
ACAMS CAMS試験問題集で[2025年最新] 有効な試験練習問題集解答
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CAMS試験では、AMLに関連する幅広いトピックをカバーしています。これには、マネーロンダリングの傾向と方法、リスク評価、顧客のデューデリジェンス、不審な活動報告、制裁コンプライアンスなどがあります。この試験は、これらのトピックに関する候補者の知識と理解を測定するように設計されています。また、この知識を実際の状況に適用する能力があります。
CAMS認定プロフェッショナルになるためには、AMLの主要な概念、マネーロンダリングトポロジー、金融システムと規制、コンプライアンスプロセス、および調査技術をカバーする厳しい試験に合格する必要があります。試験は、4時間以内に完了する必要がある120の多肢選択問題で構成されています。試験に合格するだけでなく、候補者はACAMSが設定するその他の資格要件を満たし、少なくとも40時間のAMLトレーニングを受ける必要があります。AMLフレームワークの包括的なカバレッジとグローバルに認知されたステータスを持つCAMS認定は、AML分野でキャリアを進めたいプロフェッショナルにとって必要不可欠な資格です。
CAMS認定試験は、マネーロンダリング(AML)、テロ資金供与防止(CTF)、および金融犯罪防止に従事する専門家を対象としています。試験はAML規制、AMLコンプライアンスプログラム、リスク評価、顧客デューデリジェンス、取引監視、制裁スクリーニングなど、幅広いトピックをカバーしています。試験はまた、候補者が複雑な金融犯罪シナリオを分析し、最新のAML / CTF技術と手法を適用して金融犯罪を防止および検出する能力をテストします。
質問 # 87
Which practices are dealers in antiques, precious metals, precious stones, jewelry, and art advised to follow to reduce the element of money laundering risk? Choose 3 answers
- A. Insist all vendors submit an appropriate license issued by enforcement agencies authorizing the sale
- B. Avoid accepting cash payment from the buyers
- C. Verify the identities of all new vendors and customers and conduct due diligence on them
- D. Insist on all vendors signing a declaration that the item placed by them for sale was not stolen or acquired through illegitimate means
正解:A、B、C
質問 # 88
A bank maintains a number of United States (U.S.) dollar correspondent accounts for foreign financial institutions. Upon a routine review of a U.S. dollar correspondent account owned by Foreign Bank A, a number of transactions appear to have been originated by Foreign Bank B outside the expected activity for this account. These transactions appear suspicious and a suspicious transaction report was filed by the compliance officer.
Which step should the compliance officer take?
- A. Notify other U.S. financial institutions who maintain U.S. dollar correspondent accounts for Foreign Bank A and Foreign Bank B in an effort to shut down the activity
- B. Notify senior management of the money laundering risks by allowing Foreign Bank A to maintain its U.S. dollar correspondent account
- C. Notify Foreign Bank A of the discovery and seek documentation supporting Foreign Bank A was collusive and a willing partner with Foreign Bank B in the activity
- D. File a report with the appropriate tax authorities in the jurisdictions of Foreign Bank A and Foreign Bank B
正解:C
質問 # 89
A national Financial Intelligence Unit, which is responsible for receiving, analyzing and disseminating disclosure of financial information, should consider becoming a member of what organization?
- A. The Egmont Group
- B. The Financial Action Task Force
- C. The Wolfsberg Group
- D. The Basel Committee
正解:A
質問 # 90
Which assessments are involved in the processes of mutual evaluation and follow-up by the FATF?
- A. Technical compliance assessments and effectiveness assessment
- B. Risk assessments and technical standards assessments
- C. Country audit assessments and transaction monitoring assessments
- D. Sanction risk assessments and the country's National Risk Assessment
正解:A
解説:
Reference:
https://www.fatf-gafi.org/publications/mutualevaluations/more/more-about-mutual-evaluations.html?hf=10&b=0
質問 # 91
A bank compliance officer has implemented enhanced monitoring rules that have identified some unusual activity that may be indicative of human trafficking.
Which red flag should prompt additional transactional review?
- A. Cash deposits that occur in cities where the customer does not reside or conduct business followed by same-day withdrawals
- B. Cash deposits that occur in cities where the customer resides and conducts business
- C. Cash deposits that occur in cities where the customer does not reside or conduct business
- D. Wire transfer activity from countries with significant migrant populations
正解:A
質問 # 92
A customer living in a high-risk jurisdiction makes frequent, large cash deposits at a bank. The same customer sends small wire transfers to unrelated parties in other high-risk jurisdictions.
