
2025年最新の実際に出ると確認された 無料ACAMS CAMS試験問題
CAMSリアル試験問題解答は無料
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、アンチマネーロンダリング(AML)と金融犯罪防止の分野での知識とスキルを向上させようとする専門家向けの世界的に認められた認定プログラムです。この認定は、AMLの進歩と金融犯罪防止に特化した主要な国際組織である認定反マネーロンダリングスペシャリスト(ACAMS)協会によって提供されます。 CAMS認定は業界で非常に尊敬されており、AMLコンプライアンスで働く専門家にとって卓越したマークです。
CAMS認定の専門家になるには、候補者は120の複数選択質問で構成される厳格な試験に合格する必要があります。試験は4つのセクションに分かれており、候補者は各セクションで少なくとも75%を獲得して試験に合格する必要があります。この試験はコンピューターベースであり、世界中のさまざまなテストセンターで撮影できます。認定は3年間有効であり、その後、継続教育コースを完了することにより、専門家は認定を更新する必要があります。
質問 # 476
A director of a financial institution was convicted of laundering money as part of a Ponzi scheme and terminated. As a result of an internal investigation evidence proved that an employee assisted in the illegal activity.
Which action should the institution take?
- A. Require all employees to complete additional anti-money laundering training
- B. Since the employee was not charged, no further action is required
- C. Discipline the employee and inform local authorities
- D. Discipline the employee with no further action
正解:C
解説:
If an employee of a financial institution is found to have assisted in money laundering or any other criminal activity, the institution should take appropriate disciplinary action and report the employee to the relevant authorities. This is not only a legal obligation, but also a sound compliance practice to protect the institution's reputation and integrity. Disciplining the employee without informing the authorities would be insufficient and potentially expose the institution to further legal risks. Ignoring the employee's involvement or requiring additional training for all employees would be ineffective and inappropriate responses.
References:
ACAMS CAMS Certification Package - 6th Edition, Chapter 5: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), pp. 121-1221 ACAMS CAMS Certification Package - 6th Edition, Chapter 6: AML Compliance Program, pp. 143-1441 ACAMS CAMS Certification Video Training Course, Module 5: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), Lesson 5.2: International Standards and Best Practices2 ACAMS CAMS Certification Video Training Course, Module 6: AML Compliance Program, Lesson
6.4: Internal Controls2
質問 # 477
What are two legal risks of having inadequate privacy policies and procedures? (Choose two.)
- A. Charges of deceptive business practices
- B. Higher marketing and public relations costs
- C. Industry of regulatory sanctions
- D. Diminished reputation
正解:A、C
解説:
Having inadequate privacy policies and procedures can expose an organization to legal risks such as industry or regulatory sanctions and charges of deceptive business practices. Industry or regulatory sanctions can result from violating the laws and regulations that govern data privacy and protection, such as the GDPR, the CCPA, or the GLBA.These sanctions can include fines, penalties, injunctions, or revocation of licenses.
Charges of deceptive business practices can arise from misleading or false statements about how the organization collects, uses, or discloses personal data, or from failing to comply with its own privacy policies and procedures. These charges can lead to lawsuits, settlements, or enforcement actions by authorities such as the FTC or the state attorneys general.: = The 4 Biggest Risks of Non-Compliance With Data Privacy Regulations Security and privacy laws, regulations, and compliance: The complete guide An Ethical Approach to Data Privacy Protection
質問 # 478
Financial Action Task Force (FATF)-style regional bodies are created and obliged to understand the inherent money laundering and terrorist financing risks in the region of the world they serve.
What is one of the methods they use to understand these risks?
