CAMS問題集PDFは最新 [2025年最新] 究極な学習ガイド
CAMS試験問題集PDFは更新された問題集でしかも合格保証付き
質問 # 352
Which two steps should a financial institution take when it receives a law enforcement request to keep an account open that may be associated with suspicious or criminal activity? (Choose two.)
- A. Stop filing suspicious transaction reports because law enforcement will be monitoring the account
- B. File a suspicious transaction report on the account owner(s)
- C. Ask for a written request from the law enforcement agency that defines the duration
- D. Maintain account records for at least five years after the request expires
正解：C、D
解説：
Explanation
https://www.fincen.gov/resources/statutes-regulations/guidance/requests-law-enforcement-financial-institutions-
質問 # 353
The compliance officer for a private bank has been tasked with reviewing the procedure for authorized signatories on customer accounts to ensure it is in line with relevant Wolfsberg Anti-Money Laundering Principles for Private Banking.
Which three statements from the procedure are in line with Wolfsberg? (Choose three.)
- A. Where due diligence has been satisfactorily completed on all authorized signers, the responsible private banker may reduce the due diligence performed on the account holder and/or beneficial owner.
- B. The responsible private banker must establish the identity of a holder of general powers over an account (e.g. a signatory for the account) and, as appropriate, verify that identity.
- C. Where the Authorized Signatory is not a lawyer or accountant, due diligence as to the source of funds and wealth of the Authorized Signatory should be undertaken.
- D. The responsible private banker must obtain the necessary documentation establishing the authorized signer's authority to act on behalf of the account holder or beneficial owner (e.g. a Power of Attorney).
- E. If an individual has signing authority over an account but does not act on a professional basis as a manager of funds, the responsible private banker must understand and document the relationship between that authorized singer, the account holder, and, if different, the beneficial owner of the account.
正解：A、D、E
質問 # 354
How should law enforcement obtain documentation from an institution when suspicious activity was identified? (Choose two.)
- A. Pay an employee of the accountable institution to make copies of the documents.
- B. Request copies of the relevant documents from the accountable institution.
- C. Request the documents from the FIU.
- D. Acquire a search warrant to obtain the documents.
- E. Request a Financial Intelligence Unit (FIU) share copies of suspicious transaction reports.
正解：B、C
質問 # 355
When should new business products to evaluated for AML concerns?
- A. At the time of the next enterprise risk assessment
- B. On an annual basis
- C. After they have been implemented so there is empirical data to review
- D. Before they are launched into the market
正解：D
質問 # 356
An anti-money laundering specialist has just developed and implemented an anti-money laundering program. What is the most effective resource to evaluate the effectiveness of the program?
- A. The regulator authorities
- B. A member of senior management
- C. The anti-money laundering specialist
- D. A qualified independent party/auditor
正解：D
質問 # 357
A customer runs an export business for agricultural products. There has been steady growth over the years from sales to the Caribbean region. A sudden increase is noted in this customer's account balances during the last month.
On what grounds should an anti-money laundering specialist prepare a suspicious transaction report?
- A. Travelers checks (cheques) were purchased for trips to a Non-Cooperative Countries and Territories.
- B. Wire transfers are coming from a Financial Action Task Force member country.
- C. The increased activity is due to money order deposits.
- D. The client changed his address without advising the institution.
正解：A
解説：
The customer activity that should trigger a suspicious transaction report is purchasing travelers checks (cheques) for trips to a Non-Cooperative Countries and Territories (NCCTs). This could indicate an attempt to evade currency reporting requirements, avoid sanctions or embargoes, or facilitate money laundering or terrorist financing through high-risk jurisdictions12. NCCTs are countries or territories that have been identified by the Financial Action Task Force (FATF) as having serious deficiencies in their anti-money laundering and counter-terrorist financing regimes, and that pose a threat to the international financial system3.
The other options are not necessarily grounds for a suspicious transaction report, although they may require further due diligence or monitoring depending on the customer profile and the nature of the transaction. For example:
The increased activity is due to money order deposits. This could be a legitimate source of income for the customer's export business, or it could be a way of disguising the origin or destination of the funds. The anti-money laundering specialist should verify the identity and background of the customer and the issuers of the money orders, and check for any red flags or suspicious indicators4.
Wire transfers are coming from a Financial Action Task Force member country. This could be a normal business practice, or it could be a sign of involvement in trade-based money laundering or other illicit activities. The anti-money laundering specialist should assess the customer's source of funds, business rationale, and market conditions, and monitor for any changes or inconsistencies.
