CAMS-FCI事前に試験練習テストで使おう（最新102問題)
有効なCAMS-FCI試験解答PDF一年無料更新
質問 # 34
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. Volunteer information not requested by the agents that the employees think may be useful.
- C. Take notes on the questions and comments made by the agents.
- D. Sign consent forms permitting the agents to search employees' offices.
正解：C
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 # 35
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 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.
What is the total suspicious transaction amount that the investigator should report?
- A. 59,000,000 USD
- B. 600,000,000 USD
- C. 541.000,000 USD
- D. 659,000,000 USD
正解：D
解説：
Explanation
The total suspicious transaction amount that the investigator should report is 659,000,000 USD. This is the sum of the two transactions involving the LLC and the state-run oil company, which are 59,000,000 USD and
600,000,000 USD respectively. The other transactions that the LLC made to other accounts, a money brokerage firm, and real estate purchases are not relevant to the question, as they are not part of the series of transactions that triggered the alert.
References: Advanced CAMS-FCI Certification | ACAMS
質問 # 36
A compliance analyst is reviewing the account activity of a customer that they suspect may be indicative of money laundering activity. Which is difficult to determine solely from the customer's account activity and KYC file?
- A. If the account has multiple transfers to the same, related businesses
- B. If the account is mostly dormant or has little activity
- C. If there is negative media associated with counterparties
- D. If the activity is materially different from related businesses
正解：C
解説：
Explanation
According to the Certified Anti-Money Laundering Specialist (CAMS) study guide, 6th edition, page 105, the correct answer is C. It can be difficult to determine if there is negative media associated with counterparties solely from the customer's account activity and KYC file.
The study guide explains that negative media can include news articles, government sanctions lists, and other sources of public information that may indicate that a counterparty is involved in illicit activities. However, this information may not be readily available in a customer's account activity or KYC file, and may require additional research or investigation.
質問 # 37
In a SAR/STR narrative concerning Individual A. which statement indicates a product of analysis rather than a fact or judgement?
- A. Individual A is a college student and employed part-time at a car wash.
- B. Individual A made structured cash deposits possibly to circumvent regulatory reporting requirements
- C. Individual A made structured cash deposits on almost consecutive days.
- D. Individual A was the originator of nine wires totaling 225.000 USD between January and March 2020.
正解：B
解説：
Explanation
A product of analysis is a conclusion or inference that is derived from facts or judgments, using analytical techniques or tools. Option B is a product of analysis because it implies that the investigator has used a tool or technique, such as a threshold analysis, to identify a pattern of structured cash deposits that may indicate an attempt to evade reporting requirements. The other options are facts or judgments that can be verified by evidence or observation.
References: Advanced CAMS-FCI Certification Handbook, page 23.
質問 # 38
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 'care1. 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.
During the investigation, it was determined that some of the checks were issued to a mother-in-law of a PEP and deposited into her account with the Fl. This customer was not found on the Fl's PEP list How should the investigator proceed in this situation"? (Select Two.)
- A. Conduct the investigation as usual, since the activity in question is not directly connected to the PEP.
- B. Reter the newly identified customers account for closure due to the high risk associated with the potential PEP.
- C. Send a referral to Sanctions/List Screening, or similar department/responsible individual, to ensure that the customer due diligence information is up to date.
- D. File a SAR/STR due to the potential involvement of a PEP.
- E. Use this case as an example to train employees to recognize potential PEPs during their investigation process.
正解：A、C
解説：
Explanation
The investigator should proceed in this situation by conducting the investigation as usual, since the activity in question is not directly connected to the PEP (A) and sending a referral to Sanctions/List Screening, or similar department/responsible individual, to ensure that the customer due diligence information is up to date (D).
These actions are appropriate and prudent, as they allow the investigator to continue their analysis of the suspicious activity without being biased by the potential PEP status of the customer's relative, and they ensure that the FI has accurate and current information about its customers and their associates. According to the ACAMS Advanced Financial Crimes Investigations Certification Study Guide1, "the FI should conduct enhanced due diligence on all parties involved in the investigation, including checking various sources of information, such as watch lists, sanctions lists, negative news, and official registries" (p. 24). The FI should also "update the customer profile with any new information obtained during the investigation" (p. 25).