- A. They conduct regional-level research and analysis of the money laundering and terrorist financing methods and trends using standards and templates used for FATF typologies reports
- B. They require participating financial institutions of their members to file suspicious transaction reports to the regional body
- C. They conduct global research on money laundering and terrorist financing trends and report their findings in their own typologies report
- D. They require member countries to develop statistical metrics over money laundering and terrorist financing crimes
正解:B
解説:
Explanation
Explanation/Reference: https://www.fatf-gafi.org/media/fatf/documents/recommendations/Private-Sector-Information- Sharing.pdf (18)
質問 # 479
Upon filing a suspicious transaction report, which of th€ following elements should be the highest anti-money laundering priority in making the decision to keep the account open?
- A. Financial impact on the institution if the account is closed.
- B. Procedures to ascertain the potential risk to the organization.
- C. Total number of accounts the institution closed in the last month.
- D. Additional Administrative costs of monitoring the account.
正解:B
解説:
According to the CAMS Certification Package - 6th Edition1, the decision to keep or close an account after filing a suspicious transaction report (STR) should be based on a risk-based approach that considers the nature and severity of the suspicious activity, the customer profile and relationship, the regulatory and legal obligations, and the reputational and operational risks for the institution. The financial impact, the administrative costs, and the number of accounts closed are not the primary factors in determining the appropriate course of action. Therefore, the correct answer is B. Procedures to ascertain the potential risk to the organization.
Reference:
CAMS Certification Package - 6th Edition1, Chapter 5: Risk Management, Section: Account Closure, pp. 211-212.
質問 # 480
Under the Wolfsberg Correspondent Banking Principles, which action is considered an enhanced due diligence obligation to correspondent banking clients that present greater risks?
- A. Ongoing monitoring of clients located in tax haven countries
- B. An evaluation done by the compliance officer in charge of the account
- C. Approval of a high-risk relationship by a senior management committee
- D. Conducting reviews on all high-risk relationships
正解:C
解説:
Explanation
Under the Wolfsberg Correspondent Banking Principles, conducting enhanced due diligence (EDD) is an obligation for correspondent banking clients that present greater risks. This may include conducting additional research and analysis of the client's background, ownership structure, and transactions. EDD may also involve obtaining additional documentation, verifying the client's identity, and conducting periodic reviews to ensure ongoing compliance. The level of EDD required should be commensurate with the level of risk posed by the correspondent banking relationship. Therefore, option B and D are incorrect. Option A is not specific enough to address the question. Option C is the correct answer as it highlights the importance of senior management approval for high-risk relationships, which is a key component of EDD.
Reference: Certified Anti-Money Laundering Specialist (the 6th edition) Study Guide, Chapter 7, page 12.
Wolfsberg Correspondent Banking Principles (2014)
質問 # 481
What is the appropriate compliance control for identifying politically exposed persons (PEPs) according to the Basel Committee's paper on Customer Due Diligence for Banks?
- A. Reviewing when a relationship is established
- B. Requiring that the customer discloses that they are a PEP or an associate of a PEP
- C. Determining that a local figure is a PEP
- D. Reviewing relationships at account opening and on a periodic basis
正解:D
質問 # 482
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 Financial Intelligence Unit (FIU)
- B. FATF
- C. The Basel Committee
- D. The Wolfsberg Group
正解:A
解説:
An FIU is a central, national agency responsible for receiving, analyzing, and disseminating to the competent authorities disclosures of financial information concerning suspected proceeds of crime and potential financing of terrorism or required by national legislation or regulation1. FIUs play a crucial role in the detection and prevention of money laundering and terrorist financing by collecting, processing, and analyzing financial intelligence and sharing it with domestic and foreign counterparts2. FIUs may have different organizational structures, functions, and legal frameworks, but they all adhere to the international standards and best practices set by the Egmont Group of FIUs3.
Reference:
What We Do | FinCEN.gov
Financial Intelligence Units: An Overview (June 2004) - IMF, page 1
[Egmont Group of Financial Intelligence Units]
質問 # 483
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 correspondent bank has opened branches in a country on the Office of Foreign Assets Control list.
- B. The primary institution has requested transactional details from the correspondent bank to aide in their investigation.
