[2025年04月] 最新のACAMS CAMS認定練習テスト問題
確認済みCAMS問題集と解答で一年間無料最速更新
質問 # 208
A compliance officer identifies a potentially significant risk in a popular financial product. Further investigation reveals there is no mitigating control.
Which course of action should the compliance officer take?
- A. Immediately cease providing the product and only offer it after effective permanent mitigation is implemented
- B. Note the risk and address it during the next round of policy and procedure review
- C. Implement a temporary mitigation that enables effective management of the risk until a permanent plan can be developed
- D. Launch a long-term project to remediate the control deficiency
正解：C
質問 # 209
Which are characteristics of Mutual Legal Assistance Treaties (MLATs)? (Select Three.)
- A. MLATs are useful for gathering evidence and intelligence in a foreign country.
- B. MLATs do not provide a legal basis for transmitting evidence.
- C. MLATs are neither public nor binding under international law.
- D. MLATs cooperatively combat crime between countries.
- E. MLATs cannot be used for obtaining banking records from treaty partners.
- F. MLATs only involve two countries.
正解：A、D、F
解説：
Explanation
Mutual Legal Assistance Treaties (MLATs) are characteristics of D. only involving two countries, E.
cooperatively combating crime between countries, and F. being useful for gathering evidence and intelligence in a foreign country. MLATs are public and binding under international law (A), can be used for obtaining banking records from treaty partners (B), and provide a legal basis for transmitting evidence .
質問 # 210
What should a compliance officer do during an ongoing investigation into a client's activities by a competent authority?
- A. Communicate only in writing regulatory and law enforcement authorities in line with applicable local laws
- B. Only provide information that is specifically and directly requested
- C. Communicate with regulatory and law enforcement authorities in line with applicable local laws
- D. Ensure communication with regulatory and law enforcement authorities is conducted only through the Board of Directors
正解：D
解説：
Explanation/Reference:
質問 # 211
In 2004, Consolidated KYC Risk Management was issued by the Basel Committee on Banking Supervision (BCBS). What is a key message in this document?
- A. Policies and procedures should be designed not merely to comply strictly with all relevant laws and regulations
- B. KYC Risk Management required a yearly consolidation effort
- C. Consolidated KYC risk management for a group is critical and trumps jurisdictional rules hat limit information sharing
- D. KYC Risk Management means as established decentralized process for promulgating policies and procedures
正解：A
質問 # 212
Your company has recently deployed 5,000 Internet-connected sensors for a planned AI solution.
You need to recommend a computing solution to perform a real-time analysis of the data generated by the sensors.
Which computing solution should you recommend?
- A. an Azure HDInsight Storm cluster
- B. Azure Notification Hubs
- C. an Azure HDInsight R cluster
- D. an Azure HDInsight Hadoop cluster
正解：D
解説：
Azure HDInsight makes it easy, fast, and cost-effective to process massive amounts of data.
You can use HDInsight to process streaming data that's received in real time from a variety of devices.
References:
https://docs.microsoft.com/en-us/azure/hdinsight/hadoop/apache-hadoop-introduction
質問 # 213
Which two individuals are ordinarily beneficial owners of a private banking account according to the Wolfsberg Anti-Money Laundering Principles for Private Banking? (Choose two.)
- A. Those two are authorized signers on the account
- B. Those who are the ultimate source of funds for the account and whose source of wealth should be subject to due diligence
- C. Those who have legal title to a controlling share interest in the customer
- D. Those who generally have ultimate control through ownership or other means over the funds in the account
正解：B、D
解説：
According to the Wolfsberg Anti-Money Laundering Principles for Private Banking, the beneficial owners of a private banking account are those who generally have ultimate control over the funds in the account and those who are the ultimate source of funds for the account and whose source of wealth should be subject to due diligence1. These two criteria are meant to ensure that the bank knows who is ultimately behind the account and where the funds come from, in order to prevent the use of the bank for money laundering or other criminal purposes. Authorized signers on the account or those who have legal title to a controlling share interest in the customer are not necessarily the beneficial owners, as they may act on behalf of others or have limited influence over the account.
References: 1: Wolfsberg Anti-Money Laundering Principles for Private Banking (2012), Section 1.3.1 and
1.3.2, 1
Reference: https://www.wolfsberg-principles.com/sites/default/files/wb/pdfs/wolfsberg-standards/10.%
20Wolfsberg-Private-Banking-Prinicples-May-2012.pdf (2)
質問 # 214
A bank account is established for a new business customer. The business was established five years ago with an address in another state. The business website contains few details other than stating it is a real estate business.
One principal has an international telephone number and appears to be living in another country. The other principal works out of a recreational vehicle.
What warrants enhanced due diligence in this scenario?
- A. Politically exposed person
- B. Money laundering through real estate
- C. Shell company
- D. Human trafficker
正解：B
解説：
Money laundering through real estate is a common method of disguising the source and ownership of illicit funds. Real estate transactions often involve large amounts of money, complex legal structures, and cross- border transfers, which can obscure the true nature and origin of the funds. The new business customer in this scenario raises several red flags that warrant enhanced due diligence, such as:
* The business was established five years ago but has a vague website and no physical presence in the state where it is registered.
* One of the principals has an international phone number and lives abroad, which could indicate a foreign shell company or a politically exposed person.
* The other principal works out of a recreational vehicle, which could suggest a lack of legitimate business activity or income.
* The business claims to be a real estate business, but does not provide any details about its projects, clients, or partners.
