[2023年11月28日] 合格させるACAMS CAMS-FCI試験情報と無料練習テスト [Q13-Q37]

[2023年11月28日] 合格させるACAMS CAMS-FCI試験情報と無料練習テスト

CAMS-FCI試験問題集PDF更新された問題集にはFast2test試験合格保証付き

質問 # 13
An investigator receives an alert documenting a series of transactions. A limited liability corporation (LLC) wired 59.000,000 USD to an overseas account associated with a state-run oil company. A second account associated with the state-run oil company wired 600,000,000 USD to the LLC. The LLC then wired money to other accounts, a money brokerage firm, and real estate purchases.
The investigator initiated an enhanced KYC investigation on the LLC. The financial institution opened the LLC account a couple of weeks prior to the series of transactions. The names associated with the LLC had changed multiple times since the account opened. A search of those names revealed relations with multiple LLCs. Public records about the LLCs did not show any identifiable business activities.
Open-source research identified mixed reports about the brokerage firm.
The firm indicated it purchased mutual funds for its clients and dispensed returns to clients.
Media reports claimed the firm laundered money by holding money for a fee before returning it to investors.
Which information should the investigator review first when examining the wire transaction documentation?

• A. Whether the wire transfers were initiated domestically
• B. The sanctions screening tool to see if the transaction was stopped
• C. How the wire transfers were initiated (e.g., phone, online, branch visit)
• D. The Travel Rule requirements for recordkeeping

正解：C

解説：
Explanation
The investigator should review how the wire transfers were initiated first, because this could indicate the level of involvement and knowledge of the LLC account holders. If the wire transfers were initiated online or by phone, it could suggest that the account holders were trying to avoid face-to-face contact with the bank staff and reduce the chances of being questioned or identified. If the wire transfers were initiated in person at a branch, it could indicate that the account holders were confident or careless about their activities, or that they had some relationship with the bank staff. The method of initiation could also affect the quality and quantity of information collected by the bank about the wire transfers, such as the purpose, source, and destination of the funds. References: ACAMS Advanced Financial Crimes Investigations Certification Study Guide, page 65.

質問 # 14
An AML investigator at a bank identifies an unusually high number of deposits from a few customers resulting from the encashment of multiple gambling tickets from a legitimate gambling company. It is noted that the transactions are inconsistent with the customers' profiles and that reverse (corrective) transactions did not occur. Which suspicious activity is most likely?

• A. The customers deposited fake winning tickets.
• B. The customers are attempting to evade income tax.
• C. The winning tickets are traded to criminals who. in turn, use the customers' accounts.
• D. The gambling company created fictitious transactions in an attempt to misrepresent the size of its business activity.

正解：C

解説：
Explanation
The correct answer is A because this scenario describes a possible case of ticket laundering, which is a form of money laundering where criminals use gambling tickets to disguise the source of their illicit funds. The customers who deposit the tickets are either complicit or unaware of the scheme, and they receive a commission or a fee for their service. The other options are not likely because they do not explain why the customers would deposit multiple tickets from the same gambling company and withdraw cash the next day.
References: : Ticket Laundering: A Money Laundering Method

質問 # 15
How does the Asian/Pacific Financial Action Task Force <FATF>-Style Regional Body help its members implement recommendations from the FATF? (Select Two.)

• A. Endorses regulations that define money laundering based on the model laws issued by the respective member states
• B. Facilitates the adoption and implementation of internationally accepted AMI measures by member jurisdictions
• C. Encourages cooperative AML efforts in the region
• D. Requires members to maintain lists of regional money laundering and terrorists financing issues relevant to their region
• E. Promotes laws that allow judicial challenges to seizure orders by an administrative body

正解：B、C

解説：
Explanation
The Asian/Pacific Financial Action Task Force-Style Regional Body (APG) helps its members implement recommendations from the FATF by facilitating the adoption and implementation of internationally accepted AML measures by member jurisdictions (CAMS Manual, 6th Edition, Page 22). The APG also encourages cooperative AML efforts in the region, which can include information-sharing and mutual evaluations to assess member compliance with FATF recommendations (CAMS Manual, 6th Edition, Page 25). Therefore, options C and D are the correct answers.

質問 # 16
Which pattern of activity most strongly indicates an individual is a foreign terrorist fighter?