What are two red flags that may indicate money laundering? (Choose two.)
- A. Wire transfers are to high-risk jurisdiction
- B. Large cash deposits are from a high-risk jurisdiction
- C. The bank allows cash deposits
- D. The client resides in a high-risk jurisdiction
正解:A、B
質問 # 93
Which assessments are involved in the processes of mutual evaluation and follow-up by the FATF?
- A. Technical compliance assessments and effectiveness assessment
- B. Risk assessments and technical standards assessments
- C. Country audit assessments and transaction monitoring assessments
- D. Sanction risk assessments and the country's National Risk Assessment
正解:A
解説:
The FATF conducts peer reviews of each member on an ongoing basis to assess levels of implementation of the FATF Recommendations, providing an in-depth description and analysis of each country's system for preventing criminal abuse of the financial system. The FATF Methodology for assessing compliance with the FATF Recommendations and the effectiveness of AML/CFT systems sets out the evaluation process.
Assessments focus on two areas, effectiveness and technical compliance. The effectiveness component will assess whether the AML/CFT systems are working, and the extent to which the country is achieving the defined set of outcomes. The technical compliance component will assess whether the necessary laws, regulations or other required measures are in force and effect, and whether the supporting AML/CFT institutional framework is in place.
References:
* Mutual Evaluations - Financial Action Task Force
* FATF Methodology for assessing compliance with the FATF Recommendations and the effectiveness of AML/CFT systems
* Procedures for the FATF Fourth Round of AML/CFT Mutual Evaluations
Reference: https://www.fatf-gafi.org/publications/mutualevaluations/more/more-about-mutual-evaluations.
html?hf=10&b=0&s=desc(fatf_releasedate)
質問 # 94
Which key aspect of the Office of Foreign Assets Control's extraterritorial reach specifically relates to prohibited transactions?
- A. Prohibit or reject licensed trade and financial transactions with specified countries, entities and non-U.
- B. Prohibit or reject unlicensed foreign trade and financial transactions with specified countries, entities, and individuals.
- C. individuals
- D. Prohibit or reject licensed trade and financial transactions with specified countries, entities and U.S.
individuals - E. Prohibit or reject unlicensed trade and financial transactions with specified countries, entities, and individuals
正解:E
解説:
the Office of Foreign Assets Control (OFAC) has the authority to prohibit or reject any trade or financial transactions involving specified countries, entities, and individuals that are subject to U.S. economic sanctions, unless such transactions are authorized by a general or specific license issued by OFAC. This applies to transactions that occur within the U.S. territory, as well as transactions that involve U.S. persons, U.
S. goods, or the U.S. financial system, regardless of where they take place. This is one of the key aspects of OFAC's extraterritorial reach, which means that OFAC can enforce its sanctions programs beyond the U.S.
borders.
References:
* Home | Office of Foreign Assets Control, section "Mission": "The Office of Foreign Assets Control ("OFAC") of the US Department of the Treasury administers and enforces economic and trade sanctions based on US foreign policy and national security goals against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the United States."
* The Aggressive Extraterritorial Reach of U.S. Economic Sanctions: Foreign Company Exposure to OFAC Enforcement, section "A. Bases for OFAC jurisdiction over foreign parties", paragraph 1: "One key aspect of the Office of Foreign Assets Control's extraterritorial reach includes the blocking of certain non-United States initiated transactions for or through the United States (U.S.) for benefit of a restricted person or entity."
* The global reach of OFAC sanctions, section "The global reach of OFAC sanctions", paragraph 1:
"OFAC sanctions are trade and economic sanctions administered by The U.S. Treasury Department's Office of Foreign Asset Control (OFAC). They are often intended to have extra-territorial effect, meaning that they apply outside the U.S. territory. In some instances a connection with the U.S.
territory is required."
"Prohibit or reject unlicensed trade and financial transactions with specified countries, entities, and individuals. "
質問 # 95
Which red flag should a compliance officer prioritize first for investigation?
- A. A loan is paid off in full with cash after the sale of the vehicle that was used as collateral for the loan.
- B. Several cross-border transfers are received and immediately wired to another beneficiary.
- C. A customer has 20 monthly transactions that are repetitive but less than $500 USD per transaction.
- D. A convenience store cashes government checks for its customers in amounts less than $1,000 USD per day.
正解:B
解説:
This is a common red flag of money laundering that involves layering, which is the process of moving funds through multiple accounts or entities to conceal their origin and ownership. Layering often involves cross-border transfers, especially to high-risk jurisdictions, and rapid movement of funds to avoid detection or tracing. A compliance officer should prioritize this red flag for investigation, as it may indicate a complex money laundering scheme or the financing of terrorism or proliferation.
