laundering risk assessment
- D. Anti-money laundering policy
正解：C
解説：
A money laundering risk assessment is a crucial component of an effective anti-money laundering (AML) program. It involves identifying, assessing, and understanding the specific risks related to money laundering and terrorist financing that the institutionmay face. A risk assessment helps the institution to design and implement appropriate controls, policies, procedures, and training to mitigate the risks. A risk assessment should be updated regularly and whenever there are significant changes in the institution's business activities, products, services, customers, or geographic locations. In this scenario, the financial institution has experienced significant deficiencies in its AML program during a recent regulatory examination. The deficiencies were primarily attributed to the lack of oversight by the institution's leadership in implementing adequate controls over the new products and services that were added as part of the institution's aggressive growth strategy. To correct these weaknesses in the AML program, the leadership should first address the area of international control known as "Money laundering risk assessment" (Option C). By conducting a new and comprehensive risk assessment, the leadership can identify the potential vulnerabilities and gaps in the AML program that may arise from the new products and services. The risk assessment can also help the leadership to prioritize the actions and resources needed to address the deficiencies and enhance the AML program.
Once the risk assessment is completed, the leadership can then work on updating the AML policy, providing adequate training, and ensuring sufficient compliance staff to implement and monitor the controls.
1, Chapter 2: Risk Assessments
2, Section 2: Anti-Money Laundering Compliance Program
3, Question 145
質問 # 67
A law enforcement agency submits several requests to a financial institution. Which request is legitimate and requires the bank to respond?
- A. Produce documents and testimony without a subpoena.
- B. Freeze an account in terms of a court order.
- C. Seize privileged documents upon written request.
- D. Keep an account open upon verbal request.
正解：B
解説：
A court order is a legal document issued by a judge or a magistrate that authorizes or requires a person or an entity to perform or refrain from performing a certain action. A court order to freeze an account is a legitimate request that requires the bank to comply, as it is a binding and enforceable order that may be issued for various reasons, such as preventing the dissipation of assets, preserving evidence, or facilitating the recovery of funds. A bank that receives a court order to freeze an account should follow its policies and procedures to verify the authenticity and validity of the order, and to implement the freeze as instructed by the order. A bank should also file a SAR if it suspects or has reason to suspect that the account is involved in suspicious or illicit activity.
The other options are not legitimate requests that require the bank to respond. A verbal request to keep an account open, a written request to seize privileged documents, or a request to produce documents and testimony without a subpoena are not legally binding or enforceable, and may violate the bank's obligations to protect the privacy and confidentiality of its customers. A bank may choose to cooperate with law enforcement in these situations, but it is not required to do so. A bank should also consider the potential risks and implications of maintaining an account or disclosing information that may be related to suspicious or illicit activity, and consult with its legal counsel as appropriate.
References:
Requests by Law Enforcement for Financial Institutions to Maintain Accounts Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations OCC Bulletin 2007-37: Requests by Law Enforcement for Financial Institutions to Maintain Accounts CAMS Certification Package - 6th Edition | ACAMS
質問 # 68
An internal audit team is reviewing the anti-financial crime (AFC) program of its firm.
Which of the following attributes of the third line of defense would be most critical to ensure unbiased and effective oversight?
- A. Independent testing
- B. Qualification of the team
- C. Periodic training of the function
- D. Consistency of approach
正解：A
解説：
* D (Independent testing): The third line of defense (internal audit) must conduct truly independent testing and assessments of the AFC/AML program to provide objective, unbiased assurance.
* "The third line of defense (internal audit) provides independent assurance of the effectiveness of AML
/CFT programs and controls by conducting unbiased reviews and testing."(CAMS 6th Edition, Three Lines of Defense Model; Basel Committee on Banking Supervision (BCBS) Guidance) References:
CAMS 6th Edition, Internal Controls and Audit
BCBS, The Internal Audit Function in Banks
質問 # 69
A large United States (U.S.) bank is performing due diligence on a non-U.S. bank. The non-U.S. bank has applied for a correspondent account at the U.S. bank.
Which two steps should the U.S. bank take under the USA PATRIOT Act? (Choose two.)
- A. Assess the money laundering risk presented by the correspondent account
- B. Verify the identity of politically exposed persons in management positions at the non-U.S. bank
- C. Verify the identity of the customers of the foreign bank
- D. Determine whether enhanced due diligence is necessary
正解：A、B
質問 # 70
What are two requirements for monitoring and reporting suspicious activity for correspondent banking according to the Wolfsberg Principles? (Choose two.)