• A. A series of small deposits followed by a large international wire to a well-known international charity
• B. A series of small cash deposits made in rapid succession totaling just over 10,000 USD followed by a purchase at a jewelry store
• C. A large cash advance on a credit card and purchases at travel and sporting goods websites
• D. A large purchase at a gas station immediately followed by several smaller purchases at an electronics store

正解：C

解説：
Explanation
The pattern of activity that most strongly indicates an individual is a foreign terrorist fighter is a large cash advance on a credit card and purchases at travel and sporting goods websites. This is because this pattern may suggest that the individual is preparing to travel to a conflict zone and purchase equipment or supplies for terrorist activities. According to the United Nations Office on Drugs and Crime, some of the indicators of foreign terrorist fighters include1:
Sudden or increased financial activity, such as cash withdrawals, transfers, or deposits, especially in large amounts or involving foreign currency or locations.
Purchases of travel-related items, such as airline tickets, passports, visas, luggage, or clothing, especially to or from high-risk destinations or transit hubs.
Purchases of items that could be used for terrorist purposes, such as weapons, explosives, chemicals, communication devices, or survival gear.
Changes in behavior, such as expressing radical views, cutting ties with family or friends, joining extremist groups, or displaying signs of emotional distress.
References:
Foreign Terrorist Fighters - United Nations Office on Drugs and Crime

質問 # 17
Which main vulnerability has led to an increase in the ransomware attacks perpetuated on small businesses?

• A. Inability to recover the encrypted information
• B. Tendency not to contact law enforcement
• C. Ability to pay larger ransoms
• D. Weaker cybersecurity controls

正解：D

解説：
Explanation
Weaker cybersecurity controls are a main vulnerability that has led to an increase in ransomware attacks on small businesses, as they make them easier targets for cybercriminals who can exploit their systems and demand payment for restoring access to their data. The other options are not relevant to the vulnerability, as they relate to the consequences or responses of the victims.

質問 # 18
When crafting internal procedures on writing and submitting SARs/STRs, one should:

• A. adhere to home junsdiction guidelines across the whole group when local requirements of the country of operation and home jurisdiction conflict.
• B. include attachments with the SARs/STRs as all information needs to be at the disposal of the financial intelligence unit (FIU)
• C. use internal keywords and standard industry terms to better provide context within which the suspicious activity was identified.
• D. consider the guidelines issued by the national financial intelligence unit {FIU) and local regulator and incorporate any country-specific requirements.

正解：D

解説：
Explanation
When writing and submitting SARs/STRs, one should consider the guidelines issued by the national financial intelligence unit (FIU) and local regulator and incorporate any country-specific requirements. This ensures that the reports are compliant with the relevant laws and regulations and provide useful information to the authorities. The other options are either incorrect or not best practices.
References: Advanced CAMS-FCI Study Guide, page 48-49.

質問 # 19
When writing or reviewing a SAR/STR, it is important to:

• A. avoid mentioning suspect names in case it is seen by someone involved in criminal activity, effectively tipping them off.
• B. keep the introduction brief but ensure all relevant transactions, account numbers, and suspect names are listed in the conclusion summary.
• C. ensure that the narrative is detailed with all available information so that law enforcement can decide what is relevant.
• D. ensure the narrative is kept to the point; easy to read; and addresses the who, what, when, where, why, and how.

正解：D

解説：
Explanation
The correct answer is A because a SAR/STR narrative should be concise, clear, and complete, addressing the who, what, when, where, why, and how of the suspicious activity. Option B is incorrect because providing too much information can make the narrative confusing and irrelevant. Option C is incorrect because the introduction should provide a summary of the suspicious activity, not the conclusion. Option D is incorrect because suspect names should be mentioned in the narrative to identify the parties involved in the suspicious activity.
References: Advanced CAMS-FCI Certification Handbook, page 17; Leading Complex Investigations Certificate, Module 3.

質問 # 20
An investigator is reviewing an alert for unusual activity. System scanning detected a text string within a company customer's account transactions that indicates the account may have been used for a drug or drug paraphernalia purchase. Based on the KYC profile, the investigator determines the customer's company name and business type are marketed as a gardening supplies company. The investigator reviews the account activity and notes an online purchase transaction that leads the investigator to a website that sells various strains of marijuana. Additional account review detects cash deposits into the account at the branch teller lines, so the investigator reaches out to the teller staff regarding the transactions. The teller staff member reports that the business customers have frequently deposited cash in lower amounts. The teller, without prompting, adds that one of the transactors would occasionally smell of a distinct scent of marijuana smoke.
Which information should be included in the SAR/STR?

• A. A transaction that is commensurate with the customer's background
• B. The fact that one of the transactors occasionally smelled of marijuana smoke
• C. Details of the transactor's social media accounts
• D. The customer information, including KYC background

正解：B

解説：
Explanation
The SAR/STR should include any information that is relevant to the suspicious activity, such as the customer information, the transaction details, and any other indicators of potential money laundering or criminal activity. The fact that one of the transactors occasionally smelled of marijuana smoke is an indicator that the customer may be involved in the illicit drug trade, which is a predicate offense for money laundering.
Therefore, this information should be included in the SAR/STR. References: Advanced CAMS-FCI Study Guide, page 25.

質問 # 21
A client that runs a non-profit organization that aids refugees in leaving their home countries received a remittance from a money services business that was ten times the average. The client was recently detained for providing falsified passports to illegal immigrants. Which predicate offenses could be considered in the SAR/STR? (Select Two.)