The client changed his address without advising the institution. This could be a simple oversight, or it could be a way of concealing the customer's true location or identity. The anti-money laundering specialist should update the customer's information, verify the new address, and check for any adverse media or sanctions.
References:
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 1, page 11:
https://www.acams.org/wp-content/uploads/2019/08/ACAMS-Study-Guide-6th-Edition-Chapter-1.pdf 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 4, page 77:
https://www.acams.org/wp-content/uploads/2019/08/ACAMS-Study-Guide-6th-Edition-Chapter-4.pdf ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 5, page 97:
https://www.acams.org/wp-content/uploads/2019/08/ACAMS-Study-Guide-6th-Edition-Chapter-5.pdf
質問 # 358
Which three actions should employees be instructed to do during an internal investigation?
- A. Provide corporate documents directly to law enforcement
- B. Inform counsel of all request for documentation
- C. Make copies of all documents provided to law enforcement
- D. Keep a log of the documents requested
正解：B、C、D
解説：
During an internal investigation, employees should be instructed to do the following actions:
Inform counsel of all request for documentation: This is to ensure that the legal rights and obligations of the organization and the employees are protected and respected. Counsel can also advise on the scope, relevance, and confidentiality of the requested documents1.
Make copies of all documents provided to law enforcement: This is to maintain a record of the information that has been disclosed and to prevent any loss or alteration of the original documents. Copies should be made before the documents are handed over to law enforcement2.
Keep a log of the documents requested: This is to track the progress and status of the investigation and to avoid any duplication or omission of the requested documents. The log should include the date, time, description, and location of the documents, as well as the name and contact details of the person who requested and received them3.
Providing corporate documents directly to law enforcement, on the other hand, is not an action that employees should be instructed to do during an internal investigation. This is because law enforcement may not have the legal authority or the proper warrant to access the documents, and doing so may violate the privacy or confidentiality of the organization or the employees. Employees should consult with counsel before providing any documents to law enforcement4.
References:
1: Internal money laundering reporting | The Law Society5 2: How to Conduct Effective AML Investigations - Blog | Unit212 3: What Is The Importance Of An Internal Investigation?4 4: Anti-Money Laundering: 5 Steps to Conduct an Audit3
質問 # 359
A New York-based lawyer is interested in purchasing a luxury condo in Manhattan listed at $30 million for a client based in the Caribbean.
The client does not want to be named on the deed and wants the purchase to be made under the name of a limited liability company (LLC). The client states that the reason for this arrangement is that he is a high level government official who is concerned about his privacy if the purchase were to be made in his name.
The funds for the purchase are to be wired from several accounts in various countries.
Which two facts lead to gathering more information about this potential client before moving forward with the transaction? (Choose two.)
- A. The client is from a Caribbean country
- B. The client is a high level government official
- C. The funds are coming from several accounts in various countries.
- D. The use of an LLC to make the purchase
正解：B、C
質問 # 360
You have a database that contains sales data.
You plan to process the sales data by using two data streams named Stream1 and Stream2. Stream1 will be used for purchase order data. Stream2 will be used for reference data.
The reference data is stored in CSV files.
You need to recommend an ingestion solution for each data stream.
What two solutions should you recommend? Each correct answer is a complete solution.
NOTE: Each correct selection is worth one point.
- A. an Azure event hub for Stream1 and Azure Blob storage for Stream2
- B. Azure Cosmos DB for Stream1 and an Azure event hub for Stream2
- C. an Azure event hub for Stream1 and Stream2
- D. Azure Blob storage for Stream1 and Stream2
- E. Azure Blob storage for Stream1 and Azure Cosmos DB for Stream2
正解：A、D
解説：
Stream1 - Azure Event
Stream2 - Blob Storage
Azure Event Hubs is a highly scalable data streaming platform and event ingestion service, capable of receiving and processing millions of events per second. Event Hubs can process and store events, data, or telemetry produced by distributed software and devices. Data sent to an event hub can be transformed and stored using any real-time analytics provider or batching/storage adapters. Event Hubs provides publish- subscribe capabilities with low latency at massive scale, which makes it appropriate for big data scenarios.
Stream1, Stream2 - Blob Storage
Stream Analytics has first-class integration with Azure data streams as inputs from three kinds of resources:
Azure Event Hubs
Azure IoT Hub
Azure Blob storage
These input resources can live in the same Azure subscription as your Stream Analytics job or a different subscription.
References:
https://docs.microsoft.com/en-us/azure/architecture/data-guide/technology-choices/real-time-ingestion
質問 # 361
Upon filing a suspicious transaction report, which of th€ following elements should be the highest anti-money laundering priority in making the decision to keep the account open?
