PDF無料ダウンロードにはCAMS有効な練習テスト問題
CAMSテストエンジンお試しセット、CAMS問題集PDF
質問 # 90
Bank A is a non-United States (U.S.) bank that has $5 million in a correspondent account at a bank in New York City. The Worldwide Terrorist Syndicate (WTS) has $1 million in its account at a non-US branch of Bank A.
The U.S. government has initiated forfeiture action against the WTS.
Which potential action can the U.S. take under the USA PATRIOT ACT pursuant to the issuance seizure warrant?
- A. Seize Bank A's $5 million correspondent account in the U.S.
- B. Seize $1 million from Bank A's correspondent account in the U.S.
- C. Seize WTS' $1 million account at the non-U.S. branch of Bank A.
- D. Seize $5 million from the non-U.S. branch of Bank A where the WTS' account is located.
正解：B
質問 # 91
Which three do the Office of Foreign Asset Control regulations cover? Choose 3 answers
- A. All foreign-based entities that have U.S. customers
- B. All U.S. citizens
- C. All persons and entities within the U.S.
- D. All U.S.-domiciled entities and their foreign branches
正解：B、C、D
解説：
Explanation
1. All U.S. persons
2. All persons and/or entities withing the U.S.
3. The U.S. entities and their foreign branches
質問 # 92
A financial institution (FI) is being investigated for possible money laundering. When cooperating with law enforcement agencies, which additional steps should the FI ensure are taken? (Choose two.)
- A. Make employees, including corporate officers, unavailable for interviews and refuse documents upon receipt of a subpoena.
- B. Address the document destruction policy to ensure the relevant documents are destroyed.
- C. Subpoenas and other information requests should be reviewed by senior management and an investigations group or counsel.
- D. Inquiries from the media are not answered directly, but rather are addressed by replying, "No comment."
- E. Centralized control is maintained over all requests and responses to ensure completeness and timely responses.
正解：C、E
解説：
When an FI is being investigated for possible money laundering, it is important that it cooperates with the law enforcement agencies (LEAs) in a professional and transparent manner. This means that the FI should take the following steps:
* Maintain centralized control over all requests and responses to ensure completeness and timely responses. This will help the FI to avoid duplication, inconsistency, or omission of information, as well as to track the status and progress of the requests and responses. It will also facilitate the communication and coordination between the FI and the LEAs, and demonstrate the FI's willingness to cooperate12.
* Review subpoenas and other information requests by senior management and an investigations group or counsel. This will help the FI to assess the scope, relevance, and legality of the requests, as well as to identify any potential risks, conflicts, or sensitivities. It will also enable the FI to prepare and provide the requested information in an accurate and timely manner, and to seek clarification or negotiation if necessary13.
The other options are not advisable, as they may indicate a lack of cooperation, obstruct the investigation, or damage the FI's reputation. For example:
* Making employees, including corporate officers, unavailable for interviews and refusing documents upon receipt of a subpoena may be considered as non-compliance, evasion, or contempt of court, and may result in legal sanctions or penalties4.
* Addressing the document destruction policy to ensure the relevant documents are destroyed may be seen as tampering with evidence, destroying records, or concealing information, and may constitute a criminal offence or a breach of regulatory obligations5.
* Not answering inquiries from the media directly, but rather replying, "No comment" may create a negative impression, fuel speculation, or invite criticism, and may harm the FI's image, credibility, or trustworthiness.
References:
* Cooperation between FIUs, Law Enforcement Authorities, and Prosecutors
* AML and Financial crimes investigation
* Mechanisms for interaction of law enforcement agencies in the field of counteracting and combating money laundering
* Recommendation 30: Responsibilities of law enforcement and investigative authorities
* Money laundering and illicit finance
質問 # 93
A popular restaurant in town has begun depositing less cash than it has in prior years. In a review of the customer's accounts, you notice that credit card receipts have increased with no explanation.
The account officer discovers that the restaurant has installed a privately-owned automated teller machine (ATM) onsite and has begun construction on a patio dining area.
Which red flag should trigger additional investigation?
- A. Construction of the new patio dining area
- B. Lower cash deposits
- C. Increased credit card receipts
- D. Privately-owned ATM
正解：C
質問 # 94
The bank's Compliance Officer is tasked with designing standards based on Basel's KYC principles. Which essential elements should be included in the program? (Choose two.)