The other options are not correct. The investigator should not refer the newly identified customer's account for closure due to the high risk associated with the potential PEP (B), as this could be premature or disproportionate, as well as potentially discriminatory or illegal. The investigator should not file a SAR/STR due to the potential involvement of a PEP (E), as this could also be premature or unnecessary, as well as potentially misleading or inaccurate. The investigator should not use this case as an example to train employees to recognize potential PEPs during their investigation process , as this could violate confidentiality or data protection laws, as well as compromise the investigation or alert the customer or their relative of the suspicion.
References: 1: ACAMS Advanced Financial Crimes Investigations Certification Study Guide, available at ACAMS
質問 # 39
A SAR/STR regarding money-mule activity prompts law enforcement action. Under U.S. law, the alleged money mules can be prosecuted:
- A. even if they were unaware that money was transferred.
- B. in a country only if funds were transferred between accounts maintained in the same country.
- C. unless they can prove they were not aware of the origin of the funds.
- D. only if they were aware of their role and actively participated.
正解：A
解説：
Explanation
According to U.S. law, money mules can be prosecuted even if they were unaware that money was transferred, as long as they acted with reckless disregard of the source of the funds or the purpose of the transaction1.
This is because money mules are considered to be aiding and abetting money laundering, which does not require proof of specific intent2.
References: 1: Money Mule Awareness Booklet, page 8 2: Money Laundering: An Overview of 18 U.S.C. § 1956 and Related Federal Criminal Law, page 7
質問 # 40
Law enforcement (LE) suspects human trafficking to occur during a major sporting 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 after 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 dates1' and "companionship." The Fl wants to create an automated alert for human trafficking money laundering after this investigation.
Which activity type should they target?
- A. Payments made to multiple hotels in the same city
- B. Deposits made within days of major sporting events
- C. Payments made for virtual currency
- D. Multiple deposits between midnight and 4:00 AM
正解：D
解説：
Explanation
The activity type that the FI should target for creating an automated alert for human trafficking money laundering is multiple deposits between midnight and 4:00 AM (B). This is because this pattern is consistent with the indicators of human trafficking identified by the Financial Action Task Force (FATF) and the Egmont Group1, which include:
Frequent cash deposits, often in round amounts, outside of normal business hours Deposits made at different branches or ATMs in various locations Lack of information about the nature and purpose of the business Involvement in online platforms that advertise sexual services Expenses related to travel and accommodation The other options are not as relevant or specific as option B. Payments made to multiple hotels in the same city (A) could be a legitimate business expense or a sign of other types of money laundering, such as tax evasion or fraud. Deposits made within days of major sporting events could also be explained by other factors, such as increased tourism or gambling. Payments made for virtual currency (D) are not directly related to human trafficking, although they could be used to facilitate money laundering in general.
References: 1: FATF and Egmont Group, Financial Flows from Human Trafficking, July 2018, available at FATF
質問 # 41 
In a review of the account activity associated with Nadine Kien, an investigator observes a large number of small- to medium-size deposits from numerous individuals from several different global regions. The money is then transferred to a numbered company. Which is the next best course of action for the investigator?
- A. Complete the monthly review and note the activity for next month's review.
- B. No further action is required as the customer is already rated at high-risk and the monthly spending is within expectations.
- C. Recommend the account for exit due to frequent global transactions.
- D. File a SAR/STR on the account activity in relation to a potential funnel account.
正解：D
解説：
Explanation
The next best course of action for the investigator is to file a SAR/STR on the account activity in relation to a potential funnel account. This is because a funnel account is a type of money laundering scheme that involves depositing funds from multiple sources into a single account, and then transferring them to another account, often in a different jurisdiction. A funnel account can be used to conceal the origin, ownership, and destination of illicit funds, and to evade currency transaction reporting requirements. The investigator should report the suspicious activity to the relevant authorities and document the findings and actions taken. The other options are incorrect because:
A: Completing the monthly review and noting the activity for next month's review is not sufficient, as it delays the reporting of a possible money laundering scheme and exposes the financial institution to regulatory and reputational risks.
C: Recommending the account for exit due to frequent global transactions is not appropriate, as it does not address the underlying issue of potential money laundering and may alert the customer of the investigation.
