[2025年12月01日] 最新CAMS Certification CAMS7実際の無料試験解答
CAMS Certification CAMS7問題集最新の練習テスト308独特な解答
質問 # 91
In the process of mutual evaluations and subsequent follow-ups used by the Financial Action Task Force (FATF) to assess the quality of various jurisdictions' AML controls, the FATF:
- A. publishes annual reports ranking all member jurisdictions based on their self-assessment of AML controls.
- B. imposes economic sanctions on jurisdictions with lax AML controls to force them to strengthen their controls.
- C. conducts a peer review process whereby member countries assess the AML controls of other jurisdictions and provide recommendations for improvement.
- D. conducts on-site inspections of financial institutions in jurisdictions with lax AML controls to identify deficiencies and recommend improvements.
正解：C
解説：
The FATF conducts mutual evaluations-a peer review process-whereby member countries assess each other's AML/CFT systems. This includes on-site visits and reviews by international experts, with public reports containing recommendations for improvement. The process is not punitive and does not impose sanctions.
"FATF mutual evaluations are peer reviews in which experts from member countries assess another member's AML/CFT system and provide recommendations." (CAMS 6th Edition, International AML/CFT Standards; FATF Methodology, Recommendation 40) References:
CAMS 6th Edition, FATF Mutual Evaluations
FATF Methodology for Assessing Technical Compliance and Effectiveness
質問 # 92
The transaction monitoring system of a bank generated an alert for a car wash client. After making large cash deposits, the client orders international wire transfers.
Which additional circumstances would make the case more suspicious?
- A. The beneficiary of the wire transfers is a foreign company whose shareholders and director are other companies
- B. The wire transfers are for different amounts but with the same beneficiary
- C. The beneficiary of the wire transfer is a resident of a grey-list country
- D. The beneficiary of the wire transfers is a resident of a foreign country bearing the same family name as the business owner
正解：A
解説：
The suspicion increases when the beneficiary is a foreign company whose shareholders and director are other companies, as this can indicate the use of layered corporate structures to obscure the ultimate beneficial owner and conceal illicit fund flows.
質問 # 93
According to the Basel Committee principles, which actions would make a customer identification program at a bank more robust? (Select Two.)
- A. Verifying the identity of a customer with reputable online source documentation
- B. Understanding why a customer has selected a particular financial institution for banking
- C. Understanding the nature and purpose behind a new business opening an account at the bank
- D. Limiting the online activities of a new customer during the first two months
正解：B、C
質問 # 94
The Financial Action Task Force (FATF) routinely publishes a catalogue of jurisdictions requiring enhanced monitoring which is commonly called the:
- A. yellow notice
- B. red notice
- C. white list
- D. grey list
正解：D
質問 # 95
To provide aid in investigating a cross-border money laundering case, a Financial Intelligence Unit (PIU) that is a member of the Egmont Group can:
- A. directly contact financial institutions in another country and share information pertinent to the investigation.
- B. deputize its law enforcement investigators to assist in a material ongoing investigation in another country
- C. assist law enforcement in another country with a material ongoing investigation.
- D. directly contact other FlUs in another country and share information pertinent to the investigation.
正解：D
質問 # 96
The role of FATF-style regional bodies (FSRBs) is to; (Select Three.)
- A. coordinate technical assistance for members in their FSRB jurisdiction
- B. offer mutual evaluation and follow-up processes for members in their FSRB Jurisdiction.
- C. provide AM L/C FT technical assistance needed by members in their FSRB junsdiction.
- D. identify and address any gaps in the AML/CFT policies for members outside of their FSRB jurisdiction.
- E. identify and address the current financial crime trends through the issuance of typologies originating in members outside of their FSRB's Jurisdiction.
- F. set and amend the FATF 40 Recommendations for members in their FSRB jurisdiction.
正解：A、B、C
質問 # 97
An AML compliance officer receives an independent audit report with a number of findings.
An appropriate response to the report would include:
- A. Reperforming the testing for the controls mentioned in the findings to confirm the results of the audit
- B. Defining remedial actions based on the findings' root cause analysis
- C. Assigning responsibility for reviewing the action plan to the board of directors
- D. Drafting detailed action plans for the audit team to execute to close the findings
正解：B
質問 # 98
A compliance officer is completing a case and has determined that the events do not merit filing a suspicious activity report (SAR).