• A. Terrorist financing
• B. Tax evasion
• C. Human smuggling/trafficking
• D. Narcotics trafficking
• E. Antiques smuggling

正解：A、C

解説：
Explanation
The correct answer is A and B because human smuggling/trafficking and terrorist financing are both predicate offenses for money laundering that could be related to the client's activities. Option C is incorrect because there is no indication of narcotics trafficking in the scenario. Option D is incorrect because there is no indication of antiques smuggling in the scenario. Option E is incorrect because there is no indication of tax evasion in the scenario.
References: Advanced CAMS-FCI Certification Handbook, page 10; Financial Crime Typologies - Intermediate Certificate, Module 2.

質問 # 22
CLIENT INFORMATION FORM Client Name: ABC Tech Corp Client I.D. Number: 08125 Name: ABC Tech Corp Registered Address: Mumbai, India Work Address: Mumbai. India Cell Phone: ***"- Alt Phone:
Email: ********
Client Profile Information:
Sector: Financial
Engaged in business from (date): 02 Jan 2020
Sub-sector: Software-Cryptocurrency Exchange
Expected Annual Transaction Amount: 125.000 USD
Payment Nature: Transfer received from client's fund
Received from: Clients
Received for: Sale of digital assets
The client identified themselves as "Cryptocurrency Exchange" Client has submitted the limited liability partnership deed. However, the bank's auditing team is unable to identify the client's exact business profile as the cryptocurrency exchange specified by the client as their major business awaits clearance from the country's regulator. The client has submitted documents/communications exchanged with the regulator and has cited the lack of governing laws in the country of their operation as the reason for the delay.
Investigators determine the ultimate beneficial owner of ABC Tech Corp is a high-net-worth client. The client owns a real estate agency left to her when her spouse died. The spouse provided seed capital for ABC Tech Corp through a direct 1,000.000 Great British Pound (GBP) deposit.
What additional information would trigger filing a SAR/STR?

• A. The client's current net asset value is 8 million GBP, of which 7.5 million GBP was derived from the inheritance.
• B. The client's spouse's source of wealth was a salary of 250,000 GBP per annum for the past 4 years and rental of properties of 150,000 GBP per annum for the past 6 years.
• C. An open-source search revealed that the client's spouse was a PEP.
• D. The funds for the seed capital were in the form of 50 cashier's checks of 10,000 GBP each and 50 money orders of 10,000 GBP.

正解：D

解説：
Explanation
The additional information that would trigger filing a SAR/STR is the fact that the funds for the seed capital were in the form of 50 cashier's checks of 10,000 GBP each and 50 money orders of 10,000 GBP. This is because this indicates a possible attempt to avoid the reporting threshold of 10,000 GBP for cash transactions, which is a common money laundering technique known as structuring or smurfing12. The other options are not necessarily suspicious, as they do not involve cash transactions or indicate any illicit source of funds. The fact that the client's spouse was a PEP does not automatically make the transaction suspicious unless there are other red flags or risk factors associated with the PEP34 References: 1: Money Laundering Techniques 2: Structuring 3: Politically exposed person 4: PEP Definition
& Meaning - Merriam-Webster

質問 # 23
Online payments from a customer's account to three foreign entities trigger an investigation. The investigator knows the funds originated from family real estate after an investment company approached the customer online. Funds were remitted for pre-lPO shares. Which should now occur in the investigation?

• A. Seek evidence for the customer's source of wealth.
• B. Inspect electronic banking login records.
• C. Review the structure of the transactions to the three entities.
• D. Have the relationship manager contact the customer to understand the nature of the transaction.

正解：C

解説：
Explanation
The correct answer is C because reviewing the structure of the transactions to the three entities can help the investigator to identify any red flags or indicators of fraud, such as unusual amounts, frequency, destinations, or beneficiaries. The other options are not as relevant or effective in this scenario. Option A is not necessary because the investigator already knows the source of funds for the customer. Option B is not advisable because contacting the customer directly may alert them to the investigation and compromise its integrity. Option D is not helpful because inspecting electronic banking login records does not provide any information about the nature or purpose of the transactions.
References:
Advanced CAMS-FCI Study Guide, page 281
Financial Crime Typologies - Intermediate Certificate Course, Module 32

質問 # 24
The intended benefits of section 314(b) of the USA PATRIOT Act include: (Select Three.)

• A. obtaining additional information on customers or transactions regarding potential money laundering or terrorist financing (TF).
• B. detecting money laundering and TF approaches and schemes across multiple financial institutions (FIs).
• C. participating FIs sharing information about suspicious activity by customers that may have otherwise gone unnoticed.
• D. providing mandatory results to law enforcement agencies so that they can more easily obtain useful information.
• E. expediting the filing of SARs/STRs due to the information sharing facilitated by 314(b).
• F. sharing the existence and content of SARs/STRs with other participating FIs.

