2026年最新のCAMS試験解答最新版GoShiken CAMSのPDF問題集をダウンロードせよ（865問題と解答)
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質問 # 92
Which are common types of economic sanctions? (Choose three.)
- A. Supervisory sanctions
- B. Targeted sanctions
- C. SWIFT network sanctions
- D. Technological sanctions
- E. Comprehensive sanction
- F. Sectoral sanctions
正解：B、C、E
解説：
Reference: https://www.cfr.org/backgrounder/what-are-economic-sanctions
質問 # 93
A financial institution has expanded its scope of services so that it is attracting the business of politically exposed persons (PEPs) who had previously never been part of the customer base.
Which two courses of action should the compliance officer include in the institution's procedures for considering PEPs as customers? (Choose two.)
- A. Expedite due diligence when a PEP is pre-approved by a member of senior management
- B. Conduct enhanced ongoing monitoring of the business relationship
- C. Obtain appropriate senior management approval for establishing a business relationship with a PEP from a high risk country
- D. Take adequate measures to establish the source of wealth and source of funds which are involved in the business relationship or occasional transaction
正解：B、D
解説：
According to the Anti-Money Laundering Specialist (the 6th edition) resources, PEPs are individuals who are or have been entrusted with prominent public functions, such as heads of state, senior politicians, senior government, judicial or military officials, senior executives of state-owned corporations, or important political party officials1. PEPs pose a higher risk of money laundering and corruption due to their position and influence2. Therefore, financial institutions should apply enhanced due diligence and ongoing monitoring measures when dealing with PEPs as customers3. This includes:
* Conducting enhanced ongoing monitoring of the business relationship to detect and report any suspicious transactions or activities4. This may involve more frequent reviews, higher-level approvals, or increased documentation of the transactions and the rationale behind them.
* Taking adequate measures to establish the source of wealth and source of funds which are involved in the business relationship or occasional transaction. This may involve verifying the origin, legitimacy, and purpose of the funds, as well as the economic activities and assets of the PEP.
The other two options are incorrect because:
* Expedite due diligence when a PEP is pre-approved by a member of senior management is not a recommended course of action, as it may compromise the quality and integrity of the due diligence process. Pre-approval by senior management does not exempt the financial institution from conducting thorough and timely due diligence on the PEP and the business relationship.
* Obtain appropriate senior management approval for establishing a business relationship with a PEP from a high risk country is a necessary but not sufficient course of action, as it does not address the ongoing monitoring and source of funds aspects of the PEP risk management. Senior management approval is required for establishing or continuing a business relationship with a PEP, regardless of the country of origin or residence of the PEP.
References:
1: ACAMS, CAMS Study Guide, 6th Edition, Chapter 4, p. 83 2: ACAMS, CAMS Study Guide, 6th Edition, Chapter 4, p. 84 3: ACAMS, CAMS Study Guide, 6th Edition, Chapter 4, p. 85 4: ACAMS, CAMS Study Guide, 6th Edition, Chapter 4, p. 86 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 4, p. 87 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 4, p. 86 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 4, p.
87 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 4, p. 88 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 4, p. 88 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 4, p. 88 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 4, p. 88
質問 # 94
The main purpose of the US Treasury Department for OFAC's extraterritorial reach is to:
- A. protect allied nations of the US from the economic threats of non-allied nations.
- B. defend the US against questionable trade practices of its economic rivals.
- C. accomplish the foreign policy and national security goals of the US.
- D. align OFAC's and other countries' extraterritorial reach requirements.
正解：C
解説：
Reference:
https://www.natlawreview.com/article/aggressive-extraterritorial-reach-us-economic-sanctions-foreign-company
質問 # 95
How should a compliance officer respond to law enforcement agencies' request for information on a customer undergoing an investigation?
- A. Share details of the investigation with respective colleagues who deal with this customer type on a daily basis.
- B. Collaborate with the financial institution's (FI's) designated department to determine the appropriate course of action to comply with the request.
- C. Gather all requested documentation and send via secure email to the requesting authority.
