[2025年09月]更新のACAMS Advanced-CAMS-Audit試験一発合格保証！
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質問 # 31
During a sanction review, an auditor notes that several of the bank's large corporate clients continue to route transactions through the bank to certain Office of Foreign AssetsControl (OFAC)-sanctioned countries.The head of corporate clients stated that these transactions were executed under the OFAC license.What should an auditor know to distinguish between an OFAC general license and a specific license?
- A. A general license authorizes a transaction for an entity and a specific license authorizes a transaction for an individual.
- B. A specific license authorizes a type of transaction and a general license authorizes a transaction in response to a written license application.
- C. A general license authorizes a type of transaction and a specific license authorizes a transaction in response to a written license application.
- D. A specific license authorizes a transaction for an entity and a general license authorizes a transaction for an individual.
正解：C
解説：
Distinguishing General and Specific Licenses:
* Ageneral licensepermits predefined categories of transactions without individual approval.
* Aspecific licenseis issued for unique transactions based on a written application evaluated on a case-by- case basis.
OFAC Guidance:
* Auditors should verify that transactions routed through sanctioned countries align with the licenses and confirm appropriate documentation for compliance.
質問 # 32
During the ongoing due diligence process the company becomes aware that the customer is holding personal assets for a politically exposed person (PEP). What should the auditor recommend to enhance the control environment for this customer relationship? (Select Three.)
- A. File a suspicious activity report as the previous riskrating was not correct.
- B. Review and document the details of the customer s asset-holding arrangement.
- C. Deploy automated monitoring toots to efficiently peruse the customer's KYC information and assure that the customer's KYC risk rating is correct.
- D. Review the customer risk profile every two years as with any other customers.
- E. Designate the account as a PEP-account.
- F. Conduct enhanced due diligence and enhanced ongoing monitoring of the customer relationship.
正解：B、E、F
解説：
C:Designating the account as a PEP-account triggers additional monitoring and controls as PEPs inherently pose higher risks.
D:Enhanced due diligence (EDD) and ongoing monitoring are essential for PEPs to track their financial activities closely and address any anomalies.
E:Documenting the details of the asset-holding arrangement provides clarity on the customer's profile and any associated risks.
質問 # 33
An auditor should verify that an institution has ensured its AML systems and controls include:
- A. training for senior management and the governing body only.
- B. supporting documents of its risk management policies and risk profile in relation to money laundering.
- C. measures to ensure that money laundering risk is taken into account in its monthly operations.
- D. daily reports by the institution's money laundering reporting officer on the operation and effectiveness of those systems and controls.
正解：B
解説：
Core Components of AML Systems and Controls:
* Supporting documentation ensures alignment with regulatory expectations and helps auditors verify that the institution's policies and controls reflect its assessed risks.
Other Options:
* B:Monthly operations are operational concerns, not control documentation.
* C:Daily reports are excessive for governance purposes.
* D:Training must include all staff, not only senior management.
質問 # 34
Which can be excluded from an audit report?
- A. Overall opinions, judgments or conclusions reached in prior audit reports
- B. The overall opinion judgment, or conclusion reached
- C. The scope, including the time period to which the opinion pertains
- D. The risk or control framework or other criteria used as a basis for the overall opinion
正解：A
解説：
Exclusion from Current Audit Reports:
* Prior conclusions are relevant for context but do not belong in the current report, which should focus on new findings and opinions.
Other Options:
* The risk framework, scope, and current conclusions are integral to the current audit report.
質問 # 35
The auditor finds that thecustomer risk assessment (CRA) is completed at initial onboarding and is repealed for each customer every other year. The auditor's observations should Include that the CRA should:
- A. be updated more often given the risk of the entity.
- B. include a qualitative overlay that 95% of the products offered are subject to regulatory exemptions.
- C. allow for sales oy third patties other than advisors since most of the customers are local residents.
- D. include an assessment of jurisdiction where the customer currently resides as this may have changed.
正解：D
解説：
Dynamic Nature of Customer Risk Assessment (CRA):
* A comprehensive CRA should incorporate jurisdictional risks, as customer location changes could introduce new risks, such as exposure to high-risk or non-compliant jurisdictions.
FATF Recommendations on Risk-Based Approach:
* Periodic updates to the CRA, including changes in customer location, align with FATF's risk-based approach and Recommendation 10.
Audit Observation Implications:
* Omission of jurisdictional assessments could result in undetected risks, undermining the integrity of the AML program.
質問 # 36
When assessing the effectiveness of a transaction monitoring system, which indicators require active monitoring by the auditor or compliance'? (Select Two.)
