最新（2025)ACAMS CAMS試験問題集
最適な練習法にはACAMS CAMS試験の素晴らしいCAMS試験問題PDF
CAMS認定試験は、コンプライアンス担当者、リスクマネージャー、調査員、監査人など、マネーロンダリング防止分野の専門家向けに設計されています。この試験では、マネーロンダリングテクニック、マネーロンダリングアンチマネーロンダリング法と規制、コンプライアンスプログラム、リスク評価、デューデリジェンスなど、幅広いトピックをカバーしています。試験はオンラインで実施され、4時間以内に完了する必要がある120の複数選択質問で構成されています。試験の合格スコアは75％です。
ACAMS CAMS試験では、リスク評価、規制コンプライアンス、デューデリジェンス、調査など、マネーロンダリングアンチマネーロンダリングに関連する幅広いトピックをカバーしています。この試験は、複数選択の質問で構成され、コンピューターベースの形式で管理されます。試験に合格するには、候補者はAMLの景観を完全に理解し、この知識を実際のシナリオに適用できるようにする必要があります。
質問 # 288
What are some red flags financial institutions should be aware of when trying to verify the identity of a customer? Choose 3 answers
- A. Customer being new to the community
- B. Customer having unusual documents from a foreign country
- C. Customer having no permanent address
- D. Customer not having a connected phone
正解：B、C、D
質問 # 289
What is a key risk associated with Correspondent Accounts according to the Basel Customer Due Diligence paper?
- A. The service fees are insufficient to cover the cost of managing the account
- B. The volume and value of transactions passing through the account may not be in line with the original correspondent agreement
- C. The respondent bank's customer acceptance and know your customer policies are ineffective
- D. It is not used on a daily basis
正解：C
解説：
Explanation
https://www.bis.org/publ/bcbs85.pdf - page 12
Banks should gather sufficient information about their respondent banks to understand fully the nature of the respondent's business. Factors to consider include: information about the respondent bank's management, major business activities, where they are located and its money-laundering prevention and detection efforts; the purpose of the account; the identity of any third party entities that will use the correspondent banking services; and the condition of bank regulation and supervision in the respondent's country. Banks should only establish correspondent relationships with foreign banks that are effectively supervised by the relevant authorities. For their part, respondent banks should have effective customer acceptance and KYC policies.
質問 # 290
An alert has been triggered by a monitoring system and an investigation has been opened. The activity involves significant and multiple cash deposits into a personal account and transferring funds to an offshore bank on the same day. Further investigation reveals this personal account had experienced low levels of activity for the past 6 months and funds are transferred to the account of a charitable organization. Which of the following is the next step that the Compliance Officer should take?
- A. Place the charitable organization on the bank's internal "watchlist."
- B. Prohibit further transactions with the charitable organization.
- C. File a suspicious transaction report with the competent authority.
- D. Conduct enhanced due diligence on the charity's trustees.
正解：C
質問 # 291
What are three potential issues for foreign financial institutions maintaining correspondent accounts with U.S.
banks under the Patriot Act? Choose 3 answers
- A. Cancellation of correspondent banking relationships
- B. Prohibition of correspondent accounts for shell banks
- C. U.S. residents maintaining private banking accounts
- D. Forfeiture of funds in a U.S. interbank account
正解：A、B、D
解説：
The Patriot Act, enacted in 2001, introduced several provisions to enhance the anti-money laundering and counter-terrorist financing (AML/CFT) measures for U.S. banks and their foreign correspondent relationships.
Some of the potential issues for foreign financial institutions (FFIs) maintaining correspondent accounts with
U.S. banks under the Patriot Act are:
* Cancellation of correspondent banking relationships: The Patriot Act requires U.S. banks to conduct due diligence and enhanced due diligence on their foreign correspondent accounts, and to terminate any account that poses a significant risk of money laundering or terrorist financing. This may result in the cancellation of correspondent banking relationships with FFIs that do not meet the U.S. standards or cooperate with the U.S. authorities. The loss of correspondent banking relationships may affect the FFIs' ability to access the U.S. financial system and provide services to their customers.
* Forfeiture of funds in a U.S. interbank account: The Patriot Act authorizes the U.S. government to seize and forfeit any funds in a U.S. interbank account that are involved in or traceable to money laundering or terrorist financing activities. This means that FFIs may face the risk of losing their funds in a U.S.
interbank account if they or their customers are suspected or accused of engaging in illicit activities. The forfeiture of funds may have significant financial and reputational consequences for the FFIs and their customers.