- C. The correspondent bank has recently exceeded acceptable limits in the primary banks' recently developed risk model.
- D. The compliance officer at the correspondent bank is currently being investigated due to bribery allegations.
正解:C
質問 # 484
Your company recently purchased several hundred hardware devices that contain sensors.
You need to recommend a solution to process the sensor data. The solution must provide the ability to write back configuration changes to the devices.
What should you include in the recommendation?
- A. Microsoft Azure Event Hubs
- B. Microsoft Azure Notification Hubs
- C. API apps in Microsoft Azure App Service
- D. Microsoft Azure IoT Hub
正解:D
解説:
Explanation/Reference:
References:
https://azure.microsoft.com/en-us/resources/samples/functions-js-iot-hub-processing/
質問 # 485
To deter money laundering through new accounts, a financial institution should:
1. document the identity of the party opening the account.
2. determine the beneficial owner(s) of the account.
3. query owners' names against Financial Action Task Force databases.
4. seek to determine the source of deposited funds.
- A. 1, 2, and 4 only
- B. 1, 3, and 4 only
- C. 2, 3, and 4 only
- D. 1, 2, and 3 only
正解:A
質問 # 486
Which are essential elements of a KYC program identified by the Base1 Committee on Banking Supervision?
(Select Two.)
- A. Customer acceptance policy
- B. Internal control
- C. Code of conduct
- D. Risk management
- E. Risk appetite
正解:A、D
解説:
According to the Basel Committee on Banking Supervision, a sound KYC program should include four essential elements: customer acceptance policy, customer identification, on-going monitoring of higher risk accounts, and risk management1. Customer acceptance policy defines the types of customers that the financial institution (FI) is willing to accept and the criteria for doing so. Customer identification involves verifying the identity and beneficial ownership of the customers and obtaining information on their activities and sources of funds. On-going monitoring of higher risk accounts involves reviewing the transactions and behavior of the customers that pose higher risks of money laundering or terrorist financing and updating their information and risk profiles. Risk management involves establishing appropriate policies, procedures, controls, and audit functions to ensure the effective implementation and oversight of the KYC program1.
References:
1: Basel Committee on Banking Supervision - Bank for International Settlements1
質問 # 487
Combating the Financing of Terrorism (CFT)]
Which is a purpose of imposing sanctions?
- A. Limit opportunities for desirable behavior
- B. Accomplish foreign policy and national security goals
- C. Encourage business deals
- D. Deter countries from choosing a desirable course of action
正解:B、D
解説:
Economic sanctions are measures imposed by countries or international bodies to exert pressure on individuals, entities, or nations that engage in undesirable behavior or actions. Sanctions aim to restrict or prohibit certain economic activities with the targeted parties, such as trade, investments, or financial transactions. They serve various purposes, including achieving foreign policy and national security objectives and deterring undesired actions by countries or entities. Sanctions can be comprehensive (affecting an entire country) or targeted (specific businesses, groups, or individuals), with a recent trend toward minimizing harm to innocent civilians12.
References:
1. Council on Foreign Relations: What Are Economic Sanctions?
2. [Tookitaki: A Complete Guide to Sanctions](https://www.tookitaki.com/compliance-hub/what
質問 # 488
TheWolfsberg Group's AML Principles on Private Banking:
- A. Establish rules for private bankers on how to deal with politically exposed persons (PEPs) and persons residing in high-risk countries.
- B. Assist financial institutions conducting business in jurisdictions with high data privacy standards in working with industries susceptible to money laundering.
- C. Require banks to better manage reputational risk and protect the privacy of wealthy clients.
- D. Advise banks to accept only those clients whose source of funds and beneficial ownership isunderstood.
正解:A
質問 # 489
What are three risk factors a financial institution should examine with regard to a proposed new product?
- A. The complexity of the product
- B. Whether other financial institutions are marketing the product
- C. Whether the product is easily transferable
- D. The need to verify the identification of the customer
正解:A、C、D
質問 # 490
Which type of sanctions are most likely to be used in order to avoid escalating violent conflicts and/or proliferation of weapons?