- A. Financial impact on the institution if the account is closed.
- B. Procedures to ascertain the potential risk to the organization.
- C. Total number of accounts the institution closed in the last month.
- D. Additional Administrative costs of monitoring the account.
正解：B
解説：
According to the CAMS Certification Package - 6th Edition1, the decision to keep or close an account after filing a suspicious transaction report (STR) should be based on a risk-based approach that considers the nature and severity of the suspicious activity, the customer profile and relationship, the regulatory and legal obligations, and the reputational and operational risks for the institution. The financial impact, the administrative costs, and the number of accounts closed are not the primary factors in determining the appropriate course of action. Therefore, the correct answer is B. Procedures to ascertain the potential risk to the organization.
References:
* CAMS Certification Package - 6th Edition1, Chapter 5: Risk Management, Section: Account Closure, pp. 211-212.
質問 # 362
Which measure to mitigate risk does the Basel Committee's Customer Due Diligence Principles suggest banks apply when accepting business from non-face-to-face customers?
- A. Requiring an in person interview with the customer
- B. Requiring additional review of account opening documents by senior management
- C. Certification of documents presented
- D. Imposing a limit on permissible account activity for a defined period of time
正解：C
解説：
Reference: https://books.google.com.pk/books?
id=gy8qBAAAQBAJ&pg=PA219&lpg=PA219&dq=measure+to+mitigate+risk+does+the+Basel+Committee+C face-to- face+customers&source=bl&ots=f52JnPYdW4&sig=ACfU3U2egwrWQj86a6eLQQ3Ew4EcR2bSVQ&hl=en&s
20to%20mitigate%20risk%20does%20the%20Basel%20Committee%20Customer%20Due%20Diligence%
20Principles%20suggest%20banks%20apply%20when%20accepting%20business%20from%20non-face-to- face%20customers&f=false
質問 # 363
Which two steps should a financial institution take when it receives a law enforcement request to keep an account open that may be associated with suspicious or criminal activity? (Choose two.)
- A. Stop filing suspicious transaction reports because law enforcement will be monitoring the account
- B. File a suspicious transaction report on the account owner(s)
- C. Ask for a written request from the law enforcement agency that defines the duration
- D. Maintain account records for at least five years after the request expires
正解：C、D
質問 # 364
Which action should financial institutions with cross border correspondent banking activity be required to perform according to the Financial Action Task Force 40 Recommendations?
- A. Obtain a third party independent review of the respondent's anti-money laundering program
- B. Identify natural persons who own or control more than 5%
- C. Gather a list of their politically exposed customers
- D. Obtain senior management approval before establishing the relationship
正解：D
解説：
Explanation/Reference: https://www.fatf-gafi.org/media/fatf/documents/recommendations/pdfs/FATF%
20Recommendations%202012.pdf (15)
質問 # 365
During the course of work on behalf of a client, a lawyer participated in the movement of money. If the lawyer suspects an act of money laundering, which of the following should the lawyer do according to European Union Money Laundering Directives?
- A. Adhere to business confidentiality laws.
- B. Inform the client of the intent to terminate services.
- C. Follow bank secrecy laws.
- D. Report the facts to the competent authorities.
正解：A
解説：
According to the FATF Recommendations, financial institutions should maintain all necessary records on transactions and customers for at least five years, and make them available to competent authorities upon appropriate authority1. This includes records and documents related to suspicious transactions that have been reported to the financial intelligence unit (FIU) or other designated authorities. Providing the supporting documentation to competent authorities upon request is essential for the investigation and prosecution of money laundering and terrorist financing offences, as well as for the identification and tracing of criminal assets2.
Hinting to the customer that she should come in and explain her behavior is not a correct answer, as it may tip off the customer about the suspicion and compromise the effectiveness of the reporting system. Financial institutions should not disclose to the customer or to third parties that a suspicious transaction report (STR) or related information is being reported to the FIU3.
Maintaining adequate written documentation of all individuals and transactions reported is not a sufficient answer, as it does not imply cooperation with competent authorities. Financial institutions should not only keep records, but also provide them to the authorities when requested.
Submitting information upon receiving a legal request from parties involved in a civil lawsuit is not a relevant answer, as it does not relate to the cooperation with competent authorities for AML/CFT purposes. Civil lawsuits are not part of the AML/CFT framework, and financial institutions should not disclose confidential information to private parties without proper legal grounds.