- D. Freeze account assets and advise the customer that assets will not be released until the investigation has been completed
正解：B
解説：
A compliance officer should cooperate with the law enforcement inquiry as much as possible, but also ensure that the request is valid, lawful, and does not violate any confidentiality or privacy obligations. Therefore, the compliance officer should collaborate with the FI's designated department, such as the legal counsel, the senior management, or the board of directors, to determine the appropriate course of action to comply with the request12. The compliance officer should also ensure that all communication, written and oral, is funneled through a centralized place, and that the FI maintains a record of the request and the response12.
Reference:
1: Requests by Law Enforcement for Financial Institutions to Maintain Accounts, FinCEN, 2014
2: Best Practices for Compliance and Enforcement-Related Information Requests, EPA, 2018
質問 # 96
Combating the Financing of Terrorism (CFT)]
An EU Trust and Company Service Provider (TCSP) analyst notices some unusual activity while looking through a customer's financial statements and detailed general ledger. The customer is in the business of importing and exporting machineries. Which transaction indicator warrants further escalation to the compliance officer?
- A. The payment of virtual offices services overseas.
- B. The payment of company secretarial retainer fees to a foreign company in a tax efficient jurisdiction.
- C. Inter-company loans from the holding company to the subsidiary company to finance the shipment of machinery.
- D. The payment of consultancy fees to unrelated companies and service providers established in a foreign jurisdiction.
正解：D
解説：
According to the CAMS Study Guide, one of the methods to launder money using TCSPs is to create a complex web of transactions involving multiple entities and jurisdictions, often using shell companies and nominees. The payment of consultancy fees to unrelated companies and service providers established in a foreign jurisdiction could be a sign of such a scheme, as it could be used to disguise the origin and destination of illicit funds, or to evade taxes and regulations. Therefore, this transaction indicator warrants further escalation to the compliance officer.: CAMS Study Guide, 6th Edition, Chapter 2, page 69.
質問 # 97
Which two factors should increase the risk of a correspondent bank customer and require additional due diligence according to the Wolfsberg Anti-Money Laundering Principles for Correspondent Banking? (Choose two.)
- A. The customer is located in a Financial Action Task Force member country and the bank's head of information security is a politically exposed person.
- B. The customer is located in a Financial Action Task Force member country and provides services to other correspondent banks in neighboring countries.
- C. The customer is located in a Financial Action Task Force member country and provides services primarily to a local individual customer.
- D. The customer is located in a non-Financial Action Task Force member country and services mostly commercial customers who engage in international trade.
正解：B、D
質問 # 98
Outgoing foreign transactions of similar amounts trigger a monitoring alert for a customer's accounts. During the evaluation of the accounts, the bank discovers the wire transfers were very small amounts and occurred within the last 3 months following a long period of inactivity. The wire transfers appear to originate from legal sources. To assess the potential of terrorist financing, the institution must ensure the
- A. account holder does not reside in a country included on the U.S. State Department State Sponsors of Terrorism List.
- B. beneficiaries of transfers are not on a terrorist watch list.
- C. account holder presents proof the funds are legal.
- D. beneficiaries of transfers are not included on the Transparency International List.
正解：B
解説：
This is the correct answer because the institution must ensure that the beneficiaries of the transfers are not on a terrorist watch list, such as the United Nations Security Council Consolidated List, the U.S. Treasury Office of Foreign Assets Control (OFAC) Specially Designated Nationals and Blocked Persons List, or the European Union Terrorism List. These lists contain the names of individuals, entities, and groups that are subject to sanctions or other measures due to their involvement or association with terrorism or terrorist financing. The institution must screen the beneficiaries of the transfers against these lists and report any matches or hits to the relevant authorities. Failing to do so may expose the institution to legal, regulatory, or reputational risks, as well as facilitate the financing of terrorism.
Reference:
ACAMS CAMS Certification Video Training Course1, Module 3: International AML/CTF Standards, Lesson 3.2: International AML/CTF Standards ACAMS CAMS Study Guide, 6th Edition2, Chapter 3: International AML/CTF Standards, Section 3.2: International AML/CTF Standards, pp. 57-58 ACAMS CAMS Examination Preparation Seminar, 6th Edition3, Chapter 3: International AML/CTF Standards, Section 3.2: International AML/CTF Standards, Slide 12
質問 # 99
Which actions are involved when a prosecutor instructs a bank to freeze the assets and bank accounts held by one of its clients? (Choose three.)