- A. Arms and related materials embargo
- B. Export and import restrictions
- C. Financial prohibitions
- D. Asset freeze
正解:A
解説:
Arms and related materials embargo is a type of sanction that prohibits the supply, sale, transfer, or export of arms and related materials to a targeted country, entity, or individual. This type of sanction is most likely to be used in order to avoid escalating violent conflicts and/or proliferation of weapons, as it aims to reduce the availability and access of weapons and ammunition that could fuel violence and instability. Arms and related materials embargo can also prevent the transfer of weapons of mass destruction and their delivery systems to non-state actors or rogue states. According to the UN, arms and related materials embargo is one of the most common and effective forms of sanctions that the Security Council imposes to address threats to international peace and security12.
Reference:
1: Different types of sanctions - Consilium1
2: UN Sanctions and the Prevention of Conflict - United Nations University2
質問 # 491
You plan to deploy two AI applications named AI1 and AI2. The data for the applications will be stored in a relational database.
You need to ensure that the users of AI1 and AI2 can see only data in each user's respective geographic region. The solution must be enforced at the database level by using row-level security.
Which database solution should you use to store the application data?
- A. Microsoft Azure Data Lake Store
- B. Microsoft SQL Server on a Microsoft Azure virtual machine
- C. Microsoft Azure Database for MySQL
- D. Microsoft Azure Cosmos DB
正解:B
解説:
Row-level security is supported by SQL Server, Azure SQL Database, and Azure SQL Data Warehouse.
References:
https://docs.microsoft.com/en-us/sql/relational-databases/security/row-level-security?view=sql-server-2017
質問 # 492
Which of the following activities is most likely associated with a lawyer participating in a money laundering scheme?
- A. Represents persons accused of crimes against financial institutions.
- B. Creates corporate entities to disguise true beneficial ownership of clients.
- C. Engages clients with high-net worth in foreign countries.
- D. Frequently travels to countries considered tax havens.
正解:B
解説:
One of the common methods used by money launderers to hide the origin and destination of illicit funds is to create complex corporate structures that obscure the identity of the real owners or controllers of the assets.
Lawyers can facilitate this process by providing legal services such as setting up shell companies, trusts, foundations, or other entities in jurisdictions with weak AML regulations or high secrecy. By doing so, lawyers can help their clients evade taxes, avoid sanctions, conceal criminal activities, or launder money. This is why lawyers are considered high-risk professionals for AML purposes and are subject to due diligence and reporting obligations.
= Some of the references that support this answer are:
ACAMS Study Guide for the CAMS Certification Examination, Chapter 3, Section 3.2.2, page 77: "Lawyers are often used to create complex corporate structures that can be used to hide the beneficial ownership of assets." Money Laundering Reporting Officer: The Role Of MLRO, Section "Money Laundering Risks For Lawyers":
"Lawyers are at risk of being used by criminals to launder money through various means, such as creating corporate entities, conducting transactions, or providing advice." New York Lawyer Pleads Guilty to Ponzi Scheme, Money Laundering, Section "Lawyer agrees to forfeit $19 million from investment scheme": "A New York lawyer admitted Monday to money laundering and orchestrating an $18.8 million Ponzi scheme using his Forest Hills-based law firms, Wisnicki & Associates LLP and Wisnicki Neuhauser LLP."
質問 # 493
Which method is used to launder money via wire remittances sent through a bureau de change or money services business?
- A. A customer in country A receives four small wire transfers from four different individuals located in countryB on December 21. The aggregate of the wire transfers falls below the legal reporting threshold.
- B. A customer in country A makes frequent wire transfers to a single customer in country B that are slightlyunder the legal reporting threshold.