References:
AML Red Flags - What are the Top 10 Indicators? - ComplyAdvantage, section "Red flags related to transaction patterns" AML 101: The 10 Most Common Red Flags - KYC-Chain, section "Red flag indicators related to geographical risks" Anti-money laundering red flags, page 2, bullet point 5
質問 # 96
What is the intentional evasion of a reporting or recordkeeping requirement?
- A. Structuring
- B. Layering
- C. Money laundering
- D. Placement
正解:A
解説:
Structuring is the intentional evasion of a reporting or recordkeeping requirement by breaking down a large transaction into smaller ones, or by using multiple accounts, institutions, or persons to avoid triggering the threshold for reporting or recordkeeping. Structuring is also known as smurfing, and it is a common technique used by money launderers to conceal the source, ownership, or control of illicit funds.
References: =
ACAMS Study Guide for the CAMS Certification Examination, 6th Edition, Chapter 2, Section 2.1.1, page 511 ACAMS CAMS Certification Video Training Course, Module 2, Lesson 2.1, video time 7:00-8:002 ACAMS CAMS Certification Practice Exam, Question 134, page 2853
質問 # 97
What is true regarding disclosure to a law enforcement agency by a financial institution of the supporting documentation for a suspicious transaction report?
- A. The financial institution may notify the account holder of the request
- B. Documentation must be provided as quickly as possible using email
- C. Confirm that the request originated from a representative of the law enforcement agency
- D. A copy of all the documentation released must also be provided to the account holder's attorney
正解:C
質問 # 98
A corporate services provider in a European Union (EU) country has a prospect from an African country who deals in oil and gas. The prospect intends to develop an oil terminal in his home country with a $75 million dollar loan secured by a third party, which is a trust formed in a Caribbean island with a holding company based in a European secrecy haven. A young lady is presented as an ultimate beneficial owner who has gained her wealth through a fitness studio in her home country.
What are two red flags that could indicate money laundering or financing terrorism? (Choose two.)
- A. The guarantor company's ownership structure is overly complex
- B. A loan worth $75 million with a third-party guarantor
- C. The prospect wishes to have a corporate structure with a holding company in EU country
- D. The ultimate beneficial owner is young lady who has gained her wealth through a small business
正解:A、B
質問 # 99
An institution is about to release a new peer to peer (P2P) funds transfer product to provide much needed remittance services to an under-banked population segment in the country.
The service allows customers to transfer funds through a mobile banking application to individuals worldwide entering only a name and mobile number. The new service charges less than comparable market solutions and offers real time transfer of funds. The customer onboarding process is conducted at branch locations with identity verification.
Which three present the highest anti-money laundering or sanctions risk and will require controls prior to launch? (Choose three.)
- A. Customer onboarding
- B. Servicing the under-banked population
- C. Cross-border functionality
- D. Limited access to counterparty information
- E. Real time transfer of funds
正解:C、D、E
解説:
The correct answer is B, C, and E, as these three present the highest anti-money laundering or sanctions risk and will require controls prior to launch. According to the FATF Updated Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers1, P2P transactions pose significant challenges for AML/CFT compliance, as they may involve anonymous or pseudonymous parties, cross-border transfers, real-time settlement, and limited information on the beneficiaries. These factors increase the risk of money laundering, terrorist financing, and sanctions evasion, as well as the difficulty of detecting and reporting suspicious activity. Therefore, the institution should implement appropriate controls to mitigate these risks, such as:
Conducting enhanced due diligence on customers who use the P2P service, especially if they are located in high-risk jurisdictions or are involved in high-risk activities1.
Implementing transaction monitoring systems that can identify and flag unusual or suspicious patterns of behavior, such as large or frequent transfers, transfers to or from sanctioned entities or countries, or transfers that do not match the customer's profile or expected activity12.
Applying the travel rule, which requires the originator and beneficiary VASPs (or financial institutions) to exchange and retain information on the parties involved in the transfer, such as their names, account numbers, addresses, and national identification numbers13.
Establishing information-sharing and cooperation mechanisms with other VASPs, financial institutions, and regulators, to facilitate the exchange of relevant data and intelligence on P2P transactions and customers14.
References: 1: Updated Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers - FATF, page 13-16, 28-29, 32-33, 40-412: AML and Compliance Solution for The P2P Industry - Sanction Scanner3: P2P Money Laundering: How to Comply - ComplyAdvantage4: 2024 National Money Laundering Risk Assessment - U.S. Department of the Treasury, page 17.