- A. The institution should obtain a copy of the court order to freeze the assets of the named individuals.
- B. An affidavit must accompany the freeze order for the bank to comply with the request.
- C. Inform other banks in the same geographical area to freeze the client's assets if they are a member of that bank, too.
- D. The institution does not need to comply with the request if the client's assets make the task unusually difficult or complex to access.
- E. Extend the account and asset freeze to the client's family members as a precautionary measure.
- F. Ensure the client and beneficiaries are unable to access any frozen assets during the freeze order.
正解：A、F
質問 # 100
Which is a red flag for funds transfers?
- A. Funds transfers are repeatedly sent to the same beneficiary out of line with the business purpose.
- B. Funds transfers are to a higher-risk geographic location with a known supplier within the same industry as the originator.
- C. Funds transfers are repetitive and within expected patterns.
- D. Funds transfers are received in numerous small quantities from entities that are in related industries.
正解：A
解説：
Funds transfers are electronic payments that move money from one account to another, either within the same financial institution or across different institutions, countries, or currencies1. Funds transfers are commonly used for legitimate purposes, such as remittances, trade, or investment, but they can also be abused by money launderers, terrorists, or fraudsters to move illicit funds or conceal their origin or destination2. Therefore, financial institutions and other entities that offer funds transfer services are required to apply anti-money laundering and counter-terrorism financing (AML/CFT) measures, such as customer due diligence, transaction monitoring, record-keeping, and reporting of suspicious activities2.
One of the red flags for funds transfers that may indicate money laundering or other criminal activity is when funds transfers are repeatedly sent to the same beneficiary out of line with the business purpose3. This could suggest that the originator and the beneficiary are colluding to layer or integrate illicit funds, or to evade reporting or sanctions requirements. For example, a business may send multiple funds transfers to the same supplier, but the amounts or frequencies do not match the invoices or contracts, or the supplier is located in a high-risk jurisdiction or is subject to sanctions. Alternatively, an individual may send frequent funds transfers to the same person, but the relationship or the reason for the transfers is unclear or inconsistent, or the person is associated with a criminal or terrorist organization. In such cases, the financial institution or the funds transfer service provider should conduct enhanced due diligence, verify the source and purpose of the funds, and report any suspicious activity to the relevant authorities.
Reference:
1: Wire Transfer Definition - Investopedia
2: International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation - The FATF Recommendations | FATF
3: Wire Transfer Red Flags: Money Laundering & Fraud Risks - Alessa1
質問 # 101
the Financing of Terrorism (CFT)]
Which transaction should result in a SAR/STR filing?
- A. A national food-chain restaurant with multiple cash transactions at various branch locations.
- B. A national food-chain restaurant makes multiple, anticipated cash transactions that are above the daily reporting threshold.
- C. A small business owner deposits $25,000 USD in cash proceeds with a business equipment bill of sale.
- D. A small business owner deposits checks totaling $9,950 USD on a daily basis without providing a legitimate purpose.
正解：D
解説：
RefThis transaction should result in a SAR/STR filing because it indicates possible structuring, which is a form of money laundering that involves breaking down large amounts of cash into smaller deposits to avoid detection or reporting requirements. Structuring is often done to conceal the source or destination of illicit funds, or to evade taxes, regulations, or sanctions. A small business owner who deposits checks just below the
$10,000 USD threshold on a daily basis without providing a legitimate purpose raises a red flag for suspicious activity and should be reported to the relevant Financial Intelligence Unit.
:
Suspicious Transaction Report (STR) / Suspicious Activity Report (SAR)
What Is a Suspicious Activity Report (SAR)? Triggers and Filing
How to decide if SAR filing is needed
erence: https://aml-cft.net/library/suspicious-transaction-report-str-suspicious-activity-report-sar/
質問 # 102
A foreign bank maintains a correspondent account in the US. According to an investigation carried out by US authorities, the specific correspondent account seems to have facilitated a transaction involving tainted funds.