- C. A customer in country A makes a weekly small wire transfer to the bank account of an individual in country
- D. A large number of wire transfers are sent from a large number of senders in country A to a large number ofrecipients in country B during the period of December 1 to December 15.
正解:B
解説:
The correct answer is B, because it describes a method of money laundering known as structuring or smurfing. This is when a customer or a group of customers break down large amounts of illicit funds into smaller transactions that are below the reporting threshold, and then send them to another customer or entity, often in another country. This way, they avoid triggering any suspicion or regulatory reporting by the bureau de change or money services business (MSB) that processes the wire transfers.
Structuring or smurfing is a common technique used by money launderers to move funds across borders and disguise their origin and destination.
The other options are not necessarily indicative of money laundering, although they may require further investigation depending on the circumstances and the risk profile of the customers and countries involved.
Option A describes a regular and small wire transfer that may be legitimate, such as a remittance to a family member or a friend. Option Cdescribes a large volume of wire transfers that may be related to a seasonal or business activity, such as a holiday or a trade event. Option D describes a series of small wire transfers that may be coincidental or random, and do not necessarily add up to a significant amount.
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 2, pages 36-37
https://www.acams.org/wp-content/uploads/2019/09/ACAMS-CAMS-Study-Guide-6th-Edition-Chapter-2.pdf
質問 # 494
In performing a risk analysis, which factor(s) should a financial institution review?
- A. Its customer base, location, products and services
- B. The adequacy and completeness of its STR filings
- C. The level of its gross revenue
- D. Recent regulatory actions against financial institutions of comparable size
正解:A
解説:
these are the main factors that determine the inherent money laundering risk of a financial institution. The customer base, location, products and services of a financial institution affect the type, volume, and complexity of transactions that it processes, as well as the exposure to high-risk customers, jurisdictions, and activities12. A financial institution should review these factors regularly and conduct a comprehensive risk assessment to identify, measure, and mitigate its money laundering risk34.
Anti Money Laundering Risk Assessment - Financial Crime Academy1
Anti-Money-Laundering (AML) Risk Approach Explained | Okta2
Anti-Money Laundering (AML) Risk Assessment | ACAMS4
2024 National Money Laundering Risk Assessment (NMLRA)5
質問 # 495
Which payment method for purchasing luxury items is a red flag for potential money laundering?
- A. Cash
- B. Credit card
- C. Wire transfer
- D. Personal loan
正解:A
解説:
Explanation
According to the Financial Action Task Force (FATF), the use of large amounts of cash is a common method for money launderers to move illicit funds [1]. Purchasing luxury items with cash can indicate an attempt to convert illegal funds into tangible assets that can be easily resold or moved across borders. As a result, businesses that deal with luxury items are required to implement enhanced due diligence measures, including monitoring transactions involving large amounts of cash [1].
Reference: [1] Financial Action Task Force. (2013). Money Laundering & Terrorist Financing Through the Real Estate Sector. https://www.fatf-gafi.org/media/fatf/documents/reports/ML-TF-through-real-estate.pdf
質問 # 496
An automotive parts company in South America sends multiple $500,000 wire transfers per week to ABC Holdings Ltd. in Asia referencing payment for silk flower shipments. Research reveals Sunrise Holdings, Ltd is registered in the British Virgin Islands with no available ownership information.
What are two red flags that indicate how trade-based money laundering could be occurring in this instance?
(Choose two.)
- A. The transaction involves the use of front (or shell) companies
- B. The packaging is inconsistent with the commodity or shipping method
- C. Significant discrepancies appear between the description of the commodity on the bill of lading and the invoice
- D. The type of commodity being shipped appears inconsistent with the exporter or importer's regular business activities
正解:A、D
解説:
Trade-based money laundering (TBML) is a method of disguising and moving illicit funds through the international trade system. Criminals often manipulate various aspects of trade transactions, such as pricing, quantity, documentation, and commodity type, to transfer value and obscure the source of funds. Some of the common red flags that may indicate TBML are:
The transaction involves the use of front (or shell) companies: Front or shell companies are entities that have no physical presence, no employees, and no business activity, but are used to facilitate money laundering. They often have vague or generic names, are registered in secrecy jurisdictions, and have no available ownership information. In this case, ABC Holdings Ltd. and Sunrise Holdings Ltd. could be front or shell companies that are used to launder money through trade transactions.