Which of the following should be included in the case notes to justify not filing a SAR? (Choose two.)
- A. Who made the decision not to file the SAR
- B. How much money was involved in the case
- C. How the money flowed through the institution
- D. Why the officer deemed that the case did not merit filing a SAR
- E. When the unusual activity occurred
正解：A、D
解説：
Case notes should document who made the decision and the rationale for not filing the SAR to ensure transparency, support auditability, and demonstrate compliance with regulatory expectations.
質問 # 99
Which of the services provided by Trust and Company Service Providers (TCSPs) present the greatest financial crime risks? (Choose three.)
- A. Promoting the use of complex corporate structures
- B. Using trusts to obscure the identity of beneficial owners
- C. Providing clear procedures to ensure compliance with local tax regulations
- D. Establishing shell companies for holding financial assets
- E. Maintaining accurate and updated beneficial ownership details for all customers registered for their services
正解：A、B、D
解説：
Trust and Company Service Providers (TCSPs) pose the greatest financial crime risks when they use trusts to obscure beneficial ownership, promote complex corporate structures that make tracing ownership difficult, and establish shell companies that can be used to hold and move illicit funds. These activities can facilitate money laundering, tax evasion, and other financial crimes by concealing the true origin and control of assets.
質問 # 100
Which of the following are part of a risk-based approach? (Select Three.)
- A. Choosing and applying effective controls that align with the identified risk levels
- B. Allocating resources equally across all customer segments to ensure fairness
- C. Determining detailed risk profiles for customers based on their activities and relationships
- D. Performing a comprehensive risk assessment to identify customer, transaction, and geographic risks
- E. Focusing monitoring primarily on previously flagged customers while using standard controls for others
正解：A、C、D
解説：
A risk-based approach is central to AML/CFT programs and includes:
* A: Creating detailed risk profiles for customers based on their behaviors and connections.
* C: Applying controls that are tailored to the actual risk (not a one-size-fits-all approach).
* D: Performing a thorough risk assessment, considering customer, transaction, and geographic factors.
"A risk-based approach involves risk profiling, tailored controls, and comprehensive risk assessment across key risk factors." (CAMS 6th Edition, Risk-Based Approach and Risk Assessment) Incorrect:
* B: Monitoring only flagged customers is not sufficient.
* E: Equal allocation of resources ignores differing risk levels.
References:
CAMS 6th Edition, AML Compliance Program
FATF Recommendation 1: Risk-Based Approach
質問 # 101
Common risks and red flags associated with trade finance clients may include: (Choose four.)
- A. fluctuations in the pricing of standard goods and services
- B. invoices with prices that are much higher than market price
- C. account activity that is not consistent with the purpose of the account
- D. transaction structures that appear unnecessarily complex
- E. bills of lading matching the description of goods, quantities, and values with transshipment details justified
- F. trade documents, such as invoices and letters of credit, that are not clearly worded or are in foreign languages
正解：C、D、F
解説：
Trade finance red flags include account activity inconsistent with the account's stated purpose, unnecessarily complex transaction structures, poorly worded or foreign-language trade documents that may obscure details, and invoices with prices significantly above market value, which can indicate trade-based money laundering or fraud.
質問 # 102
Which of the following are included in the 11 Immediate Outcomes outlined in the Financial Action Task Force (FATF) methodology for assessing technical compliance with the FATF Recommendations and the effectiveness of AML/CFT/CPF systems during mutual evaluations? (Select Three.)
- A. Supervisors regulate financial institutions and non-bank financial institutions and their risk-based AML
/CFT programs - B. Those convicted of money laundering offenses are denied access to basic banking services
- C. International cooperation provides actionable information to use against criminals
- D. Money laundering offenses are investigated and criminally prosecuted
- E. Financial intelligence information is collected by authorities and shared with the FATF for further investigation
正解：A、C、D
質問 # 103
Risks associated with real estate transactions include (Select Two.)
- A. cross-border purchases.
- B. purchases in the name of a natural person.
- C. non-financed purchases.
- D. paying true market price for a property.