- A. Scenario altering techniques
- B. False positive ratio
- C. Robustness of feedback relating to submitted suspicious activity reports
- D. Complexity of monitoring scenarios
- E. Data quality and mapping
正解：B、E
解説：
Transaction Monitoring Effectiveness:
* A. Data Quality: Accurate data mapping ensures scenarios detect relevant risks, reducing errors in monitoring.
* D. False Positives: Monitoring false positive ratios improves system efficiency and minimizes unnecessary alerts.
質問 # 37
Findings from a financial institution's (Fl's) regulatory examination suggest that several unidentified risks pose a serious threat. The Fl identifies the risks and implements a set of controls to mitigate those risks.
Which type of risk considers the controls' effectiveness?
- A. Aggregate
- B. Consolidated
- C. Inherent
- D. Residual
正解：D
解説：
Definition of Residual Risk:
* Residual risk is the risk that remains after controls are implemented to mitigate inherent risks.
* It reflects the effectiveness of controls and highlights areas requiring further attention.
Relevance in Risk Management:
* Evaluating residual risk helps determine whether existing controls adequately address the identified risks.
CAMS-Audit Best Practices:
* Auditors must assess residual risk as part of the broader risk management framework to ensure regulatory compliance and operational resilience.
質問 # 38
An auditor is writing the scope for an AML review of a financial institution. The objective is to evaluate how effectively existing controls are designed and operating. Which areas should be assessed? (Select Two.)
- A. Previous correspondent banking relationships
- B. Client base stability
- C. Recent audit findings
- D. AML corporate governance
- E. Clients of the institution for more than 10 years
正解：C、D
解説：
Recent Audit Findings:
* Reviewing past findings ensures the institution has addressed previous deficiencies and allows the auditor to assess the effectiveness of implemented corrective actions.
AML Corporate Governance:
* Corporate governance is a critical component of AML compliance, involving oversight structures, policies, and accountability mechanisms to prevent money laundering risks.
Alignment with CAMS-Audit Principles:
* Advanced CAMS-Audit emphasizes evaluating governance structures and learning from recent audits to maintain robust AML controls.
質問 # 39
The auditor determines that the population for transaction monitoring testing can be stratified into five distinct categories. To complete testing which sampling method should the auditor use to identify the sample size?
- A. Statistical
- B. Risk-based
- C. Judgmental
- D. Proportional
正解：A
解説：
* Importance of Statistical Sampling in Transaction Monitoring Testing:
* Statistical sampling is the most suitable method when dealing with stratified populations, as it ensures a representative sample is drawn from each distinct category.
* This method allows auditors to achieve reliable results by applying mathematical and probabilistic models to calculate the required sample size, ensuring unbiased and valid conclusions.
* Relevance to Stratified Populations:
* When the transaction monitoring population is divided into distinct categories, statistical sampling ensures that each category is proportionately represented based on its size or risk level within the overall population.
* Evaluation of Other Options:
* Judgmental Sampling:Relies on auditor discretion and may introduce bias, making it unsuitable for ensuring proportional representation in stratified populations.
* Proportional Sampling:Focuses only on proportional representation but does not leverage statistical tools to determine the optimal sample size or confidence levels.
* Risk-Based Sampling:While effective in certain contexts, it is better suited for focusing on high- risk categories rather than ensuring comprehensive representation of all strata.
* Alignment with Advanced CAMS-Audit Standards:
* Advanced CAMS-Audit recommends statistical sampling for stratified populations to ensure that all categories are adequately tested and results are statistically valid for compliance and performance assessments.
Conclusion:The auditor should usestatistical samplingto identify the sample size when testing a stratified population for transaction monitoring. This ensures a reliable, unbiased, and mathematically sound basis for the audit.
質問 # 40
Which products/services increase the risk level for money laundering for XYZ Bank?
- A. Foreign exchange services
- B. Letters of credit
- C. International fund transfers
- D. Payable through accounts
正解：C、D
解説：
Payable through accounts allow foreign banks' customers direct access to the correspondent account, which can increase the risk of money laundering due to less direct oversight.
質問 # 41
Which should be evaluated when analyzing components of risk mitigation in an AML risk assessment?
(Select Two.)
- A. Customer risk
- B. Overall customer volume
- C. Product risk
- D. Office of Foreign Assets Control filtering
- E. Liquidity risk
正解：A、C
解説：
Product Risk: Certain products (e.g., high-value transfers, anonymous payment systems) inherently carry higher AML risks and require tailored risk mitigation measures.
Customer Risk: Understanding the risk profile of customers, including PEPs and high-net-worth individuals, is critical to assessing exposure and implementing risk-based approaches.
Both factors are core components in AML risk assessments, as highlighted in CAMS-Audit materials and FATF standards.
