完全版CAMS練習テスト617特別な問題と解答が待ってます！
CAMS Certification問題集でCAMS試験完全版問題で試験学習ガイド
質問 # 292
A non-U.S. bank asks its U.S. correspondent whether there is risk of having funds seized in their correspondent account if a customer is involved in a predicate offense.The correspondent bank's reply should be,
- A. "No, only correspondent accounts of U.S. banks can be seized and forfeited by government agencies."
- B. "No, only U.S. accounts for U.S. citizens can be seized and forfeited by the competent authority."
- C. "Yes, also if the customer's account is used in a country other than the U.S. by suspected money launderers."
- D. "Yes, if it is suspected that money laundering has occurred solely in the U.S."
正解：A
質問 # 293
Which constitute red flags in connection with a company involved in illegal logging? (Select Three.)
- A. High number of transactions through company's connected bank accounts
- B. Use of heavy machinery in non-protected areas
- C. Expeditious shipment of wood to far away jurisdictions
- D. Paper packaging demand production
- E. Business registry activities state promotion of environmental protection
- F. Executive's association with politically exposed persons
正解：B、C、F
解説：
Red flags in connection with a company involved in illegal logging include: D. Expeditious shipment of wood to far away jurisdictions, E. Use of heavy machinery in non-protected areas, and F. Executive's association with politically exposed persons. These red flags could be indicative of attempts to conceal the origin of illegally harvested wood and to avoid detection by government authorities.
質問 # 294
Which statement is true about when an institute becomes aware that a particular employee is under investigation by law enforcement as a result of a subpoena or warrant?
- A. The employee can and should be interviewed, as well as notified of the investigation to demonstrate the seriousness of the offence and to get the employee's full attention and cooperation
- B. The institute has a duty as an employer to inform the employee he or she is under investigation by law enforcement, buy must not inform them that a warrant or subpoena has been received
- C. Under no circumstances can the employee be interviewed by the institution without the consent of law enforcement for fear of tipping the employee off
- D. If an independent investigation provides grounds to interview the employee, they can be interviewed and, if necessary, terminated buy not advised that they are under investigation
正解：A
質問 # 295
Which of the following is considered a shell bank as defined by the USA PATRIOT Act?
- A. An Internet bank operating in the U.S. providing services worldwide.
- B. A bank incorporated in an offshore jurisdiction without a physical presence or employees.
- C. A bank run by a foreign holding company with offices and staff in an offshore jurisdic-tion.
- D. A local bank with offices in a non-cooperative jurisdiction which is subject to minimal regulatory supervision.
正解：B
解説：
According to the USA PATRIOT Act, a shell bank is defined as "a bank that has no physical presence in any country" (Section 313(a)(1)). A physical presence means "a place of business that is maintained by a bank and is located at a fixed address, other than solely a post office box or an electronic address, in a country in which the bank is authorized to conduct banking activities, at which location the bank employs one or more individuals on a full-time basis and maintains operating records related to its banking activities" (Section
313(a)(2)). Therefore, option A is the correct answer, as it describes a bank that has no physical presence or employees in any country. Options B, C, and D are not correct, as they describe banks that have some form of physical presence or affiliation with another bank in a country.
References:
USA PATRIOT Act, Title III, Subtitle A, Section 313, Prohibition on United States Correspondent Accounts with Foreign Shell Banks, 1.
ACAMS Study Guide for the Certified Anti-Money Laundering Specialist (the 6th edition), Chapter 4:
International Standards and Global Initiatives, page 103.
質問 # 296
What three attributes do havens for money laundering and terrorist financing typically have? Choose 3 answers
- A. Limited types of institutions and persons covered by money laundering laws and regulations
- B. Absence of an effective FIU
- C. A large number of predicate crimes for money laundering
- D. Little enforcement of the laws, weak penalties or provisions that make it difficult to confiscate or freeze assets related to money laundering
正解：A、C、D
質問 # 297
A local law enforcement officer, who is conducting a criminal investigation, requests information about a customer.
Which two actions should the bank take? (Choose two.)
- A. File a suspicious transaction report
- B. Review the money laundering risk posed by the account
- C. Close the account immediately
- D. Monitor the account for suspicious activity
正解：A、D
解説：
According to the Anti-Money Laundering Specialist (the 6th edition) study guide, when a financial institution receives a law enforcement inquiry, it should cooperate as much as possible and respond to all formal requests for information, unless there is a valid objection that can and should be made1. The institution should also file a suspicious transaction report (STR) if the inquiry or the customer's activity triggers any red flags or indicators of money laundering or other financial crimes2. Additionally, the institution should monitor the account for suspicious activity and review the money laundering risk posed by the account, as these are part of the ongoing due diligence and risk assessment processes3. Closing the account immediately is not a recommended action, as it may alert the customer or interfere with the investigation4.