正解：A、C
解説：
Real estate transactions are vulnerable to ML/TF risks, particularly when there is limited transparency or unusual payment methods:
* Cross-border purchases (A):"Purchases by foreign buyers, especially from high-risk jurisdictions, are a red flag for money laundering in the real estate sector."(CAMS 6th Edition, Real Estate Money Laundering Risks; FATF, Money Laundering and Terrorist Financing through the Real Estate Sector,
2007)
* Non-financed purchases (D):"Non-financed (all-cash) purchases can indicate the introduction of illicit funds into the financial system, bypassing the controls of mortgage lenders."(CAMS 6th Edition, Real Estate ML/TF Risks) Incorrect Options:
* B: Purchasing in the name of a natural person is standard and not inherently risky.
* C: Paying the true market price does not raise ML/TF risk.
References:
CAMS 6th Edition, Chapter: ML/TF Risks in Real Estate
FATF, Money Laundering and Terrorist Financing through the Real Estate Sector (2007)
質問 # 104
When a multinational organization develops its anti-financial crime (AFC) program, what is the most important consideration for ensuring compliance across different jurisdictions?
- A. Applying global AFC and sanctions policies to ensure consistency without the need to adapt to local regulations.
- B. Ensuring group policies and procedures prioritize adherence to US regulations because they are the most influential worldwide.
- C. Ensuring group policies cater to compliance with each country's specific AML and sanctions regulations.
- D. Ensuring sanctions coy on international bodies like the UN because there is no requirement to adhere to local laws.
正解：C
解説：
A global organization must ensure its group policies accommodate compliance with each country's specific AML and sanctions regulations to effectively manage risks across multiple jurisdictions.
質問 # 105
Which control would be most effective as part of a risk-based approach (RBA) to managing AML/CFT risk for a bank established in the EU that also has a branch in a high-risk third country outside of the EU?
- A. Monitor every cross-border transaction in real time, flagging all for enhanced scrutiny due to the country risk level
- B. Fully rely on central beneficial owner registry records in the high-risk third country to determine the ultimate beneficial owners of all customers
- C. Automatically apply enhanced customer due diligence measures to all customers in the high-risk third- country branch regardless of risk level
- D. Apply tailored due diligence measures, based on the level of risk posed by each customer following risk assessment
正解：D
解説：
As part of a risk-based approach, the bank should apply tailored due diligence measures based on the assessed risk level of each customer. This ensures resources are focused where they are most needed, rather than applying uniform enhanced measures to all customers, which can be inefficient and unnecessary.
質問 # 106
Which of the following attributes would enhance an AML program's effectiveness?
- A. Providing basic AML training to all employees
- B. Auditors providing prescriptive guidance and support to the program following a less than satisfactory audit
- C. An AML officer being appointed to the board as a working member of management with increased authority
- D. Providing effective challenge with AML staff and continuous cross-training
正解：D
解説：
Effective AML programs promote aculture of compliance, which includes an environment where staff are empowered to raise concerns, challenge decisions, and continuously improve through cross-functional learning.Providing effective challengeis a supervisory expectation and best practice in institutions that value AML governance integrity.
While AML officer authority (option B) supports oversight, it is not as impactful on daily operational effectiveness as fostering a challenging and adaptive compliance culture.
Reference: ACAMS CAMS Study Guide - 6th Edition, Chapter: AML Program Components - Section:
Culture of Compliance
質問 # 107
Which of the following statements is true regarding the 2012 Financial Action Task Force (FATF) 40 Recommendations and'or 11 Immediate Outcomes?
- A. The 11 Immediate Outcomes are recommendations specific to high-risk jurisdictions requiring enhanced monitoring.
- B. The cornerstone of the 40 Recommendations is the adoption of a risk-based approach by each jurisdiction
- C. The 40 Recommendations have not been updated to reflect the impact of new technology
- D. Each jurisdiction can reach out to the FATF for private access to the interpretive notes to the 40 Recommendations
正解：B
質問 # 108
Which of the following measures can help maintain the independence of BSA/AML compliance staff to ensure effective compliance controls?
- A. Ensuring BSA/AML compliance staff is primarily outsourced
- B. Providing BSA/AML compliance staff a reporting line to compliance or other second line of defense internal control function
- C. Establishing BSA/AML compliance staff reporting to the management of the business line in the first line of defense
- D. Providing BSA/AML compliance staff with a reporting line to the chief financial officer
正解：B
解説：
BSA/AML compliance staff should report to the compliance function or another second line of defense internal control function to maintain independence from business line management, ensuring objective oversight and effective compliance controls.