Which allows the US authorities to seize the funds of the foreign bank held with the US bank?
- A. The USA PATRIOT Act
- B. The FinCEN CDD Final Rule
- C. The 6th EU AML Directive
- D. Regulations of the OFAC, US Department of Treasury
正解：A
質問 # 103
What are two requirements with respect to supporting documentation that is used to identify potentially suspicious activity, according to Financial Action Task Force? (Choose two.)
- A. It must be kept in a manner so that it can be provided promptly
- B. It must only be released to the government through a subpoena process
- C. It must be retained for at least five years
- D. It must be retained for at least seven years
正解：A、C
解説：
Explanation/Reference: https://www.fatf-gafi.org/media/fatf/documents/recommendations/pdfs/FATF%20Recommendations
%202012.pdf
質問 # 104
A bank has opened a new account for a well-known attorney to manage client funds. During the first six months, bank staff observe the account receives multiple deposits via wire transfer. They also observe that the attorney withdraws cash, makes payments to various people, and transfers funds to the law firm's account online.
What is considered a red flag for potential money laundering in this situation?
- A. Transferring funds to his law firm's account online
- B. Withdrawing cash
- C. Making payment to various people
- D. Receiving multiple deposits via wire transfer
正解：C
解説：
According to the ACAMS CAMS Study Guide, one of the methods that attorneys may use to facilitate money laundering is to make payments to third parties on behalf of their clients, using funds from their client accounts. This may obscure the source and destination of the funds, and create a false appearance of legitimate transactions. Therefore, making payment to various people is a red flag for potential money laundering in this situation.
Reference:
ACAMS CAMS Study Guide, 6th Edition, page 117
FATF Report on Money Laundering and Terrorist Financing Vulnerabilities of Legal Professionals, June 2013, page 341 AML/CFT Red Flags for Lawyers, AML-CFT.net, October 20202
質問 # 105
A United States (U.S.) bank was recently alerted by law enforcement of an increase in sale of large denomination U.S. bank notes to casas de cambio. They suspect that a Mexican syndicate is operating a money laundering scheme in the bank's jurisdiction.
Which two steps should be taken to trace funds through the bank to assist law enforcement in their investigation? (Choose two.)
- A. Identify if there is a decrease in the sale of large denomination U.S. bank notes to casas de cambio by the bank
- B. Identify the money laundering scheme and submit a suspicious transaction report
- C. Identify deposits by casas de cambio that include third-party items including sequentially numbered monetary instruments
- D. Identify multiple wire transfers initiated by casas de cambio to jurisdictions outside of Mexico that bear no apparent business relationship with that casa de cambio
正解：C、D
質問 # 106
An anti-money laundering specialist at a financial institution has received a legal request to provide all transaction records for a specific individual since 2004. Which of the following item s should be delivered?
1. Monthly statements and transaction activities for that individual since 2004.
2. All wire transfers for that individual since 2004.
3.Signature cards from accounts opened by that individual since 2004.
4. All security trading activities for that individual since 2004.
- A. 2, 3, and 4 only
- B. 1, 2, and 3 only
- C. 1, 2, and 4 only
- D. 1, 3, and 4 only
正解：C
解説：
According to the CAMS study guide, chapter 4, page 1191, transaction records include any records that reflect the movement of funds or assets, such as wire transfers, checks, deposits, withdrawals, securities trades, etc. Therefore, items 1, 2, and 4 are examples of transaction records that should be delivered in response to a legal request. Item 3, signature cards, are not transaction records, but rather account opening documents that contain the customer's name, address, identification, and signature. These documents may be relevant for customer due diligence or identification purposes, but they do not reflect the transaction activities of the customer.
References:
1: ACAMS CAMS Study Guide - 6th Edition, Chapter 4, page 119: https://www.acams.org/wp-content
/uploads/2019/09/ACAMS-CAMS-Study-Guide-6th-Edition-Chapter-4.pdf
質問 # 107
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