正解：A、B、C

解説：
Explanation
Section 314(b) of the USA PATRIOT Act allows financial institutions to share information with each other, under a safe harbor that offers protection from liability, in order to better identify and report potential money laundering or terrorist financing activities. The intended benefits of this information sharing include:
Participating financial institutions sharing information about suspicious activity by customers that may have otherwise gone unnoticed. For example, if a customer is conducting transactions with multiple financial institutions that individually do not appear suspicious, but collectively indicate a pattern of money laundering or terrorist financing, the financial institutions can share this information and report it to the authorities.
Detecting money laundering and terrorist financing approaches and schemes across multiple financial institutions. For example, if a financial institution identifies a new typology or modus operandi of money laundering or terrorist financing, it can share this information with other financial institutions to help them prevent or detect similar activities by their customers.
Obtaining additional information on customers or transactions regarding potential money laundering or terrorist financing. For example, if a financial institution has incomplete or insufficient information on a customer or a transaction that raises suspicion, it can request more information from another financial institution that may have dealt with the same customer or transaction.
References:
Section 314(b) | FinCEN.gov
Section 314(b) Fact Sheet - FinCEN.gov

質問 # 25
A SAR/STR on cash activity is filed for a company registered in the Marshall Islands operating a Mediterranean beach bar and hotel. The company has three nominee directors, one nominee shareholder, and another individual declared as both the beneficial owner and authorized signatory. Which information is key for law enforcement's physical surveillance of cash activity? (Select Two.)

• A. The identification details of the beneficial owner and authorized signatory
• B. The identification details the nominee directors
• C. The company's registered address
• D. The company's operating address
• E. The identification details o' the nominee shareholder

正解：A、D

解説：
Explanation
The identification details of the beneficial owner and authorized signatory are key for law enforcement's physical surveillance of cash activity, as they would help identify the person who controls and operates the company and who is responsible for its financial transactions. The company's operating address is also key, as it would help locate the premises where the cash activity takes place and observe any suspicious movements or behaviors. The identification details of the nominee shareholder and directors are not relevant, as they are not involved in the management or operation of the company. The company's registered address is also not relevant, as it is likely to be a shell or mailbox address that does not reflect the actual location of the business.
References: Advanced CAMS-FCI Study Guide, page 44-45; [FATF Guidance on Transparency and Beneficial Ownership], page 12-13.

質問 # 26
A KYC specialist from the first line of defense at a bank initiates an internal escalation based on a letter of credit received by the bank.
MEMO
To: Jane Doe. Compliance Manager, Bank B From: Jack Brown, KYC Specialist, Bank B RE: Concerning letter of credit A letter of credit (LC) was received from a correspondent bank. Bank A. in Country A. in Asia with strict capital controls, providing guarantee of payment to Bank B's client for the export of 10 luxury cars located in Country B. located in Europe. Bank A's customer is a general in the army where Bank A is headquartered.
The information contained in the LC is as follows:
* Advising amount per unit 30.000.00 EU *10 units of BMW
* Model IX3
* Year of registration: 2020
Upon checks on Bank B's client, the exporter mentioned that the transactions were particularly important, and a fast process would be much appreciated in order to avoid reputational damage to the firm and the banks involved in the trade finance process. The exporter has a longstanding relationship with Bank B and was clearly a good income generator. The exporter indicated that, as a general, the importer was trustworthy.
The relationship manager <RM) was contacted to conduct a full review of the exporter and to conduct a site visit.
Feedback from the RM:
The RM contacted the exporter for a client courtesy visit, but it was rearranged four times as the exporter kept cancelling the appointments. When the exporter was finally pinned down for an interview, employees were reluctant to provide clear answers about the basis of the transaction. The employees were evasive when asked about the wider business and trade activity in the country.
Findings from the investigation from various internal and external sources of information:
* There were no negative news or sanctions hits on the exporter company, directors, and shareholders.
* The registered address of the exporting business was a residential address.
* The price of the cats was checked and confirmed to be significantly below the market price of approximately
70,000 EU, based on manufacturer's new price guide.
* The key controllers behind the exporting company, that is the directors and During the investigation, the investigator determines that a nephew of the general.....

• A. is a trustworthy source.
• B. should be flagged as a senior PEP.
• C. should be treated well to avoid reputational damage to the bank
• D. is a high-net-worth individual

正解：B

解説：
Explanation
The investigator should determine that a nephew of the general (Bank A's customer) should be flagged as a senior PEP . This is because the nephew is related to a senior military official who is a customer of Bank A, which is a high-risk jurisdiction with strict capital controls. According to the ACAMS Advanced Financial Crimes Investigations Certification Study Guide1, "the FI should identify and flag any customers who are PEPs or have close associations with PEPs, such as family members or business partners" (p. 24). The FI should also conduct enhanced due diligence on these customers and monitor their transactions for any suspicious or unusual activity.
The other options are not correct. The investigator should not determine that a nephew of the general should be treated well to avoid reputational damage to the bank (A), as this could compromise the integrity and objectivity of the investigation, as well as expose the bank to legal or regulatory risks. The investigator should not determine that a nephew of the general is a high-net-worth individual (B), as this is not relevant or material to the investigation, as the nephew's wealth does not affect his potential PEP status or risk level. The investigator should not determine that a nephew of the general is a trustworthy source (D), as this could be biased or inaccurate, as the nephew's trustworthiness does not depend on his relation to the general or his involvement in the transaction.
References: 1: ACAMS Advanced Financial Crimes Investigations Certification Study Guide, available at ACAMS

質問 # 27
Law enforcement agents arrive at a broker-dealer's premises with a search warrant. In addition to cooperation with the warrant, which instructions should the person in charge of the broker-dealer provide to their employees?