* Prohibition of correspondent accounts for shell banks: The Patriot Act prohibits U.S. banks from establishing or maintaining correspondent accounts for shell banks, which are banks that have no physical presence in any country and are not affiliated with a regulated financial group. This means that FFIs that are shell banks or have relationships with shell banks cannot access the U.S. financial system through correspondent accounts. The prohibition of correspondent accounts for shell banks aims to prevent the use of shell banks as vehicles for money laundering and terrorist financing.
References:
* CAMS Study Guide, 6th Edition, Chapter 4: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), pp. 81-841
* USA PATRIOT Act, Title III: International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001, Sections 312, 319, and 3132
* Wolfsberg Anti-Money Laundering Principles for Correspondent Banking, October 2014, pp. 3-43 Reference: http://www.ffiec.gov/bsa_aml_infobase/pages_manual/olm_027.htm
質問 # 292
A bank receives a wire transfer that references the sale of equipment to a sanctioned company. The bank's operations team removes the sanctioned company reference and allows the wire transfer to process. This is a description of what type of activity?
- A. Layering
- B. Cover payment misuse
- C. U-turn payment
- D. Wire stripping
正解：D
解説：
Wire stripping is the process of removing or altering the identifying information associated with a wire transfer to make it difficult to trace the origin or destination of the funds. This technique is commonly used in money laundering schemes to conceal the illicit source of funds and avoid detection by authorities or sanctions screening systems. In this case, the bank's operations team deliberately removed the reference to the sanctioned company from the wire transfer message, thus violating the FinCEN "Travel Rule" and facilitating the evasion of sanctions.
References:
Wire Stripping in Anti Money Laundering Parlance
Wire Transfer Red Flags: Understanding Money Laundering and Fraud Risks Wire Stripping
質問 # 293
What is the term for trading through multiple accounts, where an individual generates offsetting profits and losses and transfers of positions through accounts that do not appear to be commonly controlled?
- A. Wash Trading
- B. Market Manipulation
- C. Net Trading
- D. Ponzi scheme
正解：A
解説：
Wash trading is the term for trading through multiple accounts, where an individual generates offsetting profits and losses and transfers of positions through accounts that do not appear to be commonly controlled.
Wash trading is a form of market manipulation that creates artificial trading activity and volume, and may be used to evade taxes, inflate prices, or launder money. Wash trading can also involve the use of third parties or intermediaries to conceal the true identity and source of funds of the trader.
References: = The main references for this question are the following sources:
* The document titled "Money Laundering and Terrorist Financing Typologies and Trends in Canadian Securities Dealers" published by the Investment Industry Regulatory Organization of Canada (IIROC) in December 2019. You can access it by clicking here. This document states that "Wash trading is a form of market manipulation where an individual simultaneously sells and buys the same financial instruments to create misleading, artificial activity in the marketplace. Wash trading is illegal under securities law because it misleads investors and regulators about the true supply and demand of the securities involved. Wash trading can also be used to evade taxes, inflate prices, or launder money."
* The document titled "Market Manipulation" published by the Financial Industry Regulatory Authority (FINRA). You can access it by clicking here. This document states that "Wash sales are a form of market manipulation in which an investor simultaneously sells and buys the same security to create misleading, artificial activity in the marketplace. Wash sales are illegal under Section 9(a)(1)(A) of the Securities Exchange Act of 1934. Wash sales can be used to manipulate the price of a security, evade taxes, or launder money."
質問 # 294
Pursuant to the Third European Union Money Laundering Directive, how long after being out of prominent office should a person NOT be considered to be a Politically Exposed Person (PEP)?
- A. 2 years
- B. 3 years
- C. 1 year
- D. 4 years
正解：A
解説：
According to the Third European Union Money Laundering Directive (3rd AMLD), a politically exposed person (PEP) is an individual who is or has been entrusted with prominent public functions, such as heads of state, government ministers, judges, senior military officers, or members of parliament1. The 3rd AMLD requires institutions and persons covered by the Directive to apply enhanced customer due diligence measures when dealing with PEPs residing in another Member State or in a third country, in order to prevent money laundering and terrorist financing risks1. The 3rd AMLD also specifies that a person who is no longer entrusted with a prominent public function shall not be considered a PEP after a period of at least one year has elapsed since that person left office, unless the institution or person covered by the Directive has knowledge or reason to believe that the person is still exposed to specific risks2. However, the Commission Directive
2006/70/EC, which lays down implementing measures for the 3rd AMLD, extends this period to at least two years, and allows Member States to extend it further, depending on the level of risk and the type of prominent public function involved3.