References:
* FATF Recommendation 11: Record-keeping 1
* FATF Recommendation 31: Powers of law enforcement and investigative authorities 2
* FATF Recommendation 21: Tipping-off and confidentiality 3
質問 # 366
Why is the Mutual Legal Assistance Treaty (MLAT) a gateway for international cooperation?
- A. They receive reports of suspicious transactions from financial institutions to disseminate to local Law enforcement and foreign FIUs
- B. They issue the Prmc4es of Information Exchange Between Financial intelligence Units (FIUs)
- C. They provide a legal basis for transmitting evidence that can be used for prosecution and judicial proceedings
- D. They obtain intelligence that might lead to evidence
正解：C
解説：
A Mutual Legal Assistance Treaty (MLAT) is an agreement between two or more countries for the purpose of gathering and exchanging information in an effort to enforce public or criminal laws1. MLATs provide a legal basis for transmitting evidence that can be used for prosecution and judicial proceedings, such as witness statements, bank records, search and seizure orders, and asset forfeiture2. MLATs also facilitate the cooperation and coordination between law enforcement authorities of different jurisdictions in investigating and prosecuting transnational crimes, such as money laundering, terrorist financing, corruption, and cybercrime3. The other options are incorrect because:
* B. MLATs do not receive reports of suspicious transactions from financial institutions, but rather request specific information or evidence from foreign authorities. Financial institutions report suspicious transactions to their domestic Financial Intelligence Units (FIUs), which may then share the information with foreign FIUs through other mechanisms, such as the Egmont Group or bilateral agreements4.
* C. MLATs do not obtain intelligence that might lead to evidence, but rather request evidence that is already available or can be obtained by foreign authorities. Intelligence is a broader term that refers to any information that is relevant to the security or interests of a country, and may not be admissible as evidence in a court of law5. Intelligence may be obtained through other means, such as covert operations, surveillance, or informants6.
* D. MLATs do not issue the Principles of Information Exchange Between Financial Intelligence Units (FIUs), but rather follow them. The Principles of Information Exchange are a set of guidelines that were adopted by the Egmont Group of FIUs in 2001, and aim to enhance the cooperation and communication among FIUs in exchanging financial information and intelligence7. The Principles of Information Exchange are not legally binding, but rather reflect the best practices and standards of the FIU community.
References:
* 1: Mutual legal assistance treaty - Wikipedia
* 2: FREQUENTLY ASKED QUESTIONS REGARDING LEGAL ASSISTANCE IN CRIMINAL
MATTERS, page 1
* 3: The Mutual Legal Assistance Problem explained | wilmap
* 4: ACAMS, CAMS Certification Package - 6th Edition, Chapter 4, page 125
* 5: Intelligence - Wikipedia
* 6: Intelligence cycle - Wikipedia
* 7: Egmont Group of Financial Intelligence Units - Wikipedia
* : Principles for Information Exchange Between Financial Intelligence Units for Money Laundering and Terrorism Financing Cases
質問 # 367
How should a compliance program respond to an AML audit finding?
- A. By giving recommendations for each finding as part of an audit report
- B. By nominating an independent party to implement the corrective action
- C. By closing the accounts that were subject to findings
- D. By using the findings to identify and assess their money laundering risk
正解：D
解説：
An AML audit is a process of evaluating an organization's compliance with AML regulations and best practices. The audit report should provide feedback on the strengths and weaknesses of the organization's AML program and identify any gaps or deficiencies that need to be addressed. The compliance program should use the audit findings as an opportunity to improve its AML risk management and internal controls, and to implement corrective actions as needed. The audit findings should not be ignored or dismissed, but rather used as a tool to enhance the organization's AML compliance performance and effectiveness.
References:
1: This web page explains what an AML compliance program is, why it is important, and what are the key components of an effective program. It also states that an AML compliance program should involve a regular review of the internal controls and systems used to detect and report financial crime, and measure their effectiveness in meeting compliance standards.
2: This blog post provides an overview of the importance and steps of an AML audit, and how to perform one effectively. It also suggests that an AML audit is a starting point to strengthen and improve the AML program, and that the insights from the audit should prompt action by the compliance team to address the deficiencies discovered.
3: This blog post discusses the best practices for AML audit compliance, and emphasizes the need for an ongoing testing process, including the audit, to keep the AML program current and effective. It also recommends effective communication among all employees who follow the program and procedures.
質問 # 368
A bank compliance officer has implemented enhanced monitoring rules that have identified some unusual activity that may be indicative of human trafficking.
Which red flag should prompt additional transactional review?
