[2025年02月]更新のAdvanced-CAMS-Audit試験資料ACAMS学習ガイド
有効な問題最新版を試そうAdvanced-CAMS-Auditテスト解釈Advanced-CAMS-Audit有効な試験ガイド
ACAMS Advanced-CAMS-Audit 認定試験の出題範囲：
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| トピック 4 |
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質問 # 47
Which findings indicate issues that would cause a lack of understanding of the risks associated with the business the financial institution conducts? (Select Three.)
- A. Finding 8
- B. Finding 1
- C. Finding 3
- D. Finding 5
- E. Finding 6
- F. Finding 4
正解：A、B、F
解説：
Finding 1
* This highlights fundamental gaps in the risk assessment process. A lack of clarity in identifying and analyzing risks associated with certain products, services, or client categories reflects an incomplete understanding of the business's risk landscape.
* CAMS-Audit emphasizes the importance of comprehensive risk assessments to identify inherent and residual risks and align them with the institution's overall AML/CFT framework.
Finding 4
* This pertains to inadequate integration of risk mitigation controls into operational processes, leading to blind spots in identifying emerging threats. Institutions that do not properly embed risk controls often fail to adapt to changing business or regulatory requirements.
* Reference to FATF recommendations underlines the necessity of embedding controls that reflect ongoing and emerging risks.
Finding 8
* Failure to implement effective monitoring mechanisms or maintain updated customer or transaction profiles suggests a superficial approach to understanding risk exposure. Without robust data tracking, financial institutions may overlook key risk indicators.
* CAMS-Audit documents stress the need for effective transaction and customer profile monitoring systems as part of a sound risk-based approach.
質問 # 48
Which conclusion should the auditor make regarding the staff attendance of the periodic AML training program organized by the bank?
- A. Staff attendance is complete because the training is mandatory for staff in the business, operations compliance and senior management whose duties involve knowledge of AML controls and processes.
- B. Staff attendance is incomplete because the board of directors is not part of the staff required to attend the periodic trainings, and there is no other specially designed AML training for the board.
- C. Staff attendance is complete because all staff in the institution are required to attend the AML training as part of the staff onboarding process.
- D. Staff attendance is incomplete because the compliance officer or the delegates are not part of the staff facilitating the 3-hour periodic AML training.
正解：B
解説：
Importance of AML Training for All Levels of an Institution:
* Advanced CAMS-Audit and FATF emphasize that AML training programs should be inclusive of all stakeholders, including senior management and board members, as they are integral to establishing an effective AML/CFT compliance culture.
Board-Level Training Specifics:
* Directors require tailored AML training to address strategic oversight responsibilities rather than operational controls. Periodic training is mandatory to keep the board updated on regulatory changes and institutional risk profile adjustments.
Audit Observation:
* Exclusion of the board from AML training reflects a gap in the institution's AML framework, potentially exposing it to regulatory scrutiny.
Reference to AML/CFT Standards:
* FATF Recommendations mandate training for all levels of an institution, explicitly highlighting senior management and governance roles in compliance efforts.
質問 # 49
The scoping and planning process of an AML audit of a bank is best guided by review of which document?
- A. Information technology security risk assessment of the bank's COD risk rating solution
- B. A document prepared to identify the inherent risk associated with a bank's products and services
- C. Independent model validation and testing report of the bank's transaction surveillance systems
- D. Report of independent audit conducted the previous year
正解：B
解説：
* Identifying inherent risks linked to the bank's products and services is critical to tailor the audit scope and address high-risk areas comprehensively.
質問 # 50
An auditor plans to examine a sample targeting newly onboarded, high net-worth clients to assess adherence to their onboarding policies. What sampling methods should the auditor use? (Select Three.)
- A. Discovery sampling
- B. Judgment sampling
- C. Stratified sampling
- D. Simple random sampling
- E. Snowball sampling
- F. Systematic sampling
正解：B、C、F
解説：
Sampling Methods Justification:
* A. Judgment Sampling: Enables the auditor to target high net-worth clients specifically based on their judgment of risk factors.
* B. Stratified Sampling: Allows for dividing the population into groups (e.g., high net-worth clients) and selecting samples from each group.
* F. Systematic Sampling: Ensures a structured and unbiased selection process, suitable for large datasets.
質問 # 51
What conclusion should the auditor make regarding AML training for outsourced AML providers?