D: No further action is required as the customer is already rated at high-risk and the monthly spending is within expectations is not acceptable, as it ignores the red flags of a funnel account and fails to comply with the anti-money laundering obligations of the financial institution.
References:
Advanced CAMS-FCI Certification | ACAMS, Section 2: Investigating Financial Crimes, page 9 Leading Complex Investigations Certificate | ACAMS, Module 2: Identifying Red Flags, page 5
質問 # 42
During onboarding al Private Bank A, client C indicated that the account would be initially funded with a transfer from Bank B totaling 50 million USD. On which source of funds should Bank A conduct additional scrutiny? (Select Two.)
- A. Third-party transfer
- B. Documented sale of client properties
- C. Client's verified employment income
- D. Client's overall wealth
- E. Transfer from Bank B
正解：A、E
解説：
Explanation
The sources of funds that Bank A should conduct additional scrutiny on are the third-party transfer and the transfer from Bank B. This is because these sources may pose higher risks of money laundering, terrorist financing, fraud, or other illicit activities. Some of the reasons why these sources require more scrutiny are23:
Third-party transfers may involve unknown or unrelated parties that may have ulterior motives or hidden agendas. They may also be used to obscure the origin or destination of funds, or to circumvent sanctions or other regulatory restrictions.
Transfers from Bank B may involve jurisdictions that have weak anti-money laundering and counter-terrorist financing (AML/CFT) regimes, high levels of corruption, or significant criminal activity. They may also involve banks that have poor reputation, compliance, or transparency standards.
References:
Third Party Payments - Wolfsberg Group
Guidance on Correspondent Banking Services - FATF
質問 # 43
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. The customer information, including KYC background
- B. The fact that one of the transactors occasionally smelled of marijuana smoke
- C. A transaction that is commensurate with the customer's background
- D. Details of the transactor's social media accounts
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 # 44
The investigative department of a financial institution (Fl) receives an internal escalation notice from the remittance department for a SWIFT message requesting a refund due to potential fraud. The notice indicates that a total of three international incoming remittances were transferred to a corporate customer from Country A, in the amount of approximately 5 million EUR for each. The first two incoming remittances had been exchanged into currency B and transferred out to Country B a few days ago. The third incoming remittance has been held by the remittance department.
As noted from the KYC profile, the corporate customer is working in the wood industry. with the last account review completed 3 months ago. Since the account's opening. there has been no history of a large amount of funds flowing through the account. The investigator conducts an Internet search and finds that the remitter is a food beverage company.
The same morning, the investigator receives a call from a financial intelligence unit (FIU) inquiring about the same incident. The FIU states that it will issue a warrant to freeze the account on the same day.
After further review, the decision is made that transactions appear suspicious. Which are the next steps the investigator should take? (Select Two.)
- A. Close the investigation as the FIU is already on this matter, and they will inform LE if needed.
- B. Close the customer's accounts since the FIU is issuing a warrant to freeze the funds.
- C. Gather all the information that would be useful for law enforcement (LE) and recommend filing a SAR/STR
- D. Provide additional information to the LE upon receiving a formal request.
- E. Contact local LE and advise them of the investigation details to help speed up the investigation and prosecution.
正解：C、D
解説：
Explanation
The correct answer is C and E.
The investigator should provide additional information to the LE upon receiving a formal request, and gather all the information that would be useful for LE and recommend filing a SAR/STR. These steps are consistent with the best practices of conducting financial crime investigations and reporting suspicious activity. The investigator should not close the customer's accounts or the investigation, as this may interfere with the ongoing LE inquiry and violate the FI's policies and procedures. The investigator should also not contact local LE directly, as this may compromise the confidentiality of the investigation and the FIU's authority. References:
Advanced CAMS-FCI Study Guide, Chapter 4: Reporting Suspicious Activity, pages 40-411 Advanced CAMS-FCI Study Guide, Chapter 5: Governance of an AFC Investigations Unit, pages
48-491
Advanced CAMS-FCI Certification | ACAMS
質問 # 45
A financial institution (Fl) has considered the available relevant factors in a transaction and has determined it will file a SAR^STR. Which is needed to support the contents of the report to the financial intelligence unit?
