100%合格、売れ筋最上位CAMS試験材料は2025年最新のACAMS練習試験合格させます [Q333-Q353]

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100%合格、売れ筋最上位CAMS試験材料は2025年最新のACAMS練習試験合格させます

CAMS Certification問題集でCAMS試験完全版問題、試験学習ガイド

質問 # 333
Which is a key reason why a financial institution (FI) conducts an enterprise-wide AML risk assessment?

  • A. The need to understand its overall budget needs for each department and for internal audit.
  • B. The identification of specific risk categories (i.e., export, inactivity, layman, and false locations) unique to the bank.
  • C. The need to assess money laundering and terrorist financing risks and ensure there are adequate controls to mitigate those risks.
  • D. The board of directors and senior management are required to have an AML risk assessment for the bank.

正解:C


質問 # 334
Which key factor would result in the decision for a financial institution (FI) to exit a client relationship?

  • A. Closing the client accounts will help reduce the number of transaction monitoring alerts.
  • B. The client is a registered charity known to remit funds to high risk geographies where there is limited due diligence information available.
  • C. Client transactions generate ongoing transaction monitoring alerts that did not result in any SAR/STR filings.
  • D. After assessing all risk factors the level of residual client risk exceeds the FI's risk appetite.

正解:D

解説:
The key factor that would result in the decision for a financial institution (FI) to exit a client relationship is when the level of residual client risk exceeds the FI's risk appetite. Residual client risk is the remaining risk after applying the FI's risk mitigation measures, such as customer due diligence, transaction monitoring, and suspicious activity reporting. Risk appetite is the level and type of risk that the FI is willing and able to accept in pursuit of its business objectives. If the residual client risk is higher than the risk appetite, the FI may decide to terminate the relationship to avoid potential regulatory, reputational, or operational consequences.
The other options are not necessarily key factors for exiting a client relationship, because:
The client is a registered charity known to remit funds to high risk geographies where there is limited due diligence information available. This option may indicate a higher level of inherent client risk, but it does not necessarily mean that the FI should exit the relationship. The FI may be able to apply enhanced due diligence, ongoing monitoring, and risk-based controls to mitigate the risk and comply with the regulatory requirements. The FI may also consider the nature and purpose of the client's activities, the source and destination of the funds, and the potential impact on the client's beneficiaries.
Closing the client accounts will help reduce the number of transaction monitoring alerts. This option may suggest a possible benefit of exiting the relationship, but it is not a key factor for making the decision. The FI should not base its decision solely on the volume of transaction monitoring alerts, but rather on the quality and relevance of the alerts, the results of the investigation, and the risk assessment of the client. The FI should also ensure that its transaction monitoring system is properly calibrated and validated to avoid generating excessive or false alerts.
Client transactions generate ongoing transaction monitoring alerts that did not result in any SAR/STR filings. This option may indicate a need for reviewing and improving the transaction monitoring system or the investigation process, but it does not necessarily imply that the FI should exit the relationship. The FI should not assume that the absence of SAR/STR filings means that the client is low risk or that the alerts are irrelevant. The FI should conduct a thorough and timely investigation of the alerts and document the rationale for filing or not filing a SAR/STR. The FI should also consider the overall risk profile of the client and the nature and frequency of the transactions.
References:
ACAMS Study Guide for the CAMS Certification Examination - 6th Edition, Chapter 3: AML Programs, Section 3.2: AML Program Components, Subsection 3.2.2: Risk Assessment, pp. 77-79 FFIEC BSA/AML Examination Manual, Section: Assessing Compliance with BSA Regulatory Requirements, Subsection: Suspicious Activity Reporting, pp. 4-5 Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations, Question 2, pp. 2-3


質問 # 335
What is true regarding disclosure to a law enforcement agency by a financial institution of the supporting documentation for a suspicious transaction report?

  • A. Documentation must be provided as quickly as possible using email
  • B. Confirm that the request originated from a representative of the law enforcement agency
  • C. A copy of all the documentation released must also be provided to the account holder's attorney
  • D. The financial institution may notify the account holder of the request

正解:B

解説:
Before disclosing any supporting documentation for a suspicious transaction report (STR) to a law enforcement agency, the financial institution should confirm that the request is legitimate and authorized by verifying the identity and credentials of the requester1. This is to prevent unauthorized access or misuse of the confidential information by impostors or fraudsters. The other options are not true, as they may either compromise the security, integrity, or timeliness of the disclosure, or violate the confidentiality or privacy rights of the customer.
References:
ACAMS, CAMS Examination Study Guide, 6th Edition, Chapter 4, p. 117
FATF Guidance: The Role of Hawala and Other Similar Service Providers in Money Laundering and Terrorist Financing, October 20132, p. 20 Basel Committee on Banking Supervision, Sound management of risks related to money laundering and financing of terrorism, June 20173, p. 11 Reference: https://www.sec.gov/about/offices/ocie/aml2007/fin-2007-g003.pdf


質問 # 336
A bank sells reloadable open-loop prepaid cards to both customers and non-customers.
What is a red flag associated with these cards that may indicate money laundering?

