合格させるACAMS Advanced-CAMS-Auditテスト問題でテストエンジンとPDFを提供中
あなたをお手軽にAdvanced-CAMS-Audit試験合格させるリアルAdvanced-CAMS-Audit練習問題集で更新されたのは2025年03月29日
質問 # 14
Which are the most important documents for an auditor to verify that a financial institution has proper controls in place for mitigating its money laundering risk exposure? (Select Two.)
- A. List of politically exposed persons
- B. Internal controls including policies and procedures
- C. Management action plan for remediating audit findings
- D. Money laundering risk assessment
- E. Log of law enforcement requests
正解：B、D
解説：
Importance of Risk Assessment and Controls:
* A money laundering risk assessment identifies inherent risks and vulnerabilities the institution faces, forming the foundation for mitigation efforts.
* Internal controls, including policies and procedures, are critical to operationalize the risk assessment and ensure compliance with AML requirements.
Irrelevant Options:
* C:A management action plan is remedial, not preventive.
* D:The list of PEPs is specific to high-risk individuals, not the institution's overall risk framework.
* E:Law enforcement logs provide insight into reactive measures but not ongoing control adequacy.
質問 # 15
A financial institution is auditing its correspondent banking relationships and their respective sanctions compliance programs. Which condition will merit a higher sample size assuming the correspondent banks have a moderate level of risk mitigation?
- A. A well-known customer base m a localized environment
- B. A customer base changing due to a merger in the domestic market
- C. A stable customer base in an international environment
- D. A fluctuating customer base in an international environment
正解：D
解説：
Higher Sample Size Justification:
* A fluctuating international customer base increases the complexity of correspondent banking relationships and sanctions compliance, necessitating a larger sample to assess risks effectively.
Irrelevant Options:
* B and D:Stable or localized environments reduce complexity, lowering sample size needs.
* C:Domestic mergers affect customer risk profiles but are less volatile than fluctuating international markets.
質問 # 16
Which should the external auditor recommend to ensure that the institution did not facilitate transactions involving a sanctioned person?
- A. Perform a security risk and access assessment on the sanction screening tool to ensure more timely sanctions lists are uploaded.
- B. Re-screen all transactions over the period of time when the updated sanction lists were not uploaded against the current sanctions lists.
- C. Periodically monitor the sanctions lists uploaded by the screening tool to ensure the most up-to-date lists are in the system.
- D. Re-screen all transactions based on the sanctions lists that were active at that time but not uploaded.
正解：B
解説：
Recommended Action:
* Re-screening ensures compliance with sanctions and identifies potential violations retrospectively. This is a critical regulatory requirement for addressing gaps in screening coverage.
FATF and Basel Guidelines:
* Emphasize retrospective reviews in cases of system lapses to maintain the integrity of the sanctions compliance program.
質問 # 17
in addition to this investigation report, what Information should the auditor expect to find in the investigative file? (Select Two.)
- A. Independent review by the compliance officer's line manager.
- B. Adverse news search results against the customers and its controlling persons.
- C. Historical transaction data of the customer s account.
- D. Policies and procedures relating to AML investigations and suspicious activity report filing.
- E. Board approval for the suspicious activity report filing by the compliance department.
正解：B、C
解説：
Adverse news provides context on potential risks associated with the customer, while historical transaction data is critical for understanding patterns that may indicate suspicious activity.
質問 # 18
When assessing the KYC process which should an auditor observe from the customer risk assessment? (Select Two)
- A. The purpose and intended nature of the business relationship were not reviewed m the assessment.
- B. If this was a face-to-face customer, the overall customer risk rating should be changed to low.
- C. Self-declaration or Beneficial ownership should not be accepted as it is not adequate.
- D. Overseas shareholders not involved in the customer's dally operations are not beneficial owners.
- E. The ultimate beneficial owners of the customer need to be Identified and verified.
正解：A、E
解説：
C:The purpose and intended nature of the business relationship are fundamental elements of customer due diligence (CDD) and should be reviewed in the risk assessment process to understand the rationale behind the customer's activities and their alignment with expected patterns.
D:Identifying and verifying the ultimate beneficial owners (UBOs) is a core principle of the KYC process to ensure transparency and mitigate risks related to hidden ownership or illicit activities.
質問 # 19
A financial institution (FI) recently updated its transaction monitoring (TM) thresholds During validation which should be provided as evidence of optimized thresholds'? (Select Two.)