- A. Cash deposits that occur in cities where the customer resides and conducts business
- B. Cash deposits that occur in cities where the customer does not reside or conduct business
- C. Wire transfer activity from countries with significant migrant populations
- D. Cash deposits that occur in cities where the customer does not reside or conduct business followed by same-day withdrawals
正解：D
解説：
A customer's account appears to function as a funnel account whereby cash deposits occur in cities/states where the customer does not reside or conduct business. Frequently, in the case of funnel accounts, the funds are quickly withdrawn (same day) after the deposits are made
質問 # 369
A law enforcement agency is reviewing a suspicious transaction report (STR) filed by a financial institution for suspicious activity on a client's account. Subsequently, the agency requests further information.
Which supporting documentation might the law enforcement agency request from the institution to facilitate its investigation?
- A. Previously filed STRs on the same customer
- B. Account opening documents and account statements
- C. Copies of promotional materials sent to the customer
- D. A copy of the institution's STR policy and procedures
正解：B
解説：
A law enforcement agency may request account opening documents and account statements from the institution to facilitate its investigation of a suspicious transaction report (STR). These documents can provide valuable information about the identity, background, source of funds, and transaction patterns of the customer, as well as any red flags or anomalies that may indicate money laundering or other criminal activities. Account opening documents may include identification documents, verification documents, customer due diligence forms, risk assessment forms, etc. Account statements may include transaction details, balances, fees, charges, etc.
References:
ACAMS, CAMS Examination Study Guide, 6th Edition, Chapter 4, pp. 115-116 FATF Guidance: The Role of Hawala and Other Similar Service Providers in Money Laundering and Terrorist Financing, October 20131, p. 20 Basel Committee on Banking Supervision, Sound management of risks related to money laundering and financing of terrorism, June 20172, p. 11
質問 # 370
The board of directors receives notice from the primary regulator of the bank that potentially suspicious activity has been identified and the bank president appears to be involved. The Board asks the compliance officer for advice.
Which action should the compliance officer take when informed?
- A. Inform the bank's legal counsel and follow their instructions
- B. Inform the president of the regulator's suspicions and ask for his advice
- C. Insist on the president's immediate resignation
- D. Destroy all records relating to the matter
正解：A
質問 # 371
What is an aspect of the USA PATRIOT Act that has extraterritorial reach?
- A. To strengthen US measures to prevent, detect and prosecute international money laundering and financing of terrorism.
- B. To mandate stricter money laundering controls across the continent.
- C. To implement economic and trade sanctions based on US foreign policy.
- D. To require scrutiny of foreign financial institutions (FIs) and classes of international transactions that are susceptible to criminal abuse.
正解：D
解説：
The USA PATRIOT Act, enacted in 2001, is a comprehensive legislation that aims to enhance the US government's ability to combat terrorism, money laundering, and other criminal activities. One of the aspects of the Act that has extraterritorial reach is the requirement for US financial institutions (FIs) to apply certain due diligence and reporting obligations to their correspondent accounts and private banking accounts for foreign FIs and non-US persons, respectively12. These obligations are intended to prevent foreign FIs and individuals from using the US financial system to facilitate money laundering, terrorist financing, or other illicit activities. The Act also authorizes the Secretary of the Treasury to impose special measures, such as recordkeeping, reporting, or prohibitions, on certain foreign jurisdictions, FIs, or transactions that are found to be of primary money laundering concern34. These special measures can have significant impact on the access and operations of foreign FIs and persons in the US financial market.
References:
* 1: USA PATRIOT Act, Title III, Subtitle A, Section 3121
* 2: 31 CFR 1010.610 - Due diligence programs for correspondent accounts for foreign financial institutions2
* 3: USA PATRIOT Act, Title III, Subtitle A, Section 3113
* 4: 31 CFR 1010.651 - Imposition of special measure against foreign jurisdictions, foreign financial institutions, classes of international transactions, or types of accounts of primary money laundering
* concern4
Reference: https://www.fincen.gov/resources/statutes-regulations/usa-patriot-act
質問 # 372
......
CAMS認定は、AMLの専門家の知識とスキルの向上に専念する最大の国際会員組織である認定対応洗濯スペシャリスト協会（ACAM）によって所有および管理されています。 ACAMS CAMS認定試験は、AML認定のゴールドスタンダードとして世界的に認識されており、規制当局、法執行機関、および金融機関によって非常に尊敬されています。
あなたを合格させるACAMS試験にはCAMS試験問題集：https://www.passtest.jp/ACAMS/CAMS-shiken.html
CAMS試験問題集でACAMS練習テスト問題：https://drive.google.com/open?id=1WHmG82s4sUP5VCe768SneTGZUfT2kOXA