- A. No factual description of the suspicious activity
- B. Definitive proof that suspicious activity occurred
- C. Low evidentiary threshold about the suspicious activity
- D. Enough circumstantial evidence about the suspicious activity for a criminal proceeding
正解：C
解説：
Explanation
A SAR/STR does not require definitive proof or enough circumstantial evidence of suspicious activity, as these are high evidentiary thresholds that may be difficult or impossible to obtain by the FI. A SAR/STR should include a factual description of the suspicious activity, as this is essential for the FIU to analyze and disseminate the information. A low evidentiary threshold means that the FI has reasonable grounds to suspect that the activity is related to money laundering, terrorism financing, or other financial crimes, based on the available relevant factors. This is the main criterion for filing a SAR/STR.
References: Advanced CAMS-FCI Certification | ACAMS, Suspicious activity report - Wikipedia, Suspicious Transaction Report (STR) / Suspicious Activity Report (SAR ...
質問 # 46
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.
The analyst determines that site visits should be conducted for the three daycare businesses. Which observations at the on-site visits would justify writing a SAR/STR? (Select Three.)
- A. Visible signage indicating the purpose of the building
- B. Signs of severe wear and poor maintenance at the site
- C. A full parking lot of cars with no staff at the site
- D. Lights turned off at the site during operational hours
- E. A site located in a commercial building
- F. Visible attendance with children being dropped off by parents
正解：B、C、D
解説：
Explanation
The observations at the on-site visits that would justify writing a SAR/STR are signs of severe wear and poor maintenance at the site (A), lights turned off at the site during operational hours , and a full parking lot of cars with no staff at the site (F). These observations suggest that the daycare businesses are not operating legitimately or providing adequate services to their customers, and that they may be misusing governmental grants or laundering money through their accounts. These observations are consistent with some of the red flags for fraud identified by ACAMS2, such as:
Inadequate facilities or equipment for the type of business
Lack of visible activity or customers at the business location
Discrepancy between reported income and expenses
Unusual volume or frequency of transactions
The other observations are not as relevant or indicative of fraud as options A, C, and F. A site located in a commercial building (B) could be a normal or legitimate choice for a daycare business, depending on its size, location, and availability. Visible attendance with children being dropped off by parents (D) could show that the daycare business is providing genuine services to its customers, although it does not rule out possible fraud or money laundering. Visible signage indicating the purpose of building (E) could also show that the daycare business is transparent and legitimate, although it does not guarantee its quality or compliance.
References: 1: ACAMS Advanced Financial Crimes Investigations Certification Study Guide, available at ACAMS 2: ACAMS Fraud Prevention eLearning Course Module 3: Fraud Detection Techniques
質問 # 47
A national financial intelligence unit (FIU) is undertaking the country risk assessment for the financing of the proliferation of weapons of mass destruction (WMD). The evaluation involves determining the exposure that financial institutions (FIs) have to operations that evade sanctions. Which should be performed by the FIU to assess proliferation financing risk? (Select Two.)
- A. Evaluate a sample of the amount of false-positive and false-negative alerts that FIs have regarding proliferation sanctions evasion to determine root causes of non-detection.
- B. Prepare new regulations that increase fines for FIs that allow financial operations on behalf of WMD proliferation sanctioned states.
- C. Analyze the domestic financial operations that are above the reporting threshold and have similar names to high-level officials of WMD proliferation sanctioned states.
- D. Cross-reference the databases of international commerce/logistics transactions between the country and WMD proliferation sanctioned states with the corresponding international financial operations of those transactions.
- E. Compare the international finance operations with national PEP lists to determine if the systems used by FIs are properly calibrated to detect WMD proliferation financing.
正解：A、D
解説：
Explanation
The FIU should cross-reference the databases of international commerce/logistics transactions between the country and WMD proliferation sanctioned states with the corresponding international financial operations of those transactions, as this would help identify any discrepancies or anomalies that could indicate sanctions evasion. The FIU should also evaluate a sample of the amount of false-positive and false-negative alerts that FIs have regarding proliferation sanctions evasion to determine root causes of non-detection, such as inadequate screening systems, lack of training, or human error. These actions would help the FIU assess the proliferation financing risk and provide feedback and guidance to FIs on how to improve their detection and prevention capabilities.