- A. Proof of validation from the TM software provider
- B. Comparison against past suspicious activity reported
- C. Above-the-line and below-the-line testing
- D. A copy of the FI's AML risk assessment
- E. Length of time the FI has deployed the software program
正解：B、C
解説：
Comparison Against Past Suspicious Activity Reported:
* This evaluates whether the new thresholds are identifying similar or improved patterns of suspicious activity compared to prior thresholds.
* Helps validate that the updated thresholds align with the institution's AML risk profile and regulatory expectations.
Above-the-Line and Below-the-Line Testing:
* Above-the-line tests verify that alerts generated by the thresholds include expected suspicious transactions.
* Below-the-line tests assess transactions below the threshold to ensure no significant suspicious activities are missed.
CAMS-Audit Reference:
* Advanced CAMS-Audit frameworks emphasize the importance of both historical comparison and robust testing methodologies to validate transaction monitoring system updates.
質問 # 20
What type of audit approach should the auditor use when testing KYC files as part of an AML examination?
- A. Horizontal
- B. Risk-based
- C. Vertical
- D. Full scope
正解：C
解説：
Understanding the Vertical Approach:
* A vertical audit focuses on reviewing the entire process or function within a single area or department, such as testing KYC files for compliance and effectiveness in a specific customer group or business line.
Application in AML Examinations:
* Vertical audits are particularly useful for examining KYC processes as they allow auditors to trace the end-to-end workflow, from customer onboarding to risk assessment and ongoing monitoring.
Alignment with Advanced CAMS-Audit Guidelines:
* The vertical approach provides detailed insights into compliance gaps within the KYC function, helping auditors identify root causes and systemic issues, which is emphasized in CAMS-Audit training.
質問 # 21
What is the role of the internal audit in the governance process?
- A. Execute the corrective action plan.
- B. Perform quality assurance testing of transaction monitoring.
- C. Monitor the risks of noncompliance with applicable laws and regulations.
- D. Periodically evaluate the effectiveness of processes and controls.
正解：D
解説：
Role of Internal Audit:
* Internal audit is tasked with evaluating and improving the effectiveness of governance, risk management, and control processes within the organization.
* Periodic evaluations ensure that AML/CFT processes remain robust and effective against emerging risks.
Alignment with CAMS-Audit Guidance:
* Advanced CAMS-Audit training highlights the need for internal audit to focus on process effectiveness rather than operational responsibilities, such as quality assurance or corrective actions.
質問 # 22
Findings from a financial institution's (Fl's) regulatory examination suggest that several unidentified risks pose a serious threat. The Fl identifies the risks and implements a set of controls to mitigate those risks.
Which type of risk considers the controls' effectiveness?
- A. Consolidated
- B. Inherent
- C. Residual
- D. Aggregate
正解：C
解説：
Definition of Residual Risk:
* Residual risk is the risk that remains after controls are implemented to mitigate inherent risks.
* It reflects the effectiveness of controls and highlights areas requiring further attention.
Relevance in Risk Management:
* Evaluating residual risk helps determine whether existing controls adequately address the identified risks.
CAMS-Audit Best Practices:
* Auditors must assess residual risk as part of the broader risk management framework to ensure regulatory compliance and operational resilience.
質問 # 23
Which key risk indicator should the internal auditor consider when reviewing correspondent banking activities?
- A. Volume of transaction activity referred by the respondent bank.
- B. Number of respondent banks located in higher risk jurisdictions.
- C. Number of correspondent banking relations terminated.
- D. Size and stature of a respondent bank's operations in its home country.
正解：B
解説：
Correspondent banking relationships with banks in high-risk jurisdictions are a key risk indicator, as these relationships often pose greater AML/CFT risks due to regulatory or operational deficiencies in those jurisdictions.
質問 # 24
When reviewing an AML policy, an auditor should expect to find that the policy.
- A. contains items related to staff training.
- B. is aligned with investment strategy.
- C. was reviewed and approved by the money laundering reporting officer.
- D. has been approved by regulators.
正解：A
解説：
AML Policy Expectations:
* Staff training is a fundamental component of an effective AML program. FATF Recommendations and Basel Committee guidelines require AML policies to address staff training to ensure compliance with AML/CFT laws
質問 # 25
If a final audit communication contains a significant error, the chief audit executive must:
- A. recall the audit report assess the error and resubmit the correct one.
- B. report the error to the local AML regulator.
- C. tell those who received the communication of the error and corrections.
- D. reevaluate the item(s) and resubmit findings for discussion on factualaccuracy.