References:
1: Directive 2005/60/EC of the European Parliament and of the Council of 26 October 2005 on the prevention of the use of the financial system for the purpose of money laundering and terrorist financing
2: Article 3(8) of Directive 2005/60/EC
3: Article 2 of Commission Directive 2006/70/EC of 1 August 2006 laying down implementing measures for Directive 2005/60/EC of the European Parliament and of the Council as regards the definition of 'politically exposed person' and the technical criteria for simplified customer due diligence procedures and for exemption on grounds of a financial activity conducted on an occasional or very limited basis
質問 # 295
What are two sources for maintaining up-to-date sanctions information? (Choose two.)
- A. Financial Action Task Force's list of High Risk and Non-Cooperative Jurisdictions
- B. U.S. Department of the Treasury Office of Foreign Assets Control
- C. U.S. Federal Bureau of Investigation's National Security Letters
- D. U.S. Department of the Treasury - Section 311 - Special Measures
正解：A、B
解説：
Reference: https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_lists.aspx#search
質問 # 296
In the summer, an institution identifies anti-money laundering concerns regarding a customer's account activity.
The customer, an ice cream parlor, has deposited a lot of checks drawn on banks in foreign countries, sent large number of high dollar international wires to different countries, made cash deposits of a few hundred dollars every few days and written multiple checks for a few hundred dollars to the same dozen payees every two weeks.
Which two transaction types warrant investigation? (Choose two.)
- A. The wires to foreign countries
- B. Regular cash deposits
- C. Repeated checks to the same payees
- D. Checks drawn on banks in foreign countries
正解：A、D
質問 # 297
What does the Basel Committee's Customer Due Diligence for Banks paper suggest that a bank needs to have in place when establishing an account for a corporate business entity?
- A. An understanding of the structure of the company
- B. A process to ensure that the approval of senior management is obtained prior to opening the account
- C. A fee structure that reflects the banks' costs in monitoring the risks associated with entity's business activities
- D. A policy requiring all identified beneficial owners to undergo a national police check
正解：D
質問 # 298
Which are primary purposes of Financial Action Task Force {FATF)-Style Regional Bodies? (Select Two.)
- A. Promoting effective implementation of FATF recommendations
- B. Providing due diligence for foreign correspondent banks
- C. Imposing special measures for non-cooperative jurisdictions
- D. Acting as a prudential regulatory body for financial institutions
- E. Providing expertise and input in FATF policy-making
正解：A、E
解説：
Explanation
The primary purposes of Financial Action Task Force (FATF)-Style Regional Bodies are to promote effective implementation of FATF recommendations and to provide expertise and input in FATF policy-making.
(CAMS Manual, 6th Edition, Page 180)
質問 # 299
According to the Financial Action Task Force Special Recommendations on Terrorist Financing, which of the following should an anti-money laundering specialist do if the specialist has reasonable grounds to suspect funds are linked or related to terrorist acts?
- A. Contact the institution's legal advisor.
- B. Conduct a full due diligence review of the client.
- C. Promptly report to the competent authority.
- D. Inform the institution's managing Board.
正解：C
解説：
According to the Financial Action Task Force (FATF) Special Recommendation IV, if financial institutions, or other businesses or entities subject to anti-money laundering obligations, suspect or have reasonable grounds to suspect that funds are linked or related to, or are to be used for terrorism, terrorist acts or by terrorist organisations, they should be required to report promptly their suspicions to the competent authorities1. This is consistent with the FATF Recommendation 20, which requires the same reporting obligation for money laundering and the financing of proliferation of weapons of mass destruction2.
Reporting suspicious transactions related to terrorism is a key measure to detect, prevent and suppress the financing of terrorism and terrorist acts, and to facilitate international cooperation and information exchange.
References:
* 1: The FATF Recommendations - Financial Action Task Force
* 2: IX Special Recommendations - Financial Action Task Force
質問 # 300
When the minimum CDD standards of the home and host countries differ, the offices in the host countries should follow which requirements?
- A. Local rules and regulations
- B. The CDD standards required by the home country
- C. The minimum required
- D. The higher standard of the two
正解：D
質問 # 301
How do payable through accounts (PTAs) differ from normal foreign correspondent accounts?
- A. The customers can contact the correspondent bank directly to send wire transfers
- B. The customers can hide their identity through the use of cover payments in U.S. dollars
- C. The customers do not have to worry about sanctions list screening such as OFAC
- D. The customers have the ability to directly control funds at the correspondent bank
正解：D
質問 # 302
FATF recommends the incorporation of some measures in customer due diligence (CDD) programs including:
- A. identifying the products and services and their suitability to customers.