質問 # 42
What factors are considered tor conducting an external audit and assurance review? (Select Three.)
- A. Purpose of the review
- B. Type of reporting format
- C. Budget available for the review
- D. Type of risk assessment needed
- E. Information that will be required
- F. Users of the external report
正解：A、D、F
解説：
Factors for External Audit:
* C. Purpose of the Review: Determines the scope and focus of the audit to align with regulatory or organizational objectives.
* D. Type of Risk Assessment Needed: Tailors the audit methodology to the identified risks.
* E. Users of the External Report: Ensures the audit addresses the needs of regulators, stakeholders, or management.
質問 # 43
A retail banking small and medium-sized enterprise (SME) customer launches a charity and requests a Corporate-SME account to receive donations and make disbursements. Which scenarios would most likely identify activity related to a charity account?(Select Two.)
- A. Scenario 1
- B. Scenario 7
- C. Scenario 4
- D. Scenario 6
- E. Scenario 5
正解：A、B
解説：
Scenario 1: Evaluates unusual activity, such as large, unexplained deposits or withdrawals, which are red flags in charity-related accounts .
Scenario 7: Exads to detect inconsistencies with the stated purpose, ensuring adherence to AML standards for NPOs.
質問 # 44
Considering recent changes in the bank's correspondent banking business. Which is the most important risk indicator for the internal auditor to review?
- A. The purpose of the services provided to the respondent bank.
- B. The management and ownership of the respondent bank.
- C. The major business activities of the respondent bank.
- D. The jurisdiction in which the respondent bank is located.
正解：D
解説：
Jurisdictional risk is critical in correspondent banking due to potential exposure to countries with weaker AML
/CFT controls, high corruption levels, or sanctions.
質問 # 45
What type of audit approach should the auditor use when testing KYC files as part of an AML examination?
- A. Full scope
- B. Vertical
- C. Horizontal
- D. Risk-based
正解：B
解説：
Understanding the Vertical Approach:
* A vertical audit focuses on reviewing the entire process or function within a single area or department, such as testing KYC files for compliance and effectiveness in a specific customer group or business line.
Application in AML Examinations:
* Vertical audits are particularly useful for examining KYC processes as they allow auditors to trace the end-to-end workflow, from customer onboarding to risk assessment and ongoing monitoring.
Alignment with Advanced CAMS-Audit Guidelines:
* The vertical approach provides detailed insights into compliance gaps within the KYC function, helping auditors identify root causes and systemic issues, which is emphasized in CAMS-Audit training.
質問 # 46
Which are key responsibilities of internal auditors? (Select Two.)
- A. Determining appropriate risk appetite of the entity
- B. Implementing controls and other safeguards
- C. Acting as a catalyst for improvement
- D. Mitigating the risks facing the organization
- E. Evaluating the management of risk
正解：C、E
解説：
Evaluating the Management of Risk:
* Internal auditors assess the effectiveness of risk management strategies to ensure alignment with organizational goals and regulatory expectations.
Acting as a Catalyst for Improvement:
* Auditors provide insights and recommendations to enhance controls and improve overall risk management practices.
CAMS-Audit Emphasis:
* CAMS-Audit outlines the dual role of internal auditors in evaluating and facilitating risk management improvements.
質問 # 47
A financial institution utilizes an automated daily validation report to validate the accuracy of the data flowing into its monitoring software. An auditor is responsible for testing the data used to create the report. This is an example of testing which type of effectiveness?
- A. Software
- B. Operating
- C. Program
- D. Design
正解：B
解説：
Testing Operating Effectiveness:
* Operating effectiveness testing evaluates whether controls and systems are functioning as intended on a daily basis, including the accuracy and reliability of automated validation processes.
Relevance to Data Validation:
* The auditor's role in this scenario ensures that the data flowing into the monitoring software is accurate and aligned with operational requirements, reflecting day-to-day effectiveness.
CAMS-Audit Emphasis:
* The emphasis on ongoing operational validation is consistent with Advanced CAMS-Audit practices, which stress continuous monitoring of AML system effectiveness.
質問 # 48
The standard audit report format requires that an executive summary of the findings is included. Which statement is most appropriate for summarizing detailed findings'?
- A. The dealers have assured they are able to identify long-standing regular clients that are typically collectors and customers for occasional transactions.
- B. Deletion of transaction records for completed occasional transactions is operationally an efficient practice.
- C. Evidence indicated inconsistent application of the client risk rating procedures and lack of evidence of enhanced due diligence measures for higher risk clients.
- D. Although the evidence of enhanced due diligence performed was not available audit was satisfied that the risk of higher risk clients has been appropriately mitigated.