正解：A
解説：
A significant error in an audit report undermines the credibility of the findings. The appropriate action is to recall the report, reassess the error, and submit an accurate report to stakeholders. This ensures integrity and compliance with audit standards.
質問 # 26
A retail banking small and medium-sized enterprise (SME) customer launches a charity and requests a Corporate-SME account to receive donations and make disbursements. Which scenarios would most likely identify activity related to a charity account?(Select Two.)
- A. Scenario 5
- B. Scenario 6
- C. Scenario 4
- D. Scenario 1
- E. Scenario 7
正解：D、E
解説：
Scenario 1: Evaluates unusual activity, such as large, unexplained deposits or withdrawals, which are red flags in charity-related accounts .
Scenario 7: Exads to detect inconsistencies with the stated purpose, ensuring adherence to AML standards for NPOs.
質問 # 27
An auditor is writing the scope for an AML review of a financial institution. The objective is to evaluate how effectively existing controls are designed and operating. Which areas should be assessed? (Select Two.)
- A. Client base stability
- B. Previous correspondent banking relationships
- C. Clients of the institution for more than 10 years
- D. AML corporate governance
- E. Recent audit findings
正解：D、E
解説：
Recent Audit Findings:
* Reviewing past findings ensures the institution has addressed previous deficiencies and allows the auditor to assess the effectiveness of implemented corrective actions.
AML Corporate Governance:
* Corporate governance is a critical component of AML compliance, involving oversight structures, policies, and accountability mechanisms to prevent money laundering risks.
Alignment with CAMS-Audit Principles:
* Advanced CAMS-Audit emphasizes evaluating governance structures and learning from recent audits to maintain robust AML controls.
質問 # 28
As an auditor reviewing this investigation report, which indicates an effective process?
- A. The compliance officer decided not to cease the Business relationship hut kept the account under rigorous monitoring process.
- B. The compliance officer concluded from the report that there are reasonable grounds for suspicion and filed a suspicious activity report.
- C. The compliance officer filed a suspicious activity report and omitted details regarding the reason it was filed.
- D. The compliance officer concluded the investigation approximately 3 months later and filed a suspicious activity report.
正解：B
解説：
Filing an SAR based on reasonable grounds for suspicion ensures compliance with AML obligations and demonstrates the effectiveness of the investigative process.
質問 # 29
Which should be requested from a financial institution (FI) prior to beginning a data integrity review?
- A. A report from the AML system showing the import of transactional data
- B. The FI's AML risk assessment
- C. An end-to-end diagram that depicts core elements such as source systems and data flows
- D. A document from the vendor confirming the data integrity of the AML system's software
正解：C
解説：
Data Integrity Review:
* An end-to-end diagram provides a comprehensive view of data sources, flows, and integrity checkpoints, enabling auditors to assess the completeness and accuracy of transactional data in AML systems.
Importance of Visual Representation:
* FATF and Basel guidelines stress the need for clarity in data flows to ensure accurate monitoring and reporting of suspicious activities.
質問 # 30
Independent testing of the New York branch of a foreign bank is conducted by an outsourced audit firm. The independent testing report should be submitted to which authority in order to provide appropriate level of governance and oversight?
- A. Bank's designated board committee at the head office
- B. Main office risk management committee
- C. Compliance oversight committee of the New York branch headed by the chief compliance officer
- D. New York branch regulatory compliance committee headed by the chief incumbent of the branch
正解：A
解説：
Reporting to the Head Office Board Committee:
* Independent testing reports must be submitted to the highest governance body to ensure proper oversight and alignment with global AML/CFT policies.
* This ensures that findings are addressed at the appropriate organizational level.
CAMS-Audit and FATF Guidelines:
* Governance frameworks outlined in CAMS-Audit and FATF recommendations emphasize the importance of board-level oversight for critical compliance functions
質問 # 31
Which action would an auditor take to evaluate design effectiveness?
- A. Carry out a sample check of suspicious activity reports and make sure they are in line with policies and procedures.
- B. Confirm that alerts in transaction monitoring have been properly escalated or waived.
- C. Check whether the policies and procedures are consistent with the authorities' regulations.
- D. Confirm that customer records are being kept in accordance with policies and procedures.
正解：C
解説：
* Explanation:Evaluating design effectiveness involves determining whether policies and procedures align with regulatory standards, which sets the foundation for a compliant AML/CFT program. This is a design-level assessment rather than testing implementation or outcomes, which would pertain to operational effectiveness.