These factors suggest that the business may be involved in money laundering through real estate, either by purchasing properties with illicit funds, using properties to generate illegal income, or selling properties to launder money. Therefore, the financial institution should conduct enhanced due diligence to verify the identity, background, and source of funds of the business and its principals, as well as the purpose and nature of the account relationship.
References:
* ACAMS Study Guide for the CAMS Certification Examination - 6th Edition, Chapter 2: Money Laundering Risks and Methods, pp. 46-47
* Enhanced Due Diligence in Construction and Real Estate, by James Swenson, Ethixbase 360
* Due Diligence & Legal Considerations in Commercial Real Estate, by Justia
質問 # 215
To deter money laundering through new accounts, a financial institution should:
- A. document the identity of the party opening the account.
- B. query owners' names against Financial Action Task Force databases.
- C. seek to determine the source of deposited funds.
- D. determine the beneficial owner(s) of the account.
正解：A、C、D
質問 # 216
A bank compliance officer discovers cash deposit activity inconsistent with the expected and historical cash activity within the personal accounts of the chairman of the board. The cash activity appears structured to avoid the local legal filing requirements for large cash transactions, and a suspicious transaction report (STR) was filed.
How should the compliance officer report the filing of the STR to the board of directors without revealing the existence of the filing to the subject?
- A. The compliance officer and the chief executive officer should jointly interview the chairman
- B. Inform the legal counsel of the bank
- C. Notify the financial institution's regulator to disclose the activity
- D. Follow the financial institution's established STR reporting policy
正解：B
質問 # 217
What is a major money laundering risk associated with a number of prepaid cards as opposed to credit or debit cards?
- A. The anonymous access to funds
- B. The risk of losing the prepaid cards
- C. The global access to cash through ATMs
- D. The inability to load the card with cash
正解：A
質問 # 218
Which information must a United States financial institution retain for having foreign correspondent accounts as part of the USA PATRIOT Act record keeping requirements?
- A. Section 314(b) information sharing results related to foreign correspondent accounts
- B. Purchase of monetary instruments of $3,000 or more involving foreign correspondent accounts
- C. Records identifying the owners of each foreign bank
- D. A suspicious activity report filed and the supporting documentation involving foreign correspondent accounts
正解：C
質問 # 219
A company service provider in Country A sets up a corporate structure for a client from Country B, which is known for corruption. The corporate structure includes a holding company in Country A with a bank account in one of the international banks located there.
During on-boarding, the client's wealth was estimated at $7 million. Shortly thereafter, the client's father became president of Country B. During a routine client review two years later, it was identified that client's wealth had grown to $510 million.
What are two red flags that indicate money laundering or financial terrorism? (Choose two.)
- A. The client is a family member of a PEP from a country known for corruption.
- B. The substantial growth in wealth during a short period of time.
- C. The holding company is in Country A with a bank account in one of the international banks.
- D. The client is from a country known for corruption.
正解：A、D
解説：
High-risk: The risks here are significant, but are not necessarily prohibited. To mitigate the heightened risk presented, the financial institution should apply more stringent controls to reduce the ML/FT risk, such as conducting enhanced due diligence and more rigorous transaction monitoring. Countries that maintain a reputation for corruption or drug trafficking are generally considered high-risk. High-risk customers may include politically exposed persons (PEPs) or certain types of money services businesses or cash-intensive businesses; high-risk products and services may include correspondent banking and private banking.
質問 # 220
A compliance officer at a small local bank reads in the newspaper that a high ranking local public official, who is a long-standing account holder, is being investigated by the competent authorities for accepting bribes from a well-known construction company with offices in the town. The compliance officer immediately checks the official's account and other recently opened accounts at the bank. The official opened a new account at the bank a few weeks ago. The compliance officer's investigation of these accounts discloses that the official's longstanding account had no unusual activity and the recently opened account had no activity since it was opened. Which of the following should the compliance officer do next?
- A. Call the competent authorities to assess the need to file a suspicious transaction report.
- B. Wait until the new account receives funds and confirm their source.
- C. Meet with staff who opened the account to understand its nature and purpose.
- D. Call the official's office to confirm the need for multiple accounts.
正解：C
質問 # 221
Which three are principles found in the document "Principles of information Exchange between Financial Intelligence Units (FIUs)"?
- A. The exchange of information between FIUs should take place as informally and as rapidly aspossible and with no prerequisites, while guaranteeing protection of privacy and confidentialityof the shared data
- B. Differences in the definition of offenses that fall under the competence of FIUs should be beforefree exchange of information takes place
- C. The Egmont principle of free exchange of information at the FIU level should be possible on thebasis of reciprocity, including spontaneous exchange
- D. It should be possible for communication between FIUs to take place directly and withoutintermediaries
正解：A、C、D
質問 # 222
In order to protect investigative materials from disclosure when conducting an internal Investigation of any employee of a financial institution, legal counsel of that financial should________?
- A. Refuse to provide any records or documents to law enforcement because the bank has client privilege with its bank customers
- B. Let the bank hire any and all contract investigators to conduct the internal investigation. That way Legal is not a party to the action and may remain independent
- C. Request formal company authorization to conduct the investigation. Such authorization should be granted, if possible, by the board of directors or audit committee
- D. Not mark files or documents with privileged and Confidential: Attorney-Client Privilege and/or Work- Product. Those marks will only encourage law enforcement or opposing attorneys to seize those files
正解：C
質問 # 223
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