The type of commodity being shipped appears inconsistent with the exporter or importer's regular business activities: Criminals may use commodities that are unrelated to their core business or that have low correlation with the market price to launder money. They may also use commodities that are difficult to value, verify, or trace, such as precious metals, gems, art, or antiquities. In this case, the automotive parts company and the silk flower supplier seem to have no logical connection, and the value of the silk flowers may be inflated or deflated to transfer funds.
References:
Trade-Based Money Laundering: Risk Indicators - Financial Action Task Force, pp. 9-10, 14-15 Identifying TBML: 8 Trade-Based Money Laundering Red Flags - Alessa, pp. 1-2 FFIEC BSA/AML Appendices - Appendix F - Money Laundering and Terrorist Financing Red Flags, p.
7
AML Red Flags - What are the Top 10 Indicators? - ComplyAdvantage, p. 1
質問 # 497
A financial institution files a suspicious transaction report on a customer as the result of a high volume of large currency deposits to pay off a loan. A law enforcement officer calls the anti-money laundering officer to discuss the suspicious transaction report. Which of the following is the anti-money laundering officer legally permitted to do?
1. Discuss any aspects of the reported activity.
2. Provide copies of the customer's loan documents.
3. Explain the customer's loan payment history.
4. Send the deposit documents referenced in the suspicious transaction report.
- A. 2 and 3 only
- B. 1 and 2 only
- C. 2 and 4 only
- D. 1 and 4 only
正解:A
質問 # 498
What must be materially true regarding transactions for United States (U.S.) sanctions laws to have jurisdiction?
- A. Transactions are identified as proceeds of foreign corruption
- B. Transactions are traced to illegal proceeds
- C. Transactions are processed by a U.S. person
- D. Transactions are stripped of beneficial owner information
正解:C
解説:
Reference: https://www.treasury.gov/resource-center/faqs/Sanctions/Documents/faq_all.html
''Who must comply with OFAC regulations?U.S. persons must comply with OFAC regulations, including all
U.S. citizens and permanent resident aliens regardless of where they are located, all persons and entities within the United States, all U.S. incorporated entities and their foreign branches. In the cases of certain programs, foreign subsidiaries owned or controlled by U.S. companies also must comply. Certain programs also require foreign persons in possession of U.S.-origin goods. please refer to:
https://home.treasury.gov/policy-issues/financial-sanctions/frequently-asked-questions/ofac-consolidated-frequen
質問 # 499
The USA PATRIOT Act requires United States (U.S.) financial institutions to collect certain information from non-U.S. banks that hold a correspondent account.
Which two pieces of information must a non-U.S. bank provide to its U.S. correspondent to enable them to comply with this requirement? (Choose two.)
- A. Prompt notice of any suspicious activity it detects on any customer who uses the correspondent account
- B. The name and address of all beneficial owners who own 25% or more of the bank
- C. The name and address of a U.S. person who is authorized to receive service of legal process for the bank
- D. The name and address of all shell banks the bank maintains accounts for
正解:A、B
解説:
Explanation/Reference: https://www.sec.gov/about/offices/ocie/amlsourcetool.htm
質問 # 500
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CAMS認定を取得すると、AMLコンプライアンスで働く専門家に多くの利点があります。知識とスキルを向上させ、仕事のパフォーマンスを向上させ、雇用市場での信頼性と市場性を向上させることができます。さらに、新しいキャリアの機会を開き、収益の可能性を高めることができます。全体として、CAMS認定は、AMLと金融犯罪防止の分野で優れていることを検討している専門家にとって不可欠な資格です。
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