• A. Provide agents with unlimited access to customers' personal data.
• B. Sign consent forms permitting the agents to search employees' offices.
• C. Volunteer information not requested by the agents that the employees think may be useful.
• D. Take notes on the questions and comments made by the agents.

正解：D

解説：
Explanation
The instruction that the person in charge of the broker-dealer should provide to their employees is to take notes on the questions and comments made by the agents (A). This is because taking notes can help the employees to recall and document what happened during the search warrant execution, which can be useful for legal or regulatory purposes. According to ACAMS3, "the FI should instruct its staff to cooperate with LE agents during a search warrant execution, but also to take notes of what is being searched, seized, or asked by the agents" (p. 35). The FI should also "keep copies of any documents or records that are taken by LE agents" (p.
35).
The other instructions are not correct. The person in charge of the broker-dealer should not instruct their employees to sign consent forms permitting the agents to search employees' offices (B), as this is unnecessary and potentially risky, as the agents already have a valid search warrant that authorizes them to search the premises. The person in charge of the broker-dealer should not instruct their employees to provide agents with unlimited access to customers' personal data , as this could violate privacy or data protection laws, as well as compromise customer trust and confidentiality. The person in charge of the broker-dealer should not instruct their employees to volunteer information not requested by the agents that they think may be useful (D), as this could interfere with the LE investigation or expose them to legal or regulatory risks.
References:
Introduction to Transnational Organized Crime
ACAMS Law Enforcement and Financial Crimes Investigations eLearning Course Module Law Enforcement Requests and Actions

質問 # 28
An unusual spike in activity has occurred for a customer who is a supplier of aviation parts to a military force.
The customer's current line of business is consistent with the banks records, and no adverse media hits have occurred. Which is the best reason for an investigator to continue an investigation?

• A. The current line of business is consistent with the bank's records.
• B. The end-user is a military force.
• C. The customer is a supplier of aviation parts.
• D. There are no adverse media hits.

正解：B

解説：
Explanation
The best reason for an investigator to continue an investigation is that the end-user is a military force. This is because supplying aviation parts to a military force may involve sanctions risk, export control risk, or human rights risk, depending on the nature and destination of the military force. The investigator should conduct further due diligence to determine if the customer is complying with the relevant laws and regulations, and if the bank is exposed to any reputational or legal risk by providing services to the customer.
References:
Former Airline Employee and Aircraft Part Sellers Charged in Kickback ...
Former Airline Employee and Aircraft Part Sellers Charged in Kickback ...
Former airline employee and aircraft part sellers charged in kickback ...

質問 # 29
A KYC specialist from the first line of defense at a bank initiates an internal escalation based on a letter of credit received by the bank.
MEMO
To: Jane Doe. Compliance Manager, Bank B From: Jack Brown, KYC Specialist, Bank B RE: Concerning letter of credit A letter of credit (LC) was received from a correspondent bank.
Bank A. in Country A. in Asia with strict capital controls, providing guarantee of payment to Bank B's client for the export of 10 luxury cars located in Country B. located in Europe. Bank A's customer is a general in the army where Bank A is headquartered.
The information contained in the LC is as follows:
* Advising amount per unit 30.000.00 EU *10 units of BMW
* Model IX3
* Year of registration: 2020
Upon checks on Bank B's client, the exporter mentioned that the transactions were particularly important, and a fast process would be much appreciated in order to avoid reputational damage to the firm and the banks involved in the trade finance process. The exporter has a longstanding relationship with Bank B and was clearly a good income generator. The exporter indicated that, as a general, the importer was trustworthy.
The relationship manager <RM) was contacted to conduct a full review of the exporter and to conduct a site visit.
Feedback from the RM:
The RM contacted the exporter for a client courtesy visit, but it was rearranged four times as the exporter kept cancelling the appointments. When the exporter was finally pinned down for an interview, employees were reluctant to provide clear answers about the basis of the transaction. The employees were evasive when asked about the wider business and trade activity in the country.
Findings from the investigation from various internal and external sources of information:
* There were no negative news or sanctions hits on the exporter company, directors, and shareholders.
* The registered address of the exporting business was a residential address.
* The price of the cats was checked and confirmed to be significantly below the market price of approximately 70,000 EU, based on manufacturer's new price guide.
* The key controllers behind the exporting company, that is the directors and During the investigation, the investigator determines that a nephew of the general (Bank A's customer) is a customer at Bank B.
Which step should the investigator take next?