- A. The approach outlined by the Dank is appropriate as the Dank can rely on a professional service provider to deliver the AML training program for the Dank s staff.
- B. The approach outlined by the bank Is appropriate as it considers practical issues such as time zone differences and availability of both classroom and online sessions.
- C. The approach outlined by the Dank is deficient, as it does not provide controls for the Dank to verify training delivered by outsourced providers to the bank's staff is appropriate.
- D. The approach outlined by the Dank is deficient, as the service providers are not pan of the Dank s AML training during its staff onboarding.
正解：C
解説：
Outsourced Training Oversight Requirements:
* CAMS-Audit emphasizes that institutions must ensure outsourced providers deliver training aligned with internal policies and regulatory standards.
Control Mechanisms for Outsourced AML Providers:
* The bank must have controls in place to:
* Review the content of training sessions.
* Validate trainer qualifications.
* Assess the effectiveness of training through feedback or testing.
Deficiencies in the Current Approach:
* Failure to implement verification mechanisms for outsourced training compromises the consistency and quality of the AML education program.
Regulatory Requirements:
* FATF and Basel guidelines mandate oversight of third-party service providers, especially for critical functions like AML compliance training.
質問 # 52
Which should the external auditor recommend to ensure that the institution did not facilitate transactions involving a sanctioned person?
- A. Re-screen all transactions over the period of time when the updated sanction lists were not uploaded against the current sanctions lists.
- B. Re-screen all transactions based on the sanctions lists that were active at that time but not uploaded.
- C. Perform a security risk and access assessment on the sanction screening tool to ensure more timely sanctions lists are uploaded.
- D. Periodically monitor the sanctions lists uploaded by the screening tool to ensure the most up-to-date lists are in the system.
正解：A
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 # 53
During a sample review, the auditor notices that an alert was generated for a large deposit that was inconsistent with the customer profile. The customer has had no other incidents in the past 10 years and has provided documents to confirm the deposit as a property sale. What should the auditor do?
- A. Increase the sample size.
- B. Carry out further investigation of this alert.
- C. Document the conclusion within the audit work papers.
- D. Consult with the compliance officer.
正解：C
解説：
Rationale for Documenting Conclusions:
* Documenting findings ensures transparency and provides an audit trail. This is critical when the incident is consistent with provided evidence and no further investigation is warranted.
Audit Work Paper Standards:
* CAMS-Audit recommends that all conclusions be adequately documented, especially when deviations from normal patterns are justified with valid explanations.
質問 # 54
A financial institution's (FI) risk assessment identified a lack of specific policies and procedures for existing privately-owned automated teller machine (ATM) customers.What would an auditorreview to assess whether this risk has been addressed?
- A. Prepare to audit a sample of the FI's privately-owned ATM customers.
- B. Draft policies and procedures for the FI's privately-owned ATM customers.
- C. Request data on the volume and value of transactions through the privately-owned ATM customers.
- D. Review the current risk assessment to determine the existence of privately-owned ATM customers.
正解：D
解説：
Reviewing the Risk Assessment:
* A risk assessment reveals whether privately-owned ATMs are identified and properly evaluated in terms of potential AML risks.
Auditor's Task:
* Confirm that specific policies and procedures are now in place to address identified risks from the previous assessment.
Relevance to CAMS-Audit Standards:
* Risk assessments are fundamental in identifying gaps in policies and procedures for high-risk areas like privately-owned ATMs.
質問 # 55
When evaluating an AML training program tor CFT functions the auditor should verify that:
- A. attendees have completed post-course surveys.
- B. tailored training has been provided to AML and CFT staff.
- C. ethics training has been delivered to senior management.
- D. interns and third parties are not included.
正解：B
解説：
These answers are aligned with best practices and principles outlined in FATF recommendations and the context of AML/CFT risk management and training standards. If further detailed references are required, feel free to ask!
質問 # 56
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. Management engages an independent third party to update all the customer risk profiles.
- B. The business updates the customer risk profiles periodically in accordance with the customer risk level.
- 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：B、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 # 57
An auditor should present exceptions identified during testing to the auditee after.
- A. final audit report issuance
- B. performance of additional testing.
- C. preliminary observation of exceptions.
- D. analysis of likelihood and impact.
正解：D
解説：
Presentation of Exceptions:
* Auditors must analyze the exceptions based on their likelihood of occurrence and potential impact on compliance and operational risks before presenting findings to the auditee.
