[2024年05月07日]CAMS試験問題集PDF正確率保証と更新された問題
合格させるCAMS試験にはリアルテストエンジンPDFには617問題あります
ACAMS CAMS認定は、AMLプロフェッショナルがAMLコンプライアンス体制の専門知識と知識を示すことを望む場合に貴重な資格です。この認定は、グローバルに認められ、AML分野の卓越性の基準となっています。CAMS試験は厳しいですが、適切な準備と献身により、候補者は合格し、認定を取得して、新しいキャリアの機会を開拓し、プロフェッショナルな評判を高めることができます。
CAMS試験に合格すると、専門家の卓越性に対する個人のコミットメントと、最新のAMLの傾向と規制に最新の状態を維持することへの献身が示されています。また、AMLの専門家としての信頼性と市場性を高め、キャリアの進歩と収益の可能性の増加の機会を開きます。
質問 # 112
How can a financial institution verify the nature and purpose of a business and its legitimacy?
- A. By reviewing a copy of the corporation's latest audited reports and accounts
- B. By reviewing the company's website
- C. By using an independent information verification process, such as by accessing public and private databases
- D. By undertaking a company search or other commercial inquires to see that the institution has not been, or is not in the process of being dissolved of terminated
正解：D
質問 # 113
Which is the first valid step in the Mutual Legal Assistance Treaties (MLAT) international cooperation process?
- A. The central authority that receives the request sends it to a local judicial officer to find out if the information is available.
- B. An investigator from the requesting country visits the country where the information is sought and takes statements from the identified witnesses or suspects.
- C. The central authority of the requesting country sends a commission letter of request to the central authority of the other country.
- D. The investigator may remove the evidence collected without asking permission to do so.
正解：C
解説：
Reference:
https://www.unodc.org/documents/organized-crime/Publications/Mutual_Legal_Assistance_Ebook_E.pdf
質問 # 114
A company contracts a life insurance policy with a savings feature of 100,000 USD for an individual in a high-risk country. The policy receives monthly cash deposits from unknown third parties. A minimal part of the deposit is invested and the rest is withdrawn by the end of the month. Which are the circumstances to consider as a risk for money laundering? (Select Two.)
- A. A company established in a high-risk country contracting a policy for a domestic individual
- B. A life insurance policy with a savings feature for a national from a high-risk country
- C. The regular withdrawals from the policy by the end of the month
- D. Unidentified third parties depositing cash to the policy
- E. A policy for an amount of 100,000 USD is to be considered high and suspicious
正解：C、D
解説：
According to the ACAMS CAMS Study Guide (the 6th edition), one of the common methods of money laundering in the insurance sector is to purchase policies with illicit funds, overpay premiums, and then cancel or surrender the policies to receive refunds or payouts1. This allows criminals to move and disguise the source of their funds through the insurance company. Therefore, the regular withdrawals from the policy by the end of the month could indicate a money laundering scheme. Moreover, the FATF Guidance for a Risk-Based Approach for the Life Insurance Sector states that unidentified third parties depositing cash to the policy could also pose a high money laundering risk, as cash transactions are difficult to trace and third parties may act as intermediaries or nominees for the real beneficiaries2. Therefore, the insurance company should conduct enhanced due diligence on the policyholder and the third parties, and monitor the transactions for any suspicious activity.
References:
ACAMS CAMS Study Guide (the 6th edition), Chapter 2: Money Laundering Risks and Methods, page
671
FATF Guidance for a Risk-Based Approach for the Life Insurance Sector, pages 18-192
質問 # 115
A client who owns a swimming pool company requests to open 19 accounts at a bank, each with a debit card for its swimming pool technicians. When asked about the purpose of each account, the client explains that each technician needs a separate checking account to purchase pool chemicals.
Which available source could be used in the bank's internal investigation on this client's activities?
- A. Client's credit bureau report
- B. Internet search showing how such business are typically operated
- C. Local law enforcement investigation report
- D. Interview swimming pool technicians and chemical suppliers
正解：A
質問 # 116
According to the Financial Action Task Force, which action must a financial institution take to fulfill customer due diligence obligations?
- A. Identify shareholders listed on the stock exchange of corporate entities holding fifty percent of the shares.
- B. Verify the customer is not on any sanction lists.
- C. Obtain information on the intended nature of the banking relationship.
- D. Secure a written declaration from the customer confirming the source of the funds.