References:
1: ACAMS, CAMS Certification Package - 6th Edition, Chapter 4, page 121
2: ACAMS, CAMS Certification Package - 6th Edition, Chapter 4, page 122
3: ACAMS, CAMS Certification Package - 6th Edition, Chapter 4, page 123
4: ACAMS, CAMS Certification Package - 6th Edition, Chapter 4, page 124
質問 # 298
A compliance officer at a large financial institution has been tasked by senior management to lead a team in an internal review and potential revision of the institution's customer onboarding program following a regulatory enforcement action of another institution.
Which step should the compliance officer perform first?
- A. Conducting enhanced due diligence on high risk customers
- B. Revising training materials for frontline staff
- C. Reviewing the institution's risk assessment
- D. Resolving substantive discrepancies in customer verification
正解：C
質問 # 299
A new customer has just been onboarded in a securities firm. After a few weeks, there are unusual trading patterns that are being flagged. Which pattern is most concerning to the compliance officer?
- A. The customer accumulates securities of a low volume counter in small increments on a weekly basis.
- B. The customer receives many incoming wire transfers from related parties to the trading account.
- C. The customer engages in large trading in securities that are liquid or highly priced from the trading account.
- D. The customer's repeated trading in securities that are low priced and low volume counters.
正解：A
解説：
The most concerning trading pattern for a compliance officer when a new customer has been onboarded in a securities firm is the customer accumulating securities of a low volume counter in small increments on a weekly basis. This type of behavior could indicate that the customer is attempting to obscure their identity or the true purpose of their trading activity, which can be indicative of money laundering or other suspicious activity. (CAMS Manual, 6th Edition, Page 170).
質問 # 300
The Board of Directors for a small private bank has asked the management to no longer apply the identity requirements for high net worth individuals to protect their privacy. Which of the following Financial Action Task Force 40 Recommendations should cause an anti-money laundering specialist the most concern?
- A. Financial institutions should maintain all necessary suspicious transaction report records on transactions, both domestic are international, for at least 5 years.
- B. Financial institutions should not keep anonymous accounts.
- C. Financial institutions should not warn their customers when information relating to them is being reported to the competent authorities.
- D. If financial institutions suspect that funds stem from criminal activity, they should be required to close the account.
正解：B
質問 # 301
Which statement is true regarding the FATF standards for SARs/STRs information sharing within a financial group?
- A. FIs must retain copies of SARs/STRs and supporting documentation for five years from the date of filing the STRs
- B. Financial institutions (FIs) should establish sufficient safeguards concerning the confidentiality of information shared for AML purposes.
- C. FIs cannot share customer information at all since it is confidential.
- D. FIs must require approval from regulators to share SARs/STRs information and supporting documentation.
正解：B
解説：
According to the FATF Guidance on Private Sector Information Sharing, FIs should establish sufficient safeguards concerning the confidentiality of information shared for AML purposes, both within the same financial group and between FIs not belonging to the same group. These safeguards include ensuring that the information is shared only with authorized personnel who have a need to know, that the information is used only for the intended AML purpose, and that the information is protected from unauthorized access, disclosure, or misuse. FIs should also comply with the applicable legal and regulatory requirements on data protection and privacy, and respect the rights and interests of the customers whose information is shared1.
References:
1: FATF Guidance on Private Sector Information Sharing1
質問 # 302
A customer has held an account at a local credit institution for 10 years. The account has received deposits twice weekly for the same amount and has never shown signs of suspect behavior. Monitoring software indicated that in the past few months the account has received several large deposits that were not in line with the account history. When asked, the customer states she recently sold a piece of property, which is supported with a proof of sale. What should the compliance officer do next?
- A. File an STR with the competent authorities
- B. Investigate these unusual transactions further
- C. Contact the local FIU for advice
- D. Document reasons for not filing a STR
正解：A
質問 # 303
Which three characteristics make non-profit organizations vulnerable to misuse for terrorist financing?
- A. Having access to a considerable sources of funds
- B. Having a global presence for national and international operations and financial transactions
- C. Being listed as government nonprofit organization
- D. Enjoying the public trust
正解：A、B、D
質問 # 304
An employee hears a colleague on the telephone with a customer giving advice on how to ensure that a suspicious transaction report will not be filed as a result of a future transaction.
What action should the employee take?
- A. Ignore the situation because the colleague is the relationship manager for that customer
- B. Report the conversation to the compliance officer
- C. Tell the colleague that it is against policy to give such advice
- D. Report the conversation to the local police
正解：B
解説：
According to the Anti-Money Laundering Specialist (the 6th edition) resources, the employee should report the conversation to the compliance officer because the colleague is engaging in tipping off, which is a serious violation of anti-money laundering laws and regulations. Tipping off is the act of informing a person or entity that they are the subject of a suspicious transaction report or an investigation, or providing any information that may compromise or impede the investigation. Tipping off can result in criminal penalties, civil liabilities, and disciplinary actions for the individual and the institution. Therefore, the employee has a duty to report the colleague's misconduct to the compliance officer, who is responsible for ensuring compliance with the anti-money laundering policies and procedures, and taking appropriate corrective actions.