質問 # 109
Arecruitment manager in the human resources departmentof a bank hasshortlisted a candidate for the position of relationship manager in its private banking division.
Thebank's compliance policyrequiresproper background checksto protect againstfraud and money laundering risks.
Whichresourceswould bemost usefulfor identifying potential negative information regarding the shortlisted candidate? (Select Three.)
- A. Criminal history searches.
- B. Personal references from close associates.
- C. Past employment records.
- D. Internet and public media searches.
- E. Personal resume.
正解：A、C、D
解説：
Financial institutions must conduct thorough background checks on employees in sensitive roles (e.g., private banking) to mitigate fraud, insider trading, and money laundering risks.
Option A (Correct):Past employment records help verify work history and identify any red flags related to prior financial misconduct.
Option D (Correct):Internet and media searches reveal any negative press, regulatory issues, or connections to illicit activity.
Option E (Correct):Criminal history searches help screen for prior convictions related to financial crimes.
Why Other Options Are Incorrect:
Option B (Incorrect):Personal references are less reliable and may not uncover objective risk factors.
Option C (Incorrect):A resume is self-reported and should be verified using independent sources.
Best Practices for Employee Background Screening:
Conduct enhanced due diligence for high-risk roles (e.g., private bankers, compliance officers).
Use reliable background screening tools and legal databases.
Verify employment history and check against regulatory blacklists.
Reference:
FATF Recommendation 18 (Internal Controls & Employee Screening)
Wolfsberg Group Guidance on AML Employee Background Checks
6th EU AML Directive (6AMLD) on Employee Due Diligence
質問 # 110
Which of the following accurately describes the economic, reputational and social consequences of money laundering (ML) and the risks and consequences of violating AFC regulations? (Choose two.)
- A. ML undermines the integrity and stability of financial systems and makes them vulnerable to illegal activity. This can erode investor confidence and hinder economic growth.
- B. When laundered funds flow into legitimate economies, they can be used for illegal purposes, such as funding terrorist activities or organized crime. This distorts resource allocation and undermines development.
- C. When a financial institution (FI) is found to be promoting ML or violating AFC regulations, this can lead to a loss of confidence in the institution and a loss of customers. Interestingly, this scenario might sidestep any legal consequences for the Fl.
- D. Jurisdictions perceived as having insufficient ML measures might be identified as uncooperative or high-risk, potentially facing restricted access to international markets, though economic sanctions by other countries are an unlikely outcome.
正解：A、B
解説：
Money laundering corrodes financial-system integrity, eroding investor confidence and impeding sustainable economic growth.
Illicit funds entering legitimate economies can finance terrorism and organized crime, skew resource allocation, and stifle development.
質問 # 111
Which of the following scenarios warrants enhanced due diligence (EDD)? (Select Three.)
- A. A bank located in a higher risk country trying to establish a correspondent-respondent banking relationship with a bank in a lower-risk country
- B. The current prime minister of a country trying to open a bank account in another country
- C. An individual with a current bank account who resides in one country becoming the ambassador of another country
- D. An existing local league footballer trying to open a bank account with a bank in their local jurisdiction
- E. The former personal secretary to the minister of transport in a low-risk country 25 years ago opening a bank account at a bank in a neighboring low-risk country
正解：A、B、C
質問 # 112
Which collective body of Financial Intelligence Units (FlUs) was formed with an objective to improve Information exchange and sharing mechanisms among member FlUs as well as to support its members by enhancing their capabilities'?
- A. The Organisation for Economic Co-operation and Development (OECD)
- B. The Wolfsberg Group
- C. The International Monetary Fund (IMF)
- D. The Egmont Group
正解：D
質問 # 113
According to the Financial Action Task Force (FATF) report on terrorism financing, charities and nonprofit organizations are often vulnerable to terrorist financing because they: (Select Two.)
- A. Are usually legitimate establishments and will not use the funds collected through donation for the profit of individuals or entities
- B. Enjoy the public trust and have access to considerable sources of funds, and their activities are often cash intensive
- C. Collect donations from various sources, and their primary objective is philanthropy and social wellbeing
- D. Have a global presence that provides a framework for national and international operations and financial transactions that are often in or near areas most exposed to terrorist activity
正解：B、D
質問 # 114
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