正解：B
解説：
Explanation
According to the Financial Action Task Force (FATF), a financial institution must take certain steps to fulfill its customer due diligence (CDD) obligations [1][2]. These steps include verifying the customer's identity, understanding the customer's business, and assessing the customer's risk profile. Additionally, the financial institution must verify that the customer is not on any sanction lists, such as the OFAC Specially Designated Nationals list. This step is important to ensure that the financial institution is not doing business with any individuals or entities that are subject to economic sanctions. Other steps include obtaining information on the intended nature of the banking relationship, securing a written declaration from the customer confirming the source of the funds, and identifying shareholders listed on the stock exchange of corporate entities holding fifty percent of the shares.
質問 # 117
A country that does not have strong predicate offenses and is lax in prosecuting AML cases could suffer which social/economic consequence?
- A. US sanctions
- B. Loss of tax revenue
- C. Increased organized crime and corruption
- D. Reputation risk for the port
正解：C
解説：
Predicate offenses are the criminal activities that generate the proceeds that are later laundered through money laundering schemes. A country that does not have strong predicate offenses and is lax in prosecuting AML cases could suffer from increased organized crime and corruption, as criminals would have more opportunities and incentives to engage in illicit activities and evade detection and punishment. Organized crime and corruption can have serious social and economic consequences for a country, such as undermining the rule of law, eroding public trust, threatening national security, harming human rights, reducing economic growth, and distorting market competition123.
References:
CAMS Certification Package - 6th Edition | ACAMS
Understanding Predicate Offences: The Hidden Web of Money Laundering
Predicate Offenses In Money Laundering - Financial Crime Academy
AML Terms Easily Confused: Predicate Offense vs. Money Laundering
質問 # 118
Which action should an FIU consider taking when it has information that might be useful to another FIU?
- A. Request approval from the Egmont Group prior to sharing the information with the other FIU
- B. Take no action until contacted by the other FIU
- C. Supply the information to the other FIU spontaneously as soon as the relevance of sharing the information is identified
- D. In accordance with Wolfsberg guidelines, submit the information to the other FIU in written form
正解：C
解説：
According to the Egmont Group of Financial Intelligence Units, which is a network of over 160 FIUs that promotes international cooperation and information exchange, FIUs should share information with foreign FIUs spontaneously, without prior request, when they have reasonable grounds to believe that the information is relevant for the receiving FIU1. This principle is also reflected in the FATF Recommendation 40, which states that FIUs should exchange information with other FIUs, especially when this information concerns money laundering, predicate offences, or terrorist financing2. Spontaneous information sharing can enhance the effectiveness of FIUs, as it can help to identify new leads, trends, patterns, or typologies, as well as to prevent or disrupt criminal activities1.
The other options are not consistent with the best practices of FIU information sharing. For example:
In accordance with Wolfsberg guidelines, submit the information to the other FIU in written form. The Wolfsberg Group is an association of 13 global banks that issues guidance and standards on anti-money laundering and counter-terrorist financing. However, the Wolfsberg guidelines are not binding for FIUs, and they do not specify the format or channel of information exchange between FIUs3. Moreover, submitting information in written form may not be the most efficient or secure way of communication, as it may cause delays, errors, or breaches of confidentiality.
Take no action until contacted by the other FIU. This option contradicts the principle of spontaneous information sharing, as it implies that the FIU with the relevant information will wait for a formal request from the other FIU, instead of proactively sharing the information. This may result in missed opportunities, inefficiencies, or failures in detecting or preventing money laundering or terrorist financing.
Request approval from the Egmont Group prior to sharing the information with the other FIU. This option is unnecessary and impractical, as the Egmont Group does not have the authority or the capacity to approve or deny individual information requests or exchanges between FIUs. The Egmont Group provides a platform and a framework for FIU cooperation, but it does not interfere with the operational autonomy or the bilateral relations of its members4.
References:
FATF Recommendation 40: Other Forms of International Co-operation
Egmont Group of Financial Intelligence Units Principles for Information Exchange Between Financial Intelligence Units Wolfsberg Group Egmont Group
質問 # 119
The Chief Compliance Officer (CCO) of a financial institution has been asked by a manufacturing customer reliant upon imported raw materials if there will be repercussions to his business following the weak assessment of the recent publicly issued Financial Action Task Force (FATF) Mutual Evaluation Report (MER). How should the CCO respond?