  • A. A bank customer historically purchases several prepaid cards near year-end.
  • B. A bank customer routinely purchases five prepaid cards in small even-dollar amounts on a monthly basis.
  • C. A non-bank customer consistently uses the bank to obtain cash advances using a prepaid card.
  • D. A non-bank customer regularly loads large amounts of cash onto several prepaid cards.

正解:D


質問 # 337
Under requirements for correspondent accounts in the USA PATRIOT Act, the word "certification" refers to a written representation by a

  • A. respondent bank, certifying that they do not do business with shell banks.
  • B. correspondent bank, certifying that they do not open correspondent accounts for alternative remittance companies.
  • C. federal receiver" certifying that he is not the beneficial owner of the correspondent account.
  • D. respondent bank, certifying that they do not do business with politically exposed persons.

正解:A

解説:
it describes the word "certification" as a written representation by a respondent bank, certifying that they do not do business with shell banks. This is one of the requirements for correspondent accounts in the USA PATRIOT Act, which is a law enacted in 2001 to enhance the anti-money laundering and counter-terrorist financing (AML/CTF) measures in the United States. The USA PATRIOT Act requires that correspondent banks, which are banks that provide services to other banks, such as clearing, settlement, or cash management, to obtain a certification from their respondent banks, which are banks that receive services from correspondent banks, to ensure that they are not involved in money laundering or terrorist financing activities. One of the elements of the certification is that the respondent bank does not do business with shell banks, which are banks that have no physical presence or meaningful supervision in any jurisdiction, and are often used by money launderers and other criminals to hide their identity and funds.
The other options are not necessarily the word "certification" as a written representation by a respondent bank under the USA PATRIOT Act, although they may have some relevance or importance depending on the circumstances and the nature of the correspondent relationship. Option A describes a possible certification by a federal receiver, which is a person appointed by a court to take custody and control of the assets of a failed bank, but this is not related to the correspondent accounts requirements in the USA PATRIOT Act. Option B describes a possible certification by a respondent bank, certifying that they do not do business with politically exposed persons (PEPs), which are individuals who hold or have held prominent public positions or their close associates or family members, and who may pose a higher risk of money laundering or corruption, but this is not a mandatory element of the certification under the USA PATRIOT Act, although it may be a good practice or a risk-based measure. Option C describes a possible certification by a correspondent bank, certifying that they do not open correspondent accounts for alternative remittance companies, which are businesses that provide money transfer or payment services outside the formal banking system, and which may pose a higher risk of money laundering or terrorist financing, but this is not a requirement for the respondent bank under the USA PATRIOT Act, although it may be a regulatory obligation or a risk-based measure for the correspondent bank.
References:
* ACAMS CAMS Certification Video Training Course - 6th Edition1
* Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)2
* ACAMS CAMS Study Guide - 6th Edition, Chapter 7, pages 156-157
https://www.acams.org/wp-content/uploads/2019/09/ACAMS-CAMS-Study-Guide-6th-Edition-Chapter-7.pdf


質問 # 338
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 who are the ultimate source of funds for the account and whose source of wealth should be subject to due diligence
  • B. Those who have legal title to a controlling share interest in the customer
  • C. Those who generally have ultimate control through ownership or other means over the funds in the account
  • D. Those two are authorized signers on the account

正解:A、C

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 # 339
An employee hears a colleague on the telephone with a customer giving advice on how to ensure that a suspicious transaction report will not be filed as a result of a future transaction.
What action should the employee take?

  • A. Ignore the situation because the colleague is the relationship manager for that customer
  • B. Report the conversation to the local police
  • C. Tell the colleague that it is against policy to give such advice
  • D. Report the conversation to the compliance officer

正解:D

解説:
According to the Anti-Money Laundering Specialist (the 6th edition) resources, the employee should report the conversation to the compliance officer because the colleague is engaging in tipping off, which is a serious violation of anti-money laundering laws and regulations. Tipping off is the act of informing a person or entity that they are the subject of a suspicious transaction report or an investigation, or providing any information that may compromise or impede the investigation. Tipping off can result in criminal penalties, civil liabilities, and disciplinary actions for the individual and the institution. Therefore, the employee has a duty to report the colleague's misconduct to the compliance officer, who is responsible for ensuring compliance with the anti-money laundering policies and procedures, and taking appropriate corrective actions.
References:
* CAMS Certification Package - 6th Edition | ACAMS, Chapter 3: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), page 97
* CAMS Certifications: How to Get CAMS Certified | ACAMS, CAMS Examination Preparation, page 8
* ACAMS CAMS Certification Video Training Course - Exam-Labs, Module 3: Compliance Standards for Anti-Money Laundering and Combating the Financing of Terrorism, video 3.4: Tipping Off and Confidentiality
* Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition), Question 8, Answer B


質問 # 340
Which of the following should an anti-money laundering specialist consider the most serious deficiency when detected during a regulatory audit of the anti-money laundering program?