• A. Seek senior management approval to continue the relationship with the nephew.
• B. Determine whether there is a business relationship between the nephew and the general.
• C. File a SAR/STR in relation to corruption involving the nephew and the general.
• D. Flag the nephew as a PEP by association.

正解：D

解説：
Explanation
The step that the investigator should take next is to flag the nephew as a PEP by association (D). This is because the nephew is related to a general who is a senior military official and a customer of Bank A, which is a high-risk jurisdiction with strict capital controls. According to the ACAMS Advanced Financial Crimes Investigations Certification Study Guide1, "the FI should identify and flag any customers who are PEPs or have close associations with PEPs, such as family members or business partners" (p. 24). The FI should also conduct enhanced due diligence on these customers and monitor their transactions for any suspicious or unusual activity.
The other options are not correct. The investigator should not file a SAR/STR in relation to corruption involving the nephew and the general (A), as this could be premature or unnecessary, as there is no evidence of corruption or criminal activity between them. The investigator should not determine whether there is a business relationship between the nephew and the general (B), as this is not relevant or material to the investigation, as the nephew and the general are customers of different banks and are not involved in the same transaction. The investigator should not seek senior management approval to continue the relationship with the nephew , as this could be premature or disproportionate, as there is no indication that the nephew poses a high risk or requires termination.
References: 1: ACAMS Advanced Financial Crimes Investigations Certification Study Guide, available at ACAMS

質問 # 30
As part of an internal fraud investigation, an AML officer has decided to interview an employee. Which statement is most consistent with best practices?

• A. The employee should be supplied with all information about any ongoing fraud investigations.
• B. The employee should be notified that failing to cooperate can lead to loss of employment.
• C. Information on the employee can be gathered from coworkers and supervisors before the employee is interviewed.
• D. Prior to the interview, the investigator should inform the employee about the allegations.

正解：C

解説：
Explanation
As part of an internal fraud investigation, an AML officer should gather information on the employee from coworkers and supervisors before the interview, as this can help to establish a baseline of the employee's behavior, role, and responsibilities, and identify any red flags or anomalies. The other options are not consistent with best practices because they can compromise the integrity of the investigation, violate the employee's rights, or discourage cooperation.
References: Advanced CAMS-FCI Certification Handbook, page 28.

質問 # 31
Law enforcement (LE) suspects human trafficking to occur during a major spotting event. LE officers asked several financial institutions (FIs) to monitor financial transactions occurring before, during, and after the event.
An investigator identified a pattern linked to a business. The business* account received multiple even dollar deposits between midnight and 4:00 AM. They occurred each day for several days prior to the date of the sporting event. Also, large cash deposits, typically between 2,000 USD and 3.000 USD. made by a person to the business' account occurred in many branches in the days alter the sports event.
There was little information about the company. The company did not have any history of employee payroll expenses or paying taxes. Expenses from the business account included air travel and hotel expenses. Searches about the person making cash deposits showed little. An online social media platform webpage with the individual's name showed ads for dates" and "companionship." Which fact should not be included in (he SAR/STR narrative?

• A. The request by law enforcement
• B. The time of the cash deposits
• C. The sporting event
• D. The air travel and hotel expenses

正解：B

解説：
Explanation
The fact that should not be included in the SAR/STR narrative is the request by law enforcement (D). This is because the request by law enforcement is confidential and should not be disclosed to the customer or anyone else who is not authorized to know it. According to the ACAMS Advanced Financial Crimes Investigations Certification Study Guide1, "the FI should not include any reference to the LE request in the SAR/STR narrative, as this could compromise the LE investigation or alert the customer of the suspicion" (p. 35). The FI should also not inform the customer of the LE request or delay filing the SAR/STR because of it.
The other facts should be included in the SAR/STR narrative, as they are relevant and indicative of human trafficking money laundering. The air travel and hotel expenses (A) show that the customer is involved in moving people across different locations, which could be a sign of human smuggling or trafficking. The time of the cash deposits (B) shows that the customer is receiving cash payments during unusual hours, which could be a sign of illicit activities or services. The sporting event shows that the customer is exploiting a high-demand situation for their business, which could be a sign of opportunistic or organized crime.