References:
CAMS Certification Package - 6th Edition | ACAMS, Chapter 3: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), page 97 CAMS Certifications: How to Get CAMS Certified | ACAMS, CAMS Examination Preparation, page 8 ACAMS CAMS Certification Video Training Course - Exam-Labs, Module 3: Compliance Standards for Anti-Money Laundering and Combating the Financing of Terrorism, video 3.4: Tipping Off and Confidentiality Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition), Question 8, Answer B
質問 # 305
After an institution files an STR with regard to a particular account, a law enforcement agent requests the institution to keep the account open until advised otherwise by law enforcement.
What steps should the institution take?
- A. The institution should close the account in order not to be caught in the middle of a lawenforcement investigation
- B. The institution should request a written letter From the law enforcement ( agency signed by anappropriate authorized signature
- C. The institution should follow the request of the law enforcement agent and keep the accountopen
- D. The institution should keep the account open only if doing so comports with the bank's ownAML procedures
正解：B
質問 # 306
A U.K. real estate agent has three foreign clients interested in purchasing an apartment building, valued at E30 million, in the outskirts of London as an investment property. The clients are not willing to have their names provided to the bank. The clients want to purchase to be made in the names of three private companies for privacy reasons. The plan is to wire the funds into an account held in the name of another private company at a bank in London.
Which red flag should stop the agent from discussing this potential purchase further?
- A. The clients are foreign
- B. The clients are not willing to have their names provided to the bank
- C. The clients want to purchase to be made in the names of the private companies
- D. The clients have the funds necessary to fund a E30 million purchase
正解：B
解説：
Explanation/Reference:
質問 # 307
The Chief Compliance Officer (CCO) of a financial institution has been asked by a manufacturing customer reliant upon imported raw materials if there will be repercussions to his business following the weak assessment of the recent publicly issued Financial Action Task Force (FATF) Mutual Evaluation Report (MER). How should the CCO respond?
- A. Citing inaccurate content of the MER. the president of the country has called upon the FATF to publicly withdraw the MER and commission an independent review of findings.
- B. Delayed processing of cross-border transfer of funds between countries may occur due to increased scrutiny to determine the legitimacy of each transfer.
- C. Negative consequences will not occur because the manufacturing customer has been trading with reputable countries and suppliers for many years without incident.
- D. Mandate termination of all cross-border trading until evidence can be provided to show an improved position of compliance for the weaknesses stated in the MER.
正解：B
解説：
According to the Certified Anti-Money Laundering Specialist (the 6th edition) Study guide, the CCO should advise the manufacturing customer that increased scrutiny of cross-border transfers may lead to delays and caution them to ensure that all necessary documentation is provided in order to facilitate a timely transfer.
Additionally, the CCO should recommend that the customer contact the FATF to discuss the possibility of an independent review of the findings, as well as other options to mitigate the potential negative consequences.
質問 # 308
What are the regulatory risks to a bank employee who willfully violates anti-money laundering laws?
- A. Fines and suspension from the industry
- B. Investigation and reputational damage
- C. Enforcement actions including fines against the financial institution
- D. Criminal investigation and imprisonment
正解：D
解説：
A bank employee who willfully violates anti-money laundering laws faces the risk of criminal investigation and imprisonment, as these are serious offenses that could result in felony charges and penalties. According to the U.S. Department of Justice, individuals who knowingly violate the Bank Secrecy Act (BSA) or other anti-money laundering laws could face up to 10 years in prison and/or a fine of up to $500,0001. Similarly, in other jurisdictions, such as the UK, Canada, and Australia, individuals who commit money laundering offenses could face imprisonment and/or fines234.
References:
1: U.S. Department of Justice, Criminal Resource Manual, Title 18 U.S.C. § 1956. Laundering of Monetary Instruments, Section 2101 2: UK Government, Proceeds of Crime Act 2002, Part 7: Money Laundering Offences, Section 327-329 3: Government of Canada, Criminal Code, Part XII.1: Laundering of Proceeds of Crime, Section 462.31 4: Australian Government, Criminal Code Act 1995, Chapter 10: National Infrastructure, Part 10.2: Money Laundering, Section 400.3-400.9 Penalties for AML/CFT violations, including criminal and civil penalties, fines, jail terms, as well as internal sanctions, such as disciplinary action up to and including termination of employment.
質問 # 309
An anti-money laundering specialist has been asked to create internal anti-money laundering policies, procedures and controls for a recently chartered offshore financial institution.