質問 # 100
During a law enforcement investigative interview regarding potential money laundering, the suspect starts making assertions and statements that the investigator believes are false.
How should the investigator respond?
- A. Inform the suspect that deception is obvious and continue the interview
- B. Ask questions of a material nature about the suspected false statements without revealing the suspected deception
- C. Direct the interview in another direction until there is better rapport before returning back to the troubling questions
- D. Advise the suspect that the interview will be terminated if there is suspicion of deception
正解:B
質問 # 101
A compliance officer is looking to update an institutions private bank procedures. What should be included as recommended by the Wolfsberg AML Principles on Private Banking?
- A. Dedicated automated AML monitoring of client activity
- B. Approval of Politically Exposed Persons (PEPs) by at least one person other than the relationship manager
- C. The institution's senior management has primary responsibility for the relationship
- D. Review of client files annually if there are unusual transactions
正解:B
解説:
https://www.wolfsberg-principles.com/sites/default/files/wb/pdfs/wolfsbergstandards/10.%20Wolfsberg- Private-Banking-Prinicples-May-2012.pdf
2.4 Senior Management Approval
The bank's internal policies should indicate whether, for any one or more among these categories, Senior Management must approve entering into new relationships.
Relationships with Politically Exposed Persons may only be entered into with the approval of Senior Management.
質問 # 102
A relationship manager in a bank has had a private banking customer for 10 years. The customer has business accounts and investments and seeks advice on the creation of a company overseas. The relationship manager refers the customer to the commercial banking manager and vouches for the customer. Which of the following risk factors is the most important?
- A. Entities that are to receive funds from this company are located in the same country.
- B. The company wants to transfer funds in large, even amounts.
- C. The proposed offshore jurisdiction is known for its strong privacy laws limiting access to customer information by law enforcement.
- D. The customer does not want to provide more information than when the first account was opened.
正解:C
解説:
The most important risk factor in this scenario is the proposed offshore jurisdiction that is known for its strong privacy laws limiting access to customer information by law enforcement. This indicates that the customer may be trying to evade tax, hide the source or destination of funds, or engage in other illicit activities that could expose the bank to money laundering or terrorist financing risks. Offshore jurisdictions are often used by criminals to create complex corporate structures that obscure the beneficial ownership and control of the entities involved. The bank should conduct enhanced due diligence on the customer, the offshore company, and the nature and purpose of the transactions.
References:
* ACAMS CAMS Certification Study Guide, 6th Edition, Chapter 2, page 35-36, 38-39
* ACAMS CAMS Certification Video Training Course, Module 2, Lesson 2.3, Offshore Financial Centers
* 1, CAMS Certification Package - 6th Edition | ACAMS, Offshore Financial Centers and Money Laundering
* 2, CAMS Certifications: How to Get CAMS Certified | ACAMS, CAMS Exam Outline, Domain 2, Task 2.3
質問 # 103
Which is an emerging risk associated with cyber-enabled fraud?
- A. Frequent transactions in round or whole dollars
- B. Multiple people colluding to place funds in the financial market
- C. Receipt of joint account wire transfers
- D. Mismatch between account names and government-issued documentation
正解:D
解説:
This is an emerging risk associated with cyber-enabled fraud because the use of false identities and documents can allow criminals to disguise their activities and evade detection. In such cases, the name and address provided on the account may not match the name and address on the government-issued documentation. This discrepancy can be difficult to detect, making it a potential risk for financial institutions.
質問 # 104
Which Trust parties should be identified to determine the true nature of the Trust relationship according to Basel guidelines? (Choose three.)
- A. Trustees
- B. Payees
- C. Settlors/grantors
- D. Beneficiaries
- E. Trust Administrators
- F. Respondents
正解:A、B、D
質問 # 105
To ensure that an institution's anti-money laundering program is current, which step should be taken?
- A. The program should be reassessed at least annually
- B. The program should be evaluated and updated at least every six months be the Board of Directors
- C. The program should be sent to the institution's government regulator on a periodic basis
- D. The program should be reviews by a federal law enforcement officer for gaps in controls
正解:C
質問 # 106
When should new business products to evaluated for AML concerns?
- A. Before they are launched into the market
- B. At the time of the next enterprise risk assessment
- C. On an annual basis
- D. After they have been implemented so there is empirical data to review
正解:A
解説:
Explanation
new requirement for the identification and assessment of risks of new products prior to the launch of the new product;
質問 # 107
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