質問 # 32
An audit manager identifies that a financial institution (Fl) has not produced a business-level risk assessment in accordance with policy. The senior manager of the Fl assures that assessing risk at the individual client level and aggregating the data is an acceptable approach. How should the audit manager proceed?
- A. Issue a finding that requires the completion of a business-level risk assessment.
- B. Test the accuracy of the mathematical aggregation of the risk assessments.
- C. Accept the risk conclusions provided by the senior manager.
- D. Discuss with the senior manager to establish the risk appetite.
正解：A
解説：
Importance of Business-Level Risk Assessments:
* Aggregating client-level risk assessments does not replace a comprehensive business-level risk assessment, which is required for holistic risk management.
Audit Manager's Responsibility:
* The absence of a business-level risk assessment constitutes a policy violation and must be formally addressed through a finding.
CAMS-Audit Guidelines:
* CAMS-Audit emphasizes the need for layered risk assessments, including enterprise-wide evaluations, to comply with regulatory standards.
質問 # 33
Which are methods to test internal controls related to the CDD and KYC process? (Select Two.)
- A. Confirm with client onboarding teams whether or not high-risk customers exist.
- B. Review the accuracy of the gap analysis of the CDD and KYC policies and procedures against local regulations.
- C. Ask the account officers whether the CDD and KYC information provided is correct.
- D. Evaluate the results of the sample testing of new and existing customer relationships for adherence to the CDD and KYC process.
- E. Confirm if suspicious activity reports were filed following escalation for non-compliance with the CDD and KYC process.
正解：B、D
解説：
Testing Internal Controls:
* C. Gap Analysis: Ensures policies are compliant with local regulations and address identified risks.
* D. Sample Testing: Verifies that processes are effectively implemented in practice for both new and existing customers.
質問 # 34
During the auditing process the auditor finds that the entity never updates the customers risk assessment.
Which remediation actions should the auditor suggest? (Select Two.)
- A. The business updates the customer risk profiles periodically in accordance with the customer risk level.
- B. Management engages an independent third party to update all the customer risk profiles.
- C. Delete non-active customer profiles to reduce the workload of ongoing surveillance.
- D. Compliance regularly updates the lists of high- and medium-risk countries to ensure updated customer risk profiles.
- E. Audit designates an audit manager to review customer profiles annually.
正解：A、D
解説：
A:Regularly updating lists of high- and medium-risk countries ensures that customer risk profiles align with the most current geopolitical and economic risks.
E:Periodic updates to customer risk profiles, based on their assigned risk level, are critical for maintaining an accurate and dynamic risk assessment system.
質問 # 35
During the interview, the local director informs the audit manager that no internal or regulatory audits have occurred since the local director's appointment The local director relies on a locally-approved independent external review of Company A performed 12 months ago by a local firm How should the audit manager respond?
- A. Validate the accuracy of content of the independent external review report by recommending an audit and assess if the findings of both the independent review and audit are similar.
- B. Rely upon the independent external review report as the base to formulate conclusions of the current onsite visit by internal audit.
- C. Review the independent external review report to determine the extent to which reliance can be placed on it and identify matters requiring further review by internal audit.
- D. Advise the group board that the group should set aside the external review reports as the use of the third party independent reviewer was not authorized at group board level.
正解：C
解説：
Steps to Assess the External Review Report:
* Validate the scope, methodology, and findings of the external review to determine its adequacy and reliability.
* Identify any gaps or areas that require additional scrutiny by internal audit.
Rationale for Review Instead of Reliance:
* Relying solely on external reviews without validation risks overlooking key compliance deficiencies.
Internal audit must establish an independent assessment to corroborate findings.
CAMS-Audit Recommendations:
* CAMS-Audit stresses the importance of critical evaluation of third-party reports and ensuring internal audit findings align with organizational compliance priorities
質問 # 36
The company has automated the completion of the customer risk assessment (CRA) into its main customer relationship management (CRM) system The CRM has needs recording the overall risk level assessed (Standard. Enhanced), the ID number of the staff member who completed the assessment, and me date of the last assessment Which additional fields should the auditor recommend to document the CRA process? (Select Three.)
- A. Age (Years)
- B. Annual premium (S)
- C. Type of customer (Trust. Company Individual)
- D. Photo ID taken (Passport Driver's License. Other)
- E. Risk factors (Y/N. if Y please specify)
- F. Residence (Country)
正解：C、E、F
解説：
Enhancements to the CRA Process:
* Risk Factors:Identify and document specific risk indicators for transparency and consistent assessment. This ensures alignment with the risk-based approach advocated by FATF.