  • A. The company has not implemented an anti-money laundering training program.
  • B. The compliance officer fails to have on-going meetings with upper management to keep them apprised of current money laundering trends.
  • C. The company's anti-money laundering manual has not been updated to reflect a recent internal control enhancement.
  • D. The company has failed to download the most recent regulation from the Financial Intelligence Unit web site.

正解:A

解説:
According to the ACAMS CAMS Certification Study Guide, 6th Edition, one of the four pillars of an effective anti-money laundering compliance program is the training of appropriate employees on their responsibilities and the institution's policies and procedures. Training is essential to ensure that employees are aware of the risks of money laundering and terrorist financing, the applicable laws and regulations, the red flags and indicators of suspicious activity, and the reporting and record-keeping requirements. Without proper training, employees may not be able to perform their duties effectively and efficiently, and may expose the institution to legal, regulatory, reputational, and operational risks.
The other options are less serious deficiencies, but still need to be addressed and corrected. The compliance officer should have regular meetings with upper management to inform them of the current money laundering trends and the status of the compliance program, but this is not as critical as providing training to the employees. The company's anti-money laundering manual should be updated to reflect any changes in the internal controls, policies, or procedures, but this is not as urgent as ensuring that the employees are familiar with the existing ones. The company should download the most recent regulation from the Financial Intelligence Unit web site, but this is not as important as complying with the existing ones.
References:
ACAMS CAMS Certification Study Guide, 6th Edition, Chapter 2, Section 2.1.4, page 39.
ACAMS CAMS Certification Video Training Course, Module 2, Lesson 2.1.4.


質問 # 341
Which of the following best describes the Basel Committee on Banking Supervision's principles on customer due diligence?

  • A. Generally accepted terms issued by big international banks.
  • B. A recommendation to members and banks.
  • C. Multilateral agreement between all members.
  • D. A country's initiative to increase the reputation of its financial market.

正解:A


質問 # 342
Which assessments are involved in the processes of mutual evaluation and follow-up by the FATF?

  • A. Country audit assessments and transaction monitoring assessments
  • B. Sanction risk assessments and the country's National Risk Assessment
  • C. Risk assessments and technical standards assessments
  • D. Technical compliance assessments and effectiveness assessment

正解:D

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


質問 # 343
Which are key objectives of the Egmont Group? (Select Two.)

  • A. Serving as a prudential regulator for global financial institutions
  • B. Setting international standards that aim to prevent
  • C. AML Providing a platform for the secure exchange of financial intelligence
  • D. Serving as an authoritative body in the field of anti-corruption
  • E. Serving as a united body of financial intelligence units across the world

正解:B、E

解説:
Explanation
The Egmont Group is an international body of Financial Intelligence Units (FIUs) from around the world. Its primary purpose is to serve as a forum for FIUs to exchange information, and it also sets international standards for AML/CFT measures. Additionally, the Egmont Group does not serve as a prudential regulator for global financial institutions or as an authoritative body in the field of anti-corruption.


質問 # 344
What do the Financial Action Task Force (FATF) mutual evaluations of each member assess?

  • A. The levels of implementation of the FATF Recommendations
  • B. The member's ability to send a representative to the plenary sessions
  • C. If the member has a large enough economy to maintain its membership
  • D. If the member has made any suggestions for updates to the FATF Recommendations

正解:A

解説:
Reference:
https://www.fatf-gafi.org/publications/mutualevaluations/documents/more-about-mutual-evaluations.html


質問 # 345
An anti-money laundering specialist has been asked to establish a compliance program to detect and prevent money laundering and terrorist financing. Which of the following should the anti-money laundering specialist consider in developing the program?
1. Funds for money laundering and terrorist financing are derived from illegal sources.
2. Related practices are used to conceal the nature of the funds.
3. The source and disposition of funds are similar.
4. Similar techniques are used to move funds.

  • A. 1 and 2 only
  • B. 3 and 4 only
  • C. 2 and 4 only
  • D. 1 and 3 only

正解:D


質問 # 346
Normal account-opening procedures reveal a customer who contacted a financial institution to open a bank account is the brother of a prominent member of a foreign judiciary. Which of the following actions should the anti-money laundering specialist recommend immediately?