- B. conducting the risk assessment of products and services.
- C. conducting ongoing due diligence on the business relationship and monitoring of transactions.
- D. identifying the number of beneficial owners without the verification of their true identity.
正解：C
解説：
According to the FATF Recommendation 10, financial institutions should conduct ongoing due diligence on the business relationship and scrutiny of transactions undertaken throughout the course of that relationship to ensure that the transactions being conducted are consistent with the institution's knowledge of the customer, their business and risk profile, including, where necessary, the source of funds. This is one of the core measures of customer due diligence (CDD) that aim to prevent and detect money laundering and terrorist financing risks.
References: = The main reference for this question is the document titled "International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation - The FATF Recommendations" published by the FATF in February 2018. You can access it by clicking here. You can also find more information about the CDD measures and the risk-based approach on the FATF website, the CFATF website, the Central Bank of Ireland website, and the Medium blog.
質問 # 303
According to the Basel Committee's principles on customer due diligence, a bank should:
- A. file a suspicious activity report when there is reason to believe the bank is being used for criminal activity.
- B. maintain systems to detect suspicious transactions based on a customer's velocity and volume patterns.
- C. obtain the information to establish the identity of a customer, beneficial owners, and any person acting on behalf of the customer,
- D. refuse to conduct ongoing business with a customer who fails to provide proper identification documentation.
正解：C
解説：
According to the Basel Committee's principles on customer due diligence, banks must obtain the necessary information to establish the identity of their customers, beneficial owners, and any persons acting on behalf of their customers. This includes verifying the identity of the customer and the beneficial owners and assessing the customer's risk profile. Additionally, banks must conduct ongoing due diligence to ensure that the customer does not give rise to suspicions of money laundering or terrorist financing [1].
質問 # 304
Bank A is a non-United States (U.S.) bank that has $5 million in a correspondent account at a bank in New York City. The Worldwide Terrorist Syndicate (WTS) has $1 million in its account at a non-US branch of Bank A. The U.S. government has initiated forfeiture action against the WTS.
Which potential action can the U.S. take under the USA PATRIOT ACT pursuant to the issuance seizure warrant?
- A. Seize WTS' $1 million account at the non-U.S. branch of Bank A.
- B. Seize Bank A's $5 million correspondent account in the U.S.
- C. Seize $5 million from the non-U.S. branch of Bank A where the WTS' account is located.
- D. Seize $1 million from Bank A's correspondent account in the U.S.
正解：D
解説：
This potential action is authorized by Section 319 of the USA PATRIOT ACT, which allows the U.S.
government to seize funds from a foreign bank's correspondent account in the U.S. if the foreign bank refuses to cooperate with a request for records relating to an investigation of money laundering or terrorist financing.
The U.S. government can seize an amount equal to the funds in the account of the target of the investigation, regardless of whether those funds are actually in the correspondent account. In this case, the U.S. government can seize $1 million from Bank A's correspondent account in the U.S. because Bank A holds $1 million in the account of the WTS, which is the target of the forfeiture action.
The other potential actions are not authorized by the USA PATRIOT ACT or other U.S. laws. The U.S.
government cannot seize Bank A's entire $5 million correspondent account in the U.S. because that would exceed the amount in the WTS's account and would violate the principle of proportionality. The U.S.
government cannot seize the WTS's $1 million account at the non-U.S. branch of Bank A because that would require the cooperation of the foreign jurisdiction where the branch is located, which may not be forthcoming.
The U.S. government cannot seize $5 million from the non-U.S. branch of Bank A where the WTS's account is located because that would also require the cooperation of the foreign jurisdiction and would exceed the amount in the WTS's account.
References:
CAMS Certification Package - 6th Edition | ACAMS, Chapter 3: International Standards and Global Initiatives, pp. 67-68 CAMS Certifications: How to Get CAMS Certified | ACAMS, CAMS Study Guide, pp. 54-55 How Does the Patriot Act Affect Criminal Investigations? | Nolo, Section 319: Forfeiture of Funds in United States Interbank Accounts The USA PATRIOT Act at 20: Sneak and Peek Searches - CRS Reports, Section 319: Forfeiture of Funds in United States Interbank Accounts
質問 # 305
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CAMS資格は、金融サービス業界の雇用主にとって非常に価値があり、コンプライアンスとリスク管理に対するコミットメントを証明します。さらに、多くの規制機関や法執行機関がCAMS資格をAML分野の専門知識の証明として認めています。CAMS資格を持つ専門家は、より多くの求人機会、高い給与、そしてキャリアアップの可能性が高くなる可能性があります。
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