* Type of Customer:Differentiating customer types (trust, company, individual) is critical for tailoring due diligence measures to the unique risks associated with each type.
* Residence (Country):Tracking customer jurisdiction ensures risk assessments reflect geopolitical and regulatory changes, fulfilling FATF compliance expectations.
Role of Additional Fields in Compliance:
* These fields enhance traceability, accountability, and risk profiling, ensuring the CRA process is comprehensive and meets regulatory standards.
Advanced CAMS-Audit Guidance:
* Documentation must be detailed and periodically reviewed to address evolving AML risks effectively, as recommended by CAMS-Audit guidelines.
質問 # 37
The auditor identifies that the bank launched trade finance services this year.The target clients are multinational companies who actively support China's belt and road initiatives.Which scoring themes would be affected? (Select Two.)
- A. 11.3
- B. 13.1
- C. 11.2
- D. 12.2
- E. 12.1
正解：A、C
解説：
* Identification of Themes Relevant to Trade Finance Services:
* Trade finance services for multinational companies participating in China's Belt and Road initiatives involve transactions with potential geopolitical, regulatory, and economic risks.
* These transactions generally encompass cross-border activities, high-value accounts, and potentially politically exposed persons (PEPs).
* Scoring Theme A (11.2): Economic Activity and Geographical Risks:
* As these services involve international trade, they are inherently linked to economic activity and geographical risks. FATF guidelines indicate the necessity to evaluate regions with different AML
/CFT maturity levels. This is consistent with theme 11.2, focusing on the understanding and mitigation of risks associated with economic and geographical contexts.
* Scoring Theme B (11.3): Customer Due Diligence and Enhanced Measures for High-Risk Profiles:
* The target clientele includes multinational companies, which might require enhanced customer due diligence (EDD), especially when engaging with entities or PEPs from countries with varying regulatory controls.
* FATF Recommendations and Basel Committee insights emphasize robust customer identification, verification, and ongoing monitoring, aligning with theme 11.3's requirements.
* Not Affected Themes:
* C (12.1):This theme pertains more to specific reporting or transaction monitoring requirements that might not directly relate to the initiation of trade finance services.
* D (12.2) and E (13.1):These themes are typically associated with procedural adjustments rather than the scoring of risk profiles.
* Advanced CAMS-Audit Framework Alignment:
* Advanced CAMS-Audit highlights the role of structured compliance frameworks in mitigating risks tied to strategic initiatives like the Belt and Road.
* Evaluators assess the institution's alignment with FATF, Basel Committee, and regional guidelines to ensure adherence to best practices for risk mitigation.
Conclusion:The scoring themes A (11.2) and B (11.3) are significantly influenced by the introduction of trade finance services targeting multinational corporations under China's Belt and Road initiatives. This is due to the intertwined economic and geographical risks and the requisite enhanced due diligence measures for high-risk customer segments.
質問 # 38
Which finding must be first remediated in order to understand is risks the organization is exposed to?
- A. Finding 3
- B. Finding 8
- C. Finding 1
- D. Finding 5
正解：C
解説：
Finding 1
* This finding likely pertains to foundational gaps in the organization's risk assessment framework or the absence of a comprehensive understanding of inherent risks. Without addressing this, the organization cannot adequately identify, assess, or mitigate risks effectively.
* According to CAMS-Audit standards, a thorough risk assessment is the cornerstone of an effective AML/CFT program. It helps to prioritize resources and design appropriate controls based on the identified risk levels.
Critical Role in Understanding Risks
* Remediating foundational issues ensures that the organization has a clear understanding of its risk exposure across all products, services, and jurisdictions. This step is essential before addressing downstream issues such as customer due diligence (CDD) gaps or monitoring inefficiencies.
Alignment with Regulatory Requirements
* FATF guidelines and CAMS-Audit practices emphasize that risk assessment should precede other remediation efforts. Without this, the organization may address symptoms rather than root causes of compliance and operational risks.
質問 # 39
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ACAMS Advanced-CAMS-Audit 認定試験の出題範囲：
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Advanced-CAMS-Auditリアル無料試験問題と解答：https://www.goshiken.com/ACAMS/Advanced-CAMS-Audit-mondaishu.html
2025年最新の実際に出る検証済みの無料ACAMS Advanced-CAMS-Audit試験問題：https://drive.google.com/open?id=1Yx8Lhf99SYAzPNXfl1hnSQaWE1TlyFMj