Supporting Standards:
* Basel and FATF emphasize prioritizing findings based on their materiality and risk implications during the audit process.
質問 # 58
Which factors should be taken into consideration in designing a follow-up strategy when remedial action needs to be taken due to deficiencies identified in an AML audit?
- A. Available resources and board of directors' commitment
- B. Target completion date and status update on remedial action
- C. Reporting the breach and the regulatory response
- D. Responsible action owner and internal audit commitment to follow up
正解：B
解説：
In follow-up strategies, the focus should be on ensuring accountability and tracking progress. Establishing a target completion date and regularly updating the status of remedial actions ensures timely and effective resolution of deficiencies.
CAMS-Audit emphasizes tracking timelines and milestones for corrective actions to align with regulatory expectations and internal compliance frameworks.
質問 # 59
Which set of activities describes the planning phase of an audit?
- A. Request management overview of the organization conduct analytical review of processes and issue findings
- B. Request the scheduling of preliminary discussions with management and request a walk-through of key processes
- C. Request data regarding financials, schedule planning meeting and perform sample testing
- D. Request organizational charts, assess data for sample testing and provide an initial report
正解：B
解説：
Comprehensive Detailed Step-by-Step Explanation:
* Activities in the Planning Phase:
* The planning phase involves understanding the scope, objectives, and framework for the audit.
* Preliminary discussions with management set the stage for identifying critical processes and potential risk areas.
* Key Actions:
* Scheduling preliminary discussions ensures alignment on audit goals.
* A walk-through of key processes provides insight into workflows and control mechanisms.
* Alignment with CAMS-Audit Principles:
* Effective planning as described in CAMS-Audit guidelines prioritizes communication and process understanding during initial audit phases.
質問 # 60
Which should be evaluated when analyzing components of risk mitigation in an AML risk assessment?
(Select Two.)
- A. Product risk
- B. Liquidity risk
- C. Overall customer volume
- D. Office of Foreign Assets Control filtering
- E. Customer risk
正解：A、E
解説：
Product Risk: Certain products (e.g., high-value transfers, anonymous payment systems) inherently carry higher AML risks and require tailored risk mitigation measures.
Customer Risk: Understanding the risk profile of customers, including PEPs and high-net-worth individuals, is critical to assessing exposure and implementing risk-based approaches.
Both factors are core components in AML risk assessments, as highlighted in CAMS-Audit materials and FATF standards.
質問 # 61
Which finding indicates issues that could result in clients being subject to incorrect scenarios and thresholds?
- A. Firming 2
- B. Finding 4
- C. Finding 5
- D. Finding 7
正解：D
解説：
* Significance of Finding 4 in Scenario and Threshold Calibration:
* Finding 4typically points to issues with the alignment of customer segmentation or risk profiling.
Incorrect segmentation or categorization directly impacts the assignment of scenarios and thresholds, leading to clients being subjected to inappropriate monitoring settings.
* For example, placing a low-risk client in a high-risk threshold group can cause unnecessary alerts, while the opposite scenario might miss genuine suspicious activities.
* Other Options Evaluated:
* Finding 2:May relate to broader systemic issues but does not specifically highlight misalignment with thresholds or scenarios.
* Finding 5:Typically involves data accuracy concerns but does not directly result in the application of incorrect scenarios or thresholds.
* Finding 7:Often pertains to gaps in coverage or monitoring rather than specific issues in the calibration of scenarios and thresholds.
* Advanced CAMS-Audit Context:
* Advanced CAMS-Audit emphasizes the importance of precise customer segmentation and scenario calibration to ensure transaction monitoring systems operate efficiently and effectively.
Findings pointing to misalignments in these areas are critical indicators of potential weaknesses.
* Regulatory Relevance:
* FATF and Basel Committee standards require risk-based monitoring tailored to the risk profile of each customer. Misaligned thresholds violate this principle, potentially leading to regulatory scrutiny.
Conclusion:The correct answer isB. Finding 4, as it identifies the misalignment of scenarios and thresholds with customer risk profiles, which is a critical issue in ensuring effective AML monitoring systems.
質問 # 62
What is the role of the internal audit in the governance process?
- A. Execute the corrective action plan.
- B. Monitor the risks of noncompliance with applicable laws and regulations.
- C. Perform quality assurance testing of transaction monitoring.
- 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 # 63
When assessing the KYC process which should an auditor observe from the customer risk assessment? (Select Two)
- A. The ultimate beneficial owners of the customer need to be Identified and verified.