- A. Delayed processing of cross-border transfer of funds between countries may occur due to increased scrutiny to determine the legitimacy of each transfer.
- B. Citing inaccurate content of the MER. the president of the country has called upon the FATF to publicly withdraw the MER and commission an independent review of findings.
- C. Mandate termination of all cross-border trading until evidence can be provided to show an improved position of compliance for the weaknesses stated in the MER.
- D. Negative consequences will not occur because the manufacturing customer has been trading with reputable countries and suppliers for many years without incident.
正解：A
解説：
According to the Certified Anti-Money Laundering Specialist (the 6th edition) Study guide, the CCO should advise the manufacturing customer that increased scrutiny of cross-border transfers may lead to delays and caution them to ensure that all necessary documentation is provided in order to facilitate a timely transfer.
Additionally, the CCO should recommend that the customer contact the FATF to discuss the possibility of an independent review of the findings, as well as other options to mitigate the potential negative consequences.
質問 # 120
Historically, which of the following vehicles is most often used to hide beneficial ownership?
- A. a limited liability partnership
- B. an offshore company
- C. a charitable organization
- D. a professional association
正解：B
解説：
An offshore company is a legal entity that is incorporated or registered in a foreign jurisdiction, usually with low or no taxes, high confidentiality, and minimal regulation1. Offshore companies are often used to hide beneficial ownership, as they can create complex and opaque structures that obscure the identity and control of the real owners and beneficiaries of the assets or transactions involved2. Offshore companies can also use nominee directors and shareholders, trust and company service providers, and shell companies to further conceal beneficial ownership3. According to the web search results, offshore companies are among the most common vehicles for money laundering, tax evasion, corruption, and other illicit activities4 .
References:
1: What is an offshore company? - ACAMS
2: Guidance on Transparency and Beneficial Ownership - FATF
3: Concealment of Beneficial Ownership - FATF-Egmont Group
4: What's a Beneficial Owner and Why Does it Matter? - Dun & Bradstreet
5: The Panama Papers: Exposing the Rogue Offshore Finance Industry - ICIJ
質問 # 121
Which three procedures should a compliance officer looking to revise an institution's CTF efforts include in accordance with the Wolfsberg Group's Statement on the Suppression of the Financing of Terrorism?
- A. Reviewing only original identification documents when verifying customers
- B. Reporting matches from lists of known or suspected terrorists to relevant authorities
- C. Maintaining customer information to facilitate timely retrieval of such information
- D. Consulting applicable lists and taking appropriate actions to determine if customers appear on such lists
正解：B、C、D
解説：
According to the Wolfsberg Group's Statement on the Suppression of the Financing of Terrorism1, a compliance officer should include the following three procedures in revising an institution's CTF efforts:
Consulting applicable lists and taking appropriate actions to determine if customers appear on such lists.
This procedure is important to prevent terrorist organizations from accessing the financial services of the institution and to comply with the sanctions and regulations imposed by competent authorities. The compliance officer should implement procedures for checking the customers against the lists of known or suspected terrorists or terrorist organizations issued by relevant authorities and taking reasonable and practicable steps to verify the identity and status of the customers.
Reporting matches from lists of known or suspected terrorists to relevant authorities. This procedure is important to assist the authorities in their efforts to detect and disrupt terrorist financing and to fulfill the legal obligations of the institution. The compliance officer should report to the relevant authorities any matches from the lists of known or suspected terrorists or terrorist organizations consistent with the applicable laws and regulations regarding the disclosure of customer information.
Maintaining customer information to facilitate timely retrieval of such information. This procedure is important to enable the institution to respond promptly and effectively to the enquiries and requests from the authorities and to enhance the quality and accuracy of the customer data. The compliance officer should explore ways of improving the maintenance of customer information to facilitate the timely retrieval of such information.
References:
Wolfsberg Statement on Anti-Terrorism Financing
UNUSUAL CUSTOMER IDENTIFICATION CIRCUMSTANCES
* Customer furnishes unusual or suspicious identification documents or declines to produce originals for verification."
質問 # 122
A bank located in New York has identified suspicious transactions at a correspondent bank in ChinA. For one of the international customers, the correspondent bank is not following agreed upon protocols.
Which factor indicates that the bank should terminate the relationship?
- A. The primary institution has requested transactional details from the correspondent bank to aide in their investigation.
- B. The correspondent bank has opened branches in a country on the Office of Foreign Assets Control list.