References: Advanced CAMS-FCI Study Guide, page 32-33; [FATF Guidance on Counter Proliferation Financing], page 15-16.
質問 # 48
A new customer has just been onboarded in a securities firm. After a few weeks, there are unusual trading patterns that are being flagged. Which pattern is most concerning to the compliance officer?
- A. The customer engages in large trading in securities that are liquid or highly priced from the trading account.
- B. The customer accumulates securities of a low volume counter in small increments on a weekly basis.
- C. The customer receives many incoming wire transfers from related parties to the trading account.
- D. The customer's repeated trading in securities that are low priced and low volume counters.
正解：B
解説：
Explanation
The most concerning trading pattern for a compliance officer when a new customer has been onboarded in a securities firm is the customer accumulating securities of a low volume counter in small increments on a weekly basis. This type of behavior could indicate that the customer is attempting to obscure their identity or the true purpose of their trading activity, which can be indicative of money laundering or other suspicious activity. (CAMS Manual, 6th Edition, Page 170).
質問 # 49
A country that does not have strong predicate offenses and is lax in prosecuting AML cases could suffer which social/economic consequence?
- A. Reputation risk for the port
- B. Increased organized crime and corruption
- C. Loss of tax revenue
- D. US sanctions
正解：B
解説：
Explanation
A country that does not have strong predicate offenses and is lax in prosecuting AML cases could suffer increased organized crime and corruption as a social/economic consequence. "Weaknesses in the AML/CFT regime can lead to a range of economic and social consequences, including...increased crime and corruption." (CAMS Manual, 6th Edition, page 32)
質問 # 50
The intended benefits of section 314(b) of the USA PATRIOT Act include: (Select Three.)
- A. expediting the filing of SARs/STRs due to the information sharing facilitated by 314(b).
- B. participating FIs sharing information about suspicious activity by customers that may have otherwise gone unnoticed.
- C. providing mandatory results to law enforcement agencies so that they can more easily obtain useful information.
- D. sharing the existence and content of SARs/STRs with other participating FIs.
- E. detecting money laundering and TF approaches and schemes across multiple financial institutions (FIs).
- F. obtaining additional information on customers or transactions regarding potential money laundering or terrorist financing (TF).
正解：B、E、F
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 # 51
A bank's transaction surveillance system triggers an alert for a deposit of 250.000 USO into a client's account.
According to the bank's KYC information, the client works for a financial advisory firm, and earns approximately 100,000 USD per year. Which actions should be taken? (Select Three.) File the suspicious transaction immediately to the financial intelligence unit.
- A. Contact the client advisor to learn if he has any insight on the transaction background.
- B. Request information and documentation from the client on the background of the transaction.
- C. Review the transaction background in the bank's transaction platform.
- D. Review the alert if the deposit is made in cash.
- E. Discard the alert as a false positive hit
正解：A、B、C
解説：
Explanation
According to the Certified Anti-Money Laundering Specialist (CAMS) Manual , 6th edition, if a bank's transaction surveillance system triggers an alert for a deposit of 250.000 USD into a client's account, the bank should take the following actions:
Request information and documentation from the client on the background of the transaction (CAMS Manual, 6th edition, page 46).
Contact the client advisor to learn if he has any insight on the transaction background (CAMS Manual,
6th edition, page 47).
Review the transaction background in the bank's transaction platform (CAMS Manual, 6th edition, page
47).
Discarding the alert as a false positive hit and reviewing the alert if the deposit is made in cash should not be done.
The bank should request additional information and documentation from the client to better understand the nature of the transaction. Additionally, the bank should reach out to the client advisor to learn if they have any insight on the transaction background. Finally, the bank should review the transaction background in the bank's transaction platform to determine if any additional alerts or anomalies are present. (CAMS Manual, 6th Edition, Pages 117-118)
質問 # 52
A client at a financial institution deposits large amounts of money into an account, and almost immediately, the funds are then distributed to numerous individuals' accounts. The transaction activity described in the scenario is a pattern of:
- A. geographic usage.
- B. safe deposit custody.
- C. deposit trading.
- D. account usage.