  • A. Perform enhanced due diligence.
  • B. Contact the institution's legal advisor.
  • C. File a suspicious transaction report with the competent authority.
  • D. Monitor the customer's account.

正解:A

解説:
A customer who is the brother of a prominent member of a foreign judiciary is considered a politically exposed person (PEP) or a family member of a PEP. PEPs are individuals who hold or have held positions of public trust or influence in a foreign country, such as heads of state, senior politicians, high-ranking military officers, judges, or executives of state-owned enterprises. PEPs pose a higher risk of money laundering, corruption, or bribery due to their access to public funds, influence over policy decisions, or connections to other powerful individuals. Therefore, financial institutions are required to perform enhanced due diligence (EDD) on PEPs and their family members, as well as monitor their transactions and activities more closely.
EDD is a set of additional measures that go beyond the standard customer due diligence (CDD) to obtain more information about the customer, such as their source of wealth, source of funds, expected account activity, business relationships, and reputation. EDD also involves conducting ongoing reviews and updating the customer risk profile regularly. EDD helps the financial institution to mitigate the risks associated with PEPs and detect any signs of money laundering or other illicit activities.
References:
* ACAMS Study Guide1, Chapter 2: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), pages 51-52
* FATF Guidance on Politically Exposed Persons2, pages 9-10, 13-14, 17-18
* Wolfsberg Group Guidance on Politically Exposed Persons3, pages 2-3, 6-7


質問 # 347
A compliance officer is looking to update an institution's private bank procedures. What should be included as recommended by the Wolfsberg AML Principles on Private Banking?

  • A. The institution's senior management has primary responsibility for the relationship
  • B. Approval of Politically Exposed Persons (PEPs) by at least one person other than the relationship manager
  • C. Review of client files annually if there are unusual transactions
  • D. Dedicated automated AML monitoring of client activity

正解:B


質問 # 348
Which method to launder money through deposit-taking institutions is closely associated with international trade?

  • A. Investing in legitimate businesses with illicit funds
  • B. Forming a shell company
  • C. Structuring cash deposits/withdrawals
  • D. Using Black Market Peso Exchange

正解:D

解説:
Explanation/Reference: http://fraudaid.com/Dictionary-of-Financial-Scam-Terms/black_market_peso_exchange.htm


質問 # 349
A new compliance officer is reviewing the bank's anti-money laundering program and notices that the risk assessment was completed six months ago. Since that time, the bank acquired another financial institution, renamed the internal records group, and streamlined cash handling procedures.
Which factor causes the compliance officer to update the bank's risk assessment?

  • A. The bank acquired another institution
  • B. The risk assessment was completed six months ago
  • C. The internal records group has been re-named
  • D. The cash handling procedures were streamlined

正解:C


質問 # 350
An anti-money laundering specialist working at a bank just received a legal request from a law enforcement agency mandating the release of all financial transaction records relating to an account at the bank. The specialist immediately recognizes the account as one owned by the bank Chief Executive Officier's brother. During research to gather the requested documents, the specialist finds several internal memos he had sent to the bank president with concerns regarding possible suspicious activity relating to this account. The specialist recalls the bank president verbally responded to each memo with an explanation of the activity and indicated there was no cause for concern. What should the specialist do with respect to these internal memos?

  • A. Ask the bank president to document his instructions to the specialist
  • B. Call the law enforcement agent and suggest he modify the legal request to include these memos
  • C. Advise the bank's senior legal advisor of the situation
  • D. Place these memos in his personal files in case they are subsequently requested

正解:C


質問 # 351
You need to design an application that will analyze real-time data from financial feeds.
The data will be ingested into Azure IoT Hub. The data must be processed as quickly as possible in the order in which it is ingested.
Which service should you include in the design?

  • A. Azure Data Factory
  • B. Azure Notification Hubs
  • C. Azure Event Hubs
  • D. Azure Stream Analytics
  • E. Apache Kafka
  • F. Azure Queue storage

正解:D

解説:
Stream processing can be handled by Azure Stream Analytics. Azure Stream Analytics can run perpetual queries against an unbounded stream of data. These queries consume streams of data from storage or message brokers, filter and aggregate the data based on temporal windows, and write the results to sinks such as storage, databases, or directly to reports in Power BI. Stream Analytics uses a SQL-based query language that supports temporal and geospatial constructs, and can be extended using JavaScript.
Incorrect Answers:
E: Apache Kafka is used for ingestion, not for stream processing.
F: Azure Event Hubs is used for ingestion, not for stream processing.
Reference:
https://docs.microsoft.com/en-us/azure/architecture/data-guide/big-data/real-time-processing


質問 # 352
Which insurance product is particularly vulnerable to money laundering?

  • A. Collateral
  • B. Annuity
  • C. Regulated pension
  • D. Casualty

正解:B


質問 # 353
......

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