- C. The compliance officer at the correspondent bank is currently being investigated due to bribery allegations.
- D. The correspondent bank has recently exceeded acceptable limits in the primary banks' recently developed risk model.
正解：D
質問 # 123
When implementing a risk-based approach related to casinos, which risks are related to the customer as an individual? (Choose two.)
- A. Transfer between customers
- B. Customer from a high-risk country
- C. Casual customers
- D. Use of casino deposit accounts by the customer
- E. Improper use of third parties as customers
正解：B、C
解説：
When implementing a risk-based approach related to casinos, the risks related to the customer as an individual are mainly based on the customer's profile, behaviour, source of funds, and geographic location. Among the options given, B and D are the most relevant factors that could indicate a higher risk of money laundering or terrorist financing.
Casual customers are those who do not have a regular or established relationship with the casino, and who may visit the casino only once or occasionally. They may not provide sufficient or reliable identification information, or may use false or stolen identities. They may also engage in suspicious transactions, such as large cash purchases of chips, minimal or no gaming activity, or frequent transfers of chips between customers. Casual customers pose a higher risk of money laundering or terrorist financing because they are harder to verify, monitor, and trace by the casino operators.
Customer from a high-risk country is a customer who resides in, or has links to, a country that is subject to sanctions, embargoes, or similar measures, or that is identified by credible sources as having significant levels of corruption, or as being a source, transit, or destination of illicit funds. Such customers pose a higher risk of money laundering or terrorist financing because they may be involved in, or connected to, criminal or terrorist activities, or may be using funds that are derived from or intended for such activities.
References: = The main reference for this question is the document titled "FATF Guidance on the Risk-Based Approach for Casinos" published by the FATF in October 2008. You can access it by clicking here. You can also find more information about the risk-based approach and the customer risks for casinos on the Gambling Commission website and the Exam Answer website.
質問 # 124
How can dealers in high-value items be at risk for money laundering?
- A. Carrying large amounts of gems of high value is physically easy
- B. Paperwork is not required to ship precious metals and gems
- C. Drug dealers prefer cash to precious metals and gems
- D. The value of precious metals such as gold and silver is constantly fluctuating.
正解：A
質問 # 125
What national agency is responsible for analyzing and assessing the information it receives to substantiate possible existence of money laundering or terrorist financing activities?
- A. The Wolfsberg Group
- B. The Basel Committee
- C. FATF
- D. The Financial Intelligence Unit (FIU)
正解：C
質問 # 126
According to the Basel Committee, customer acceptance, customer due diligence, and record-keeping policies and procedures should be changed as necessary to:
- A. address structure changes strictly related to new employees.
- B. ensure policies and procedures are reviewed every three months.
- C. address KYC deficiencies in account opening procedures.
- D. address variations in risk among each line of business within the organization.
正解：D
解説：
The Basel Committee on Banking Supervision (BCBS) is an international body that sets standards and guidelines for the prudential regulation of banks. One of its key publications is the Customer Due Diligence for Banks, which outlines the essential elements of Know Your Customer (KYC) standards for banks.
According to this document, customer acceptance, customer due diligence, and record-keeping policies and procedures should be changed as necessary to address variations in risk among each line of business within the organization. This means that banks should adopt a risk-based approach to KYC, taking into account the different types, levels, and sources of risk associated with different customers, products, services, transactions, and delivery channels. By doing so, banks can allocate their resources more efficiently and effectively, and mitigate the potential for money laundering, terrorist financing, and other financial crimes.
References:
Customer Due Diligence for Banks, BCBS, October 2001, p. 5, 14-15.
The Basel Committee: The Important Set Of International Banking Regulations, Financial Crime Academy, November 2023.
質問 # 127
Which three measures are contained in Financial Action Task Force 40 Recommendations for reporting suspicious activity? (Choose three.)
- A. The financial institution has grounds to believe the activity is related to terrorist financing.
- B. The financial institution has been contracted by law enforcement regarding the activity.
- C. The financial institution has contacted the account holder to determine the activity of the account.
- D. The financial institution has reasonable grounds to suspect the funds are proceeds of criminal activity.
- E. The activity should be reported promptly to the country's financial intelligence unit.