- B. Self-declaration or Beneficial ownership should not be accepted as it is not adequate.
- C. If this was a face-to-face customer, the overall customer risk rating should be changed to low.
- D. Overseas shareholders not involved in the customer's dally operations are not beneficial owners.
- E. The purpose and intended nature of the business relationship were not reviewed m the assessment.
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 # 64
The auditor identifies that the bank has launched trade finance services this year.When rating the various themes of the risk mitigants, which are expected to be impacted by the launchof these services? (Select Three.)
- A. M2.1
- B. M1.2
- C. M4.2
- D. M5.2
- E. M1.1
- F. M3.2
正解：A、C、E
解説：
* M1.1 - Risk Identification and AssessmentTrade finance introduces new types of risks such as exposure to cross-bordertransactions, multiple parties, and complex financial instruments. These elements necessitate a reassessment of existing risk frameworks to identify new vulnerabilities, including trade-based money laundering (TBML). As detailed in the CAMS-Audit guidance, financial institutions must periodically update their risk assessments to reflect changes in products and services.
* M2.1 - Enhanced Due Diligence (EDD) on High-Risk CustomersTrade finance clients often involve politically exposed persons (PEPs), entities in high-risk jurisdictions, or complex supply chains.
According to FATF Recommendation 10 and CAMS standards, banks must enhance customer due diligence measures, including obtaining additional information on the customer's source of funds, beneficial ownership, and the nature of the business.
* M4.2 - Transaction Monitoring SystemsThe complexity of trade finance transactions requires robust monitoring systems capable of identifying unusual patterns indicative of money laundering or terrorist financing. These systems must be calibrated to flag discrepancies in trade documentation, over- or under-invoicing, and deviations from expected trade flows, as emphasized in the FATF Recommendations and CAMS-Audit references.
References from Advanced CAMS-Audit Documents:
* AML/CFT-document references specify the need for updated risk assessments and transaction monitoring systems aligned with international AML standards for new services.
* FATF Recommendations provide a framework for enhanced due diligence and risk-based approaches for trade finance.
質問 # 65
During the ongoing due diligence process the company becomes aware that the customer is holding personal assets for a politically exposed person (PEP). What should the auditor recommend to enhance the control environment for this customer relationship? (Select Three.)
- A. Review the customer risk profile every two years as with any other customers.
- B. Designate the account as a PEP-account.
- C. File a suspicious activity report as the previous riskrating was not correct.
- D. Review and document the details of the customer s asset-holding arrangement.
- E. Deploy automated monitoring toots to efficiently peruse the customer's KYC information and assure that the customer's KYC risk rating is correct.
- F. Conduct enhanced due diligence and enhanced ongoing monitoring of the customer relationship.
正解：B、D、F
解説：
C:Designating the account as a PEP-account triggers additional monitoring and controls as PEPs inherently pose higher risks.
D:Enhanced due diligence (EDD) and ongoing monitoring are essential for PEPs to track their financial activities closely and address any anomalies.
E:Documenting the details of the asset-holding arrangement provides clarity on the customer's profile and any associated risks.
質問 # 66
The mam characteristics of an AML program testing are:
- A. standard and focused.
- B. remedial and interdependent.
- C. innovative and evaluative.
- D. tailored and risk-based.
正解：D
解説：
Characteristics of Effective AML Program Testing:
* Tailored:Custom-designed to address specific organizational risks.
* Risk-Based:Prioritizes high-risk areas to ensure optimal resource allocation and compliance.
Alignment with CAMS-Audit and FATF Principles:
* Both emphasize the importance of a risk-based approach to AML program evaluation to mitigate the most significant threats.
質問 # 67
When conducting an audit of a money services business (MSB), the frequency of the review depends on the country's regulatory practices and the MSB's.
- A. scope.
- B. policy.
- C. regulatory requirements.
- D. internal controls.
正解：C
解説：
Review Frequency:
* The frequency of MSB reviews depends on regulatory requirements, which vary by jurisdiction but are guided by FATF Recommendations that mandate risk-based supervision for money services businesses.
Risk-Based Approach:
* Regulators often require more frequent reviews for high-risk MSBs to ensure compliance with AML
/CFT standards.
質問 # 68
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. 13.1
- B. 11.2
- C. 12.2
- D. 12.1
- E. 11.3
正解：B、E
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 # 69
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