- A. Incorporate suspicious activity monitoring into periodic reviews
- B. Investigate and report suspicious activity only for the correspondent bank's clients
- C. Utilize downstream correspondents to investigate and report suspicious activity
- D. Incorporate due diligence results such as customer risk ratings
正解：A、D
解説：
'https://www.wolfsberg-principles.com/sites/default/files/wb/pdfs/wolfsberg-standards/8.%20Wolfsberg- Correspondent-Banking-Principles-2014.pdf - page 6 Monitoring and Reporting of Suspicious Activities The institution shall implement bank-wide policies and procedures to detect and investigate unusual or suspicious activity and report any such activity as required by applicable law. These will include guidance on what is considered to be unusual or suspicious and give examples thereof. The policies and procedures shall include appropriate monitoring of the Correspondent Bank's activity, incorporating due diligence results such as customer risk rating and other factors considered meaningful in the assessment of transaction activity risk. In turn, the results of suspicious activity monitoring shall be factored into the periodic review of the client's file, particularly when the results of transaction monitoring indicate elevated risk levels.
質問 # 71
Combating the Financing of Terrorism (CFT)]
According to the Financial Action Task Force 40 Recommendations, to fulfill identification requirements concerning legal entities, financial institutions should take measures to verify
- A. the legal existence and ownership structure of the legal entity.
- B. funds or trusts maintained by terrorists.
- C. a person purporting to act on behalf of the legal entity who is a resident in a country with strict secrecy laws.
- D. the financial status of the legal entity through documented proof of the entity's other banking relations.
正解：A
解説：
According to the Financial Action Task Force (FATF) 40 Recommendations, Recommendation 10 requires financial institutions to identify and verify the identity of their customers, including legal persons and arrangements, using reliable and independent sources. This includes verifying the legal existence and structure of the legal entity, such as by obtaining a certificate of incorporation, a partnership agreement, or a trust deed. Additionally, financial institutions should identify and verify the identity of the beneficial owners of the legal entity, such as by obtaining information on the natural persons who ultimately own or control the entity, or who exercise effective control over the entity.
The other options are not consistent with the FATF 40 Recommendations. Verifying the financial status of the legal entity, or the entity's other banking relations, is not a requirement for identification purposes, although it may be relevant for risk assessment or due diligence purposes. Verifying a person purporting to act on behalf of the legal entity is also not sufficient, as the person may not be authorized or may not disclose the true identity or beneficial ownership of the entity. Verifying funds or trusts maintained by terrorists is not a specific identification requirement, but rather a general obligation to comply with targeted financial sanctions and freeze the assets of designated persons or entities.
:
FATF 40 Recommendations, Recommendation 10, Interpretive Note to Recommendation 10, pages 14-18.
ACAMS CAMS Certification Study Guide, 6th Edition, Chapter 3, Section 3.2.1, page 77.
質問 # 72
Outgoing foreign transactions of similar amounts trigger a monitoring alert for a customer's accounts. During the evaluation of the accounts, the bank discovers the wire transfers were very small amounts and occurred within the last 3 months following a long period of inactivity. The wire transfers appear to originate from legal sources. To assess the potential of terrorist financing, the institution must ensure the
- A. account holder does not reside in a country included on the U.S. State Department State Sponsors of Terrorism List.
- B. beneficiaries of transfers are not on a terrorist watch list.
- C. beneficiaries of transfers are not included on the Transparency International List.
- D. account holder presents proof the funds are legal.
正解：B
解説：
This is the correct answer because the institution must ensure that the beneficiaries of the transfers are not on a terrorist watch list, such as the United Nations Security Council Consolidated List, the U.S. Treasury Office of Foreign Assets Control (OFAC) Specially Designated Nationals and Blocked Persons List, or the European Union Terrorism List. These lists contain the names of individuals, entities, and groups that are subject to sanctions or other measures due to their involvement or association with terrorism or terrorist financing. The institution must screen the beneficiaries of the transfers against these lists and report any matches or hits to the relevant authorities. Failing to do so may expose the institution to legal, regulatory, or reputational risks, as well as facilitate the financing of terrorism.
References:
* ACAMS CAMS Certification Video Training Course1, Module 3: International AML/CTF Standards, Lesson 3.2: International AML/CTF Standards
* ACAMS CAMS Study Guide, 6th Edition2, Chapter 3: International AML/CTF Standards, Section 3.2:
International AML/CTF Standards, pp. 57-58
* ACAMS CAMS Examination Preparation Seminar, 6th Edition3, Chapter 3: International AML/CTF Standards, Section 3.2: International AML/CTF Standards, Slide 12
質問 # 73
Which reputations risk consequence could a financial entity face for violating AML laws?
- A. Seizure of assets
- B. Loss of high-profile customers
- C. Monetary penalties
- D. Increased audit costs to monitor behavior
正解：C
解説：
According to the Certified Anti-Money Laundering Specialist (CAMS) Manual [1], 6th edition, financial entities that violate Anti-Money Laundering (AML) laws can face several reputational risks such as loss of high-profile customers, seizure of assets, increased audit costs to monitor behavior, and monetary penalties. For example, the US Treasury's Financial Crimes Enforcement Network (FinCEN) imposes civil money penalties on "persons who willfully violate, attempt to violate, conspire to violate, or cause any violation of any provision of the Bank Secrecy Act or its implementing regulations." (CAMS Manual, 6th edition, page 26).
質問 # 74
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