質問 # 32
SAR/STR NARRATIVE
A SAR/STR has been submitted on five transactions conducted on the correspondent banking relationship with ABC Bank.
Client Information:
Remitter information: DEF Oil Resource Ltd. is the oldest member of the DEF Group. It was founded in 1977 as a general trading business with a primary focus on exports from Africa and North America. The group has business activities that span the entire energy value chain. Their core field of endeavor is centered within the oil and gas industry and its associated sub-sectors.
Beneficiary Information:
As per the response received from ABC Bank, it was determined that the beneficiaries are related to DEF Oil Resource Ltd. These were created by DEF Oil Resource Ltd. to purchase property in a foreign country on behalf of their senior management as part of a bonus scheme. The purpose behind this payment was for the purchase of property in another country.
Payment Reference:
ABCXXXXX31PZFG2H
ABCXXXXXX51PQGEH
ABCXXXXXX214QWVG
ABCXXXXXX41PSXA2
ABCXXXXXX815QWS3
Concerns:
* We are unsure about the country of incorporation of the beneficiaries.
* We are concerned about the transactional activity since the payment made towards entities (conducted on behalf of individuals) appears to be possible tax evasion.
* There appears to be an attempt to conceal the identity of individuals (senior management), which again raises concerns about the source of funds.
* Referring to the response received from ABC Bank, we are unclear about the ultimate beneficiary of funds.
* The remitter is involved in a high-risk business, (i.e., oil and crude products trading), and the beneficiary is involved in real estate business which again poses a higher risk.
When drafting the SAR/STR narrative, the investigator notes several payment references. What additional information should the investigator include in the narrative?

• A. All relevant tables, spreadsheets, and other supporting documentation
• B. Personal tax records pertinent to the owners to indicate tax evasion
• C. The investigator's concerns based on their subjective opinion
• D. The suspicious accounts and transactions identified

正解：D

解説：
Explanation
The SAR/STR narrative should include the suspicious accounts and transactions identified, as well as the reasons why they are considered suspicious. The narrative should provide a clear and concise description of the activity, the parties involved, the dates, amounts, and frequencies of the transactions, and any other relevant information that would assist law enforcement in understanding the nature and purpose of the activity.
The narrative should not include the investigator's subjective opinion, personal tax records, or supporting documentation that is not essential to explain the suspicious activity. Supporting documentation can be attached separately to the SAR/STR form or provided upon request by law enforcement.

質問 # 33
An analyst reviews an alert for high volume Automated Clearing House (ACH) activity in an account. The analyst's initial research finds the account is for a commercial daycare account that receives high volumes of large government-funded ACH transactions to support the programs. The account activity consists of checks (cheques) made payable to individual names in varying dollar amounts. One check indicates rent to another business.
An Internet search finds that the daycare company owner has previous government-issued violations for safety and classroom size needs, such as not having enough chairs and tables per enrollee. These violations were issued to a different daycare name.
Simultaneous to this investigation, another analyst sends an email about negative news articles referencing local child/adult daycare companies misusing governmental grants. This prompts the financial institution (Fl) to search all businesses for names containing 'daycare' or *care'. Text searches return a number of facilities as customers at the Fl and detects that three of these businesses have a similar transaction flow of high volume government ACH funding with little to no daycare expenses.
Which red flags would be an indicator that activity is connected to a corruption/bribery typology? (Select Two.)

• A. The same beneficial owner owning several daycare centers in different locations
• B. Checks issued to an unrelated entity referencing "rent" and "utilities" in the memos
• C. Large checks issued to various individuals with the memos noting "gift", "thank you", "favor"
• D. Multiple daycare locations with no active business operations or related account activity
• E. Negative news found on the customer related to government-issued violations for safety

正解：C、E

解説：
Explanation
The red flags that would be an indicator that activity is connected to a corruption/bribery typology are large checks issued to various individuals with the memos noting "gift", "thank you", "favor" (A) and negative news found on the customer related to government-issued violations for safety (B). These red flags suggest that the customer is involved in paying or receiving bribes or kickbacks to or from government officials or other parties in exchange for favorable treatment or contracts. These red flags are consistent with some of the indicators of corruption/bribery identified by ACAMS1, such as:
Payments made to or from third parties that are not directly related to the business Payments made to or from high-risk jurisdictions or sectors Payments made with vague or incomplete descriptions or justifications Negative news or reputation of the customer or its associates The other options are not as relevant or indicative of corruption/bribery as options A and B. Checks issued to an unrelated entity referencing "rent" and "utilities" in the memos could be a legitimate business expense or a sign of other types of fraud or money laundering, such as tax evasion or shell company schemes. Multiple daycare locations with no active business operations or related account activity (D) could also be a sign of other types of fraud or money laundering, such as embezzlement or front company schemes. The same beneficial owner owning several daycare centers in different locations (E) could be a normal or legitimate business practice, depending on the size, location, and profitability of the centers.

質問 # 34
Which actions should financial institutions perform to ensure proper data governance? (Select Three.)

• A. Review significant discrepancies between the values of the product reported on the invoice and the fair market value.
• B. Establish an appropriate data management method for collecting and storing information.
• C. For customers who are determined to be at high risk, review their risk rating and apply risk mitigation measures as appropriate.
• D. Evaluate the nature of foreign remittance under a risk-based structure of AML/CFT and take necessary measures in accordance with the risk-based approach.
• E. Ensure the accuracy of customer identification records and transaction records and appropriately manage data as a prerequisite for the effective use of IT systems.
• F. Periodically validate integrity and accuracy of information used for IT systems such as customer information, customer identification records, and transaction records.