正解：C
解説：
Explanation
Deposit trading is a pattern of suspicious activity where a client deposits large amounts of money into an account, and then transfers the funds to other accounts, often in different jurisdictions or countries. This could be an attempt to disguise the source or destination of the funds, or to avoid reporting requirements. Deposit trading is also known as layering, which is the second stage of money laundering.
References: ACAMS Advanced Financial Crimes Investigations Certification Study Guide, page 43; ACAMS Glossary, page 34.
質問 # 53
An investigator is reviewing a case generated from the transaction monitoring system, with two large amounts of incoming remittance (IR) to an individual customer. Based on the KYC profile, the customer is a plant manager of a famous multi-national electronics manufacturing firm. As the customer has no similarly large transaction patterns for the past 2 years, the investigator sends an inquiry to the relationship manager (RM) about the nature of the transaction. The RM replies that the transaction is a consultancy fee provided from two different electronics companies with a debit note provided However, there is no detail of service provided on the debit note, and the remitters are two individuals.
Which actions should the investigator recommend to mitigate risk? (Select Two.)
- A. Re-evaluate the customer risk profile.
- B. Exit the relationship with the customer.
- C. Conduct enhanced due diligence.
- D. Document and maintain a file with the investigative findings.
- E. Discuss the investigation findings with the customer.
正解：A、C
解説：
Explanation
The actions that the investigator should recommend to mitigate risk are conducting enhanced due diligence (D) and re-evaluating the customer risk profile (E). These actions are appropriate and prudent, as they allow the investigator to obtain more information and evidence about the nature and purpose of the transactions, the source and destination of the funds, and the identity and legitimacy of the parties involved. According to the ACAMS Advanced Financial Crimes Investigations Certification Study Guide1, "the FI should conduct enhanced due diligence on all parties involved in the investigation, including checking various sources of information, such as watch lists, sanctions lists, negative news, and official registries" (p. 24). The FI should also "re-assess the customer risk profile based on any new information obtained during the investigation, and adjust the customer due diligence and monitoring requirements accordingly" (p. 25).
The other options are not as appropriate or effective as options D and E. The investigator should not recommend exiting the relationship with the customer (A), as this could be premature or disproportionate, as well as potentially discriminatory or illegal. The investigator should not recommend documenting and maintaining a file with the investigative findings (B), as this is not an action to mitigate risk, but rather a standard procedure for any investigation. The investigator should not recommend discussing the investigation findings with the customer , as this could compromise the integrity and objectivity of the investigation, as well as expose the FI to legal or regulatory risks.
References: 1: ACAMS Advanced Financial Crimes Investigations Certification Study Guide
質問 # 54
A retail bank prepares a yearly AML risk assessment. Which inherent risk factor is likely the most relevant?
- A. The provision of cash services
- B. The provision of remote check deposit services
- C. The provision of payable through accounts
- D. The provision of brokerage services
正解：A
解説：
Explanation
Retail banks typically have a high inherent risk of money laundering due to their provision of cash services.
This is because cash is a preferred medium of exchange for criminals and terrorists, and retail banks provide a convenient way for them to move large sums of money without detection. Retail banks are also vulnerable to money laundering through the use of false identities and other deceptive practices. (CAMS Manual, 6th Edition, Page 8).
質問 # 55
A bank investigator notices an account receiving multiple deposits from the same employer under different employees' names. A cash withdrawal occurs one day after each deposit. The outcome of this investigation will likely uncover which crime typology?
- A. Bribery and corruption
- B. Trade-based money laundering
- C. Environmental
- D. Human trafficking
正解：A
解説：
Explanation
The correct answer is A because this scenario describes a possible case of human trafficking, which is a crime where people are exploited for labor or sexual services against their will. Human traffickers may use bank accounts to launder their proceeds and pay their victims, and they may use fake or stolen identities to avoid detection. The other options are not likely because they do not explain why multiple deposits from the same employer under different employees' names would occur, nor why cash withdrawals would follow each deposit.
References: : Human Trafficking, : Human Trafficking Red Flags
質問 # 56
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. The suspicious accounts and transactions identified
- B. All relevant tables, spreadsheets, and other supporting documentation
- C. The investigator's concerns based on their subjective opinion
- D. Personal tax records pertinent to the owners to indicate tax evasion
正解：A
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 # 57
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