正解：A、D、E
解説：
Explanation
REPORTING OF SUSPICIOUS TRANSACTIONS [https://www.fatf-
gafi.org/media/fatf/documents/recommendations/pdfs/FATF%20Recommendations%202012.pdf] If a financial institution suspects or has reasonable grounds to suspect that funds are the proceeds of a criminal activity, or are related to terrorist financing, it should be required, by law, to report promptly its suspicions to the financial intelligence unit (FIU). According to the Financial Action Task Force's (FATF) Recommendation 20, a suspicious transaction report (STR) or a suspicious activity report (SAR) is filed by a financial institution or, by a concerned citizen, to the local Financial Intelligence Unit if they have reasonable grounds to believe that a transaction is related to criminal activity.
[https://aml-cft.net/library/suspicious-transaction-report-str-suspicious-activity-report-sar/]
質問 # 128
Separating illicit proceeds from their source by a series of complex financial Transactions designed to disguise the audit trail and provide anonymity is an example of what?
- A. integration
- B. layering
- C. placement
- D. structuring
正解：B
解説：
Layering is the second stage of the money laundering process, in which the launderer moves the funds around to create distance and confusion between the source and the destination of the illicit proceeds. Layering often involves multiple transactions, such as wire transfers, shell companies, trusts, and offshore accounts, that make it difficult to trace the origin and ownership of the funds. Layering is intended to disguise the audit trail and provide anonymity for the launderer12.
Placement is the first stage of the money laundering process, in which the launderer introduces the illicit proceeds into the financial system, often by breaking them into smaller amounts or using cash-intensive businesses12.
Structuring is a technique used in the placement stage, in which the launderer deposits or withdraws cash in amounts below the reporting threshold to avoid detection or suspicion12.
Integration is the third and final stage of the money laundering process, in which the launderer reintroduces the funds into the legitimate economy, often by purchasing assets, investing in businesses, or mixing them with legal income12.
References: 1: ACAMS (2020), Study Guide for the Certification Examination, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams-certification-package-6th-edition, pp. 12-14. 2: ACAMS (2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams-certification-package-6th-edition, Module 1.
質問 # 129
The most important anti-money laundering issue associated with on-line banking is accurately
- A. Capturing data
- B. Analyzing data
- C. Generating reports
- D. Identifying clients
正解：D
質問 # 130
What do Financial Action Task Force (FATF)-style regional bodies do for their members to help combat money laundering and terrorist financing?
- A. They provide technical assistance to members in implementing FATF recommendations
- B. They assist member countries in penalizing entities that violate FATF standards and recommendations
- C. They supervise member country financial institutions relating to anti-money laundering and terrorist financing
- D. They work with members on areas of concern outside of anti-money laundering and terrorist financing
正解：C
解説：
Explanation/Reference: https://www.fatf-gafi.org/media/fatf/documents/brochuresannualreports/FATF30-(1989-2019).pdf
質問 # 131
A compliance officer at a financial institution (FI) received an investigation request for a customer from a local law enforcement agency. Which action should be taken by the FI?
- A. Assign employees responsible for the customer to the investigation team.
- B. Consider retaining qualified, experienced legal counsel.
- C. Obtain approval from the Financial Intelligence Unit (FIU) before submitting the customer's information.
- D. Omit some responses to meet the regulatory deadline.
正解：C
質問 # 132
When creating an anti-money laundering program for a foreign bank with branches in the United States, which of the following are included among the four minimum elements required under the USA PATRIOT Act?
1. The development of a Know Your Customer program.
2. An ongoing employee training program.
3. The designation of a compliance officer.
4. An independent audit function to test the program.
- A. 1, 2, and 3 only
- B. 1, 2, and 4 only
- C. 1, 3, and 4 only
- D. 2, 3, and 4 only
正解：B
質問 # 133
......
ACAMS CAMS（認定反マネーロンダリングスペシャリスト）認定試験は、AML（反マネーロンダリング）分野のプロフェッショナルの知識とスキルをテストするために設計された、世界的に認知されている認定試験です。試験は、金融機関、規制当局、法執行機関、および金融犯罪防止に関わる他の組織で働くプロフェッショナルを対象としています。CAMS認定は、AMLプロフェッションの進展を目的とした専門組織であるAssociation of Certified Anti-Money Laundering Specialists（ACAMS）によって授与されます。
最新をゲットせよ！CAMS認定練習テスト問題試験問題集：https://jp.fast2test.com/CAMS-premium-file.html
リアルCAMS試験問題集解答で有効なCAMS問題集PDF：https://drive.google.com/open?id=1M3Z2mdSueIepFFvpVptnUQUWenOKqCBn