正解：B、E、F

解説：
Explanation
Financial institutions should perform the following actions to ensure proper data governance:
Establish an appropriate data management method for collecting and storing information. This is important to ensure that the data is consistent, reliable, and accessible for various purposes, such as risk assessment, compliance reporting, and customer service. Data management methods may include defining data standards, policies, and procedures; implementing data quality controls and validation checks; and using appropriate data storage systems and formats.
Ensure the accuracy of customer identification records and transaction records and appropriately manage data as a prerequisite for the effective use of IT systems. This is important to comply with the anti-money laundering and counter-terrorist financing (AML/CFT) requirements, such as customer due diligence, transaction monitoring, and suspicious activity reporting. Accurate and complete customer and transaction data also enables financial institutions to use IT systems more effectively for data analysis, risk management, and decision making.
Periodically validate integrity and accuracy of information used for IT systems such as customer information, customer identification records, and transaction records. This is important to ensure that the data remains up-to-date, relevant, and reliable over time. Data validation may include verifying the source and quality of the data; identifying and correcting any errors or inconsistencies; and updating or deleting any obsolete or redundant data.
References:
Data Governance for Financial Institutions - Capgemini
Small and Medium-Sized Deposit-Taking Institutions (SMSBs) Capital and Liquidity Requirements - OSFI

質問 # 35
How does the Financial Action Task Force (FATF) measure the effectiveness of a country's efforts to combat money laundering and terrorist financing?

• A. Mutual evaluation
• B. Series of internal audits followed by reporting to FATF
• C. FATF Evaluation Committee
• D. Basel Committee

正解：A

解説：
Explanation
"The FATF measures the effectiveness of a country's efforts to combat money laundering and terrorist financing through a mutual evaluation process. During a mutual evaluation, the FATF assesses a country's legal and institutional framework, its implementation of measures to combat money laundering and terrorist financing, and the effectiveness of its efforts. The FATF then issues a report with recommendations for improvement" [CAMS Study Guide 6th edition, page 15-16].

質問 # 36
During transaction monitoring. Bank A learns that one of their customers. Med Supplies 123. is attempting to make a payment via wire totaling 382,500 USD to PPE Business LLC located in Mexico to purchase a large order of personal protective equipment. specifically surgical masks and face shields. Upon further verification.
Bank A decides to escalate and refers the case to investigators.
Bank A notes that, days prior to the above transaction, the same customer went to a Bank A location to wire
1,215,280 USD to Breath Well LTD located in Singapore. Breath Well was acting as an intermediary to purchase both 3-ply surgical masks and face shields from China. Bank A decided not to complete the transaction due to concerns with the involved supplier in China. Moreover, the customer is attempting to send a third wire in the amount of 350,000 USD for the purchase of these items, this time using a different vendor in China. The investigator must determine next steps in the investigation and what actions, if any. should be taken against relevant parties.
During the investigation, Bank A receives a USA PATRIOT Act Section 314(a) request related to Med Supplies 123. Which steps should the investigator take when fulfilling the request? (Select Three.)

• A. Report to Financial Crimes Enforcement Network (FinCEN) that a match was found without revealing any other details.
• B. Search its records expeditiously to determine whether it maintains(ed) any accounts for the subject(s) listed in the request.
• C. Report back to the Financial Crimes Enforcement Network (FinCEN) within 15 days of receipt of the request via a secure internet website.
• D. Review the account(s) activity and proactively file a SAR/STR using the 314(a) request as the basis for the filing.
• E. Exit the relationship with the business since it appears that customer is under investigation.
• F. Do not respond to Financial Crimes Enforcement Network (FinCEN) if the requested information is not present in the financial institution's system of records.

正解：A、B、C

解説：
Explanation
According to the FinCEN's 314(a) Fact Sheet1, the steps that the investigator should take when fulfilling the request are:
Search its records expeditiously to determine whether it maintains(ed) any accounts for the subject(s) listed in the request. This is option F.
Report back to the Financial Crimes Enforcement Network (FinCEN) within 15 days of receipt of the request via a secure internet website. This is option E.
Report to Financial Crimes Enforcement Network (FinCEN) that a match was found without revealing any other details. This is option D.
The other options are incorrect because:
Exiting the relationship with the business since it appears that customer is under investigation is not required by the 314(a) program and may interfere with law enforcement's investigation. This is option A:Not responding to Financial Crimes Enforcement Network (FinCEN) if the requested information is not present in the financial institution's system of records is contrary to the 314(a) program, which requires financial institutions to respond whether or not they have a match. This is option B.
Reviewing the account(s) activity and proactively filing a SAR/STR using the 314(a) request as the basis for the filing is not appropriate, as the 314(a) request itself is not a sufficient reason to file a SAR/STR. The financial institution should only file a SAR/STR if it has its own independent suspicion of money laundering or terrorist financing. This is option C.
References: 1: FinCEN's 314(a) Fact Sheet

質問 # 37
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