正解：C
解説：
Executive Summary Requirements:
* The statement focuses on clear, evidence-based findings, critical for reflecting material deficiencies in enhanced due diligence (EDD) for high-risk clients.
Guidelines for Reporting:
* FATF emphasizes the consistent application of risk rating systems to ensure ML/TF risks are adequately mitigated.
質問 # 49
Following completion of testing and tuning of the parameters and thresholds of the transaction monitoring model which final step should the team recommend as necessary to verify effective model functioning?
- A. Regulatory approvals
- B. Data validation
- C. Model validation
- D. Audit continuous monitoring
正解：C
解説：
Purpose of Model Validation:
* Model validation ensures that the transaction monitoring model is functioning as intended, effectively identifying suspicious transactions and mitigating AML/CFT risks.
* It encompasses testing data accuracy, parameter relevance, threshold efficacy, and compliance with regulatory requirements.
Process:
* Validation includes end-to-end reviews, statistical evaluations, and expert assessments of model outputs.
* According to FATF and Basel Committee standards, model validation is a critical component of the AML framework.
Irrelevance of Other Options:
* Audit continuous monitoringfocuses on ongoing oversight, not the specific confirmation of initial model functionality.
* Data validationaddresses data quality but does not verify operational model performance.
* Regulatory approvalsare necessary for compliance but are not a step in verifying model functioning.
質問 # 50
Which should the auditor recommend to management in terms of the client's risk rating procedures?
- A. Remove enhanced due diligence requirements for long-standing clients that are art collectors and do not transact with precious metals.
- B. Provide staff with training on new record retention requirements for occasional transactions.
- C. Remediate client files to verify their AML and sanctions risk rating and document enhanced due diligence measures, where applicable.
- D. Include an assessment of risk factors of channel, credit, and transaction risk to determine the client's composite AML and sanctions risk score.
正解：D
解説：
* Incorporating Comprehensive Risk Factors
* By including an assessment of channel, credit, and transaction risks, the client's overall risk profile is accurately determined. This aligns with risk-based approaches emphasized by FATF and CAMS-Audit standards.
* These risk factors provide a granular view of the client's risk level, ensuring proper classification into Standard or Enhanced Due Diligence categories.
* Regulatory Alignment
* FATF Recommendations mandate that client risk assessments consider the products, services, and delivery channels used, as well as geographic and transactional risks.
ConclusionImplementing composite AML and sanctions risk scores ensures the institution is compliant with regulatory standards and adequately mitigates risks associated with different client profiles.
質問 # 51
Which finding must be first remediated in order to understand is risks the organization is exposed to?
- A. Finding 5
- B. Finding 8
- C. Finding 1
- D. Finding 3
正解：C
解説：
Finding 1
* This finding likely pertains to foundational gaps in the organization's risk assessment framework or the absence of a comprehensive understanding of inherent risks. Without addressing this, the organization cannot adequately identify, assess, or mitigate risks effectively.
* According to CAMS-Audit standards, a thorough risk assessment is the cornerstone of an effective AML/CFT program. It helps to prioritize resources and design appropriate controls based on the identified risk levels.
Critical Role in Understanding Risks
* Remediating foundational issues ensures that the organization has a clear understanding of its risk exposure across all products, services, and jurisdictions. This step is essential before addressing downstream issues such as customer due diligence (CDD) gaps or monitoring inefficiencies.
Alignment with Regulatory Requirements
* FATF guidelines and CAMS-Audit practices emphasize that risk assessment should precede other remediation efforts. Without this, the organization may address symptoms rather than root causes of compliance and operational risks.
質問 # 52
When reviewing an AML policy, an auditor should expect to find that the policy.
- A. has been approved by regulators.
- B. is aligned with investment strategy.
- C. was reviewed and approved by the money laundering reporting officer.
- D. contains items related to staff training.
正解：D
解説：
AML Policy Expectations:
* Staff training is a fundamental component of an effective AML program. FATF Recommendations and Basel Committee guidelines require AML policies to address staff training to ensure compliance with AML/CFT laws
質問 # 53
As an auditor reviewing this investigation report, which indicates an effective process?
- A. The compliance officer concluded from the report that there are reasonable grounds for suspicion and filed a suspicious activity report.
- B. The compliance officer concluded the investigation approximately 3 months later and filed a suspicious activity report.
- C. The compliance officer filed a suspicious activity report and omitted details regarding the reason it was filed.
- D. The compliance officer decided not to cease the Business relationship hut kept the account under rigorous monitoring process.
正解：A
解説：
Filing an SAR based on reasonable grounds for suspicion ensures compliance with AML obligations and demonstrates the effectiveness of the investigative process.
質問 # 54
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