Which three should be included? Choose 3 answers
- A. Basel Committee on Banking Supervision's capital adequacy requirements for the host country
- B. An anti-money laundering compliance program, internal audit program, and procedure manual
- C. A training program for senior management and staff
- D. Compliance requirement of host and charting countries
正解：B、C、D
解説：
these are the essential components of an effective anti-money laundering program for any financial institution, especially an offshore one. According to the CAMS Study Guide, 6th Edition, an anti-money laundering program should include the following elements1:
A risk assessment that identifies and evaluates the money laundering and terrorist financing risks faced by the institution, and the measures taken to mitigate them.
A compliance program that establishes policies, procedures, and controls to prevent, detect, and report money laundering and terrorist financing activities, and to comply with the applicable laws and regulations of the host and chartering countries.
A designated compliance officer who is responsible for overseeing the implementation and maintenance of the compliance program, and for liaising with the relevant authorities and stakeholders.
A training program that provides regular and appropriate education and awareness to senior management and staff on their roles and responsibilities in relation to anti-money laundering and terrorist financing, and on the latest trends and typologies in these areas.
An independent audit function that reviews and tests the adequacy and effectiveness of the compliance program, and reports the findings and recommendations to senior management and the board of directors.
The Basel Committee on Banking Supervision's capital adequacy requirements for the host country (answer A) are not directly related to anti-money laundering, but rather to the prudential regulation and supervision of banks. They are important for ensuring the financial soundness and stability of banks, but they are not sufficient to prevent or combat money laundering and terrorist financing2.
References:
1: CAMS Study Guide, 6th Edition, Chapter 5: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), page 139-140. 2: Basel Committee on Banking Supervision, Bank for International Settlements.
質問 # 310
A customer brings $15,000 worth of chips into a casino and plays various games. The customer redeems all the remaining chips and requests a wire transfer of the proceeds to an unrelated third party.
What are two red flags that indicate money laundering? (Choose two.)
- A. Requesting a wire transfer to an unrelated third party
- B. Customer redeeming all remaining chips
- C. Bringing $15,000 worth of chips into the casino
- D. Playing various games before cashing out
正解：A、C
解説：
Bringing $15,000 worth of chips into the casino is a red flag because it could indicate that the customer is trying to avoid the currency transaction reporting (CTR) requirement for cash transactions over
$10,0001. Requesting a wire transfer to an unrelated third party is another red flag because it could indicate that the customer is trying to conceal the source or destination of the funds, or transfer them to a high-risk jurisdiction2.
References:
1: ACAMS CAMS Certification Video Training Course, Module 3: Casinos and Gaming, Section 3.1:
Regulatory Requirements, Slide 8 2: ACAMS CAMS Certification Video Training Course, Module 3: Casinos and Gaming, Section 3.2: Money Laundering Methods and Red Flags, Slide 11
質問 # 311
You design an AI solution that uses an Azure Stream Analytics job to process data from an Azure IoT hub. The IoT hub receives time series data from thousands of IoT devices at a factory.
The job outputs millions of messages per second. Different applications consume the messages as they are available. The messages must be purged.
You need to choose an output type for the job.
What is the best output type to achieve the goal? More than one answer choice may achieve the goal.
- A. Azure Blob storage
- B. Azure Cosmos DB
- C. Azure SQL Database
- D. Azure Event Hubs
正解：B
解説：
Stream Analytics can target Azure Cosmos DB for JSON output, enabling data archiving and low-latency queries on unstructured JSON data.
References:
https://docs.microsoft.com/en-us/azure/stream-analytics/stream-analytics-documentdb-output
質問 # 312
After an institution files an STR with regard to a particular account, a law enforcement agent requests the institution to keep the account open until advised otherwise by law enforcement.
What steps should the institution take?
- A. The institution should request a written letter from the law enforcement (agency signed by an appropriate authorized signature)
- B. The institution should keep the account open only if doing so comports with the bank's own AML procedures
- C. The institution should follow the request of the law enforcement agent and keep the account open
- D. The institution should close the account in order not to be caught in the middle of a law enforcement investigation
正解：A
質問 # 313
A commission regotorie would be used in which gateway to obtain information from another country?
- A. A supervisory channel request with the Basel Committee
- B. An MLAT request
- C. A FATF request
- D. An FIU request under the Egmont principles
正解：D
質問 # 314
Which are the two most common controls a financial institution (FI) uses to identify suspicious money-laundering activity? (Choose two.)
- A. Transaction monitoring rules
- B. Adverse media information
- C. Governmental subpoena
- D. Sanctions screening
- E. Search warrant
正解：A、B
解説：
Reference: https://www.fatf-gafi.org/media/fatf/content/images/Updated-2017-FATF-2013-Guidance.pdf
質問 # 315
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