- A. Establishing on-going monitoring of high-risk accounts
- B. Documenting a customer acceptance policy
- C. Conducting a money laundering risk assessment
- D. Reporting suspicious activity
- E. Appointing an independent audit function
正解：A、B
解説：
According to the Basel Committee on Banking Supervision, banks should adopt a risk-based approach to customer due diligence, which includes four essential elements1:
A customer acceptance policy that defines the types of customers that are likely to pose a higher than average risk to the bank.
A customer identification program that collects and verifies information about the customer's identity, beneficial ownership, and purpose of the account or relationship.
An on-going monitoring of high-risk accounts to detect and report any unusual or suspicious activity, and to keep customer information up-to-date.
A risk management program that ensures that the bank's policies and procedures are implemented effectively, and that the bank's staff are trained and aware of their AML/CFT obligations.
Therefore, documenting a customer acceptance policy and establishing on-going monitoring of high-risk accounts are the correct choices for the essential elements that should be included in the program based on Basel's KYC principles.
References: 1: Basel Committee on Banking Supervision, Customer due diligence for banks, October 2001, page 8.
質問 # 95
In reviewing recent activity, a compliance officer for a money transmitter that several customers are each remitting the same amount of money but much more frequently.
How should the institution respond?
- A. Conduct further investigation to determine whether this is truly suspicious activity
- B. File a suspicious transaction report
- C. Instruct the tellers not to process remittances for these customers in the future
- D. Immediately contact the customers and ask them why they are remitting money more often
正解：A
解説：
Explanation/Reference:
質問 # 96
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. Asset freeze
- C. Financial prohibitions
- D. Export and import restrictions
正解：B
質問 # 97
Which unusual or suspicious activity by a financial institution's (FI's) employee requires additional investigation and scrutiny?
- A. The employee avoids taking periodic vacations despite having accrued vacation time.
- B. The employee assists with transactions of a disclosed ultimate beneficiary.
- C. The employee is involved in a minimal number of unresolved exceptions.
- D. The employee lives a lavish lifestyle within their means.
正解：A
解説：
an employee who avoids taking periodic vacations despite having accrued vacation time may be trying to conceal fraudulent or illegal activities that would be exposed in their absence. This is a common red flag for internal fraud and money laundering, as it indicates a lack of segregation of duties, internal controls, and oversight. Employees who engage in such behavior may also exhibit other signs of stress, defensiveness, or secrecy.
References:
* Learn about red flags for internal fraud, section "An employee may be a higher internal fraud risk when a combination of the following red flags are present", bullet point 1: "Unwilling to share duties or take leave."
* Money Laundering Red Flags | Key Behaviours and Indicators, section "Employee Red Flags", bullet
* point 1: "Avoiding taking holidays or time off work."
* Top 10 AML Red Flags: Warning Signs and Financial Risks, section "AML Red Flags Categories", sub-section "Employee Red Flags", bullet point 1: "Avoiding taking vacations or sick leaves."
質問 # 98
An anti-money laundering specialist has been asked to create internal anti-money laundering policies, procedures and controls for a recently chartered offshore financial institution.
Which three should be included? Choose 3 answers
- A. Basel Committee on Banking Supervision's capital adequacy requirements for the host country
- B. An anti-money laundering compliance program, internal audit program, and procedure manual
- C. Compliance requirement of host and charting countries
- D. A training program for senior management and staff
正解：B、C、D
質問 # 99
Law enforcement is confidentially investigating 20 individuals suspected of belonging to a criminal network allegedly involved in laundering tens of millions of euros for cybercriminals. Which actions need to be taken by the AML Specialist at a bank upon learning the alert? (Select Two.)
- A. Respond to law enforcement that their request without a judicial order would breach the bank's General Data Protection Regulation duty with respect to its clients.
- B. N Send out an email to all of the bank's client advisors to request information on any of the individuals.
- C. Perform a search on the bank's client data platform to determine if the bank has had any business with the named individuals.
- D. Report findings back to law enforcement only if they are of any significance.
- E. Involve the bank's legal and compliance function to address the gravity of the matter.
正解：C、E
解説：
According to the ACAMS CAMS Study Guide, 6th Edition, Chapter 4, Section 4.2, the AML Specialist at a bank should take the following actions upon receiving a confidential alert from law enforcement about suspected money launderers:
Involve the bank's legal and compliance function to address the gravity of the matter and ensure that the bank's response is appropriate and lawful. The legal and compliance function can also advise on the bank's obligations and rights under the relevant laws and regulations, such as the General Data Protection Regulation (GDPR), the Bank Secrecy Act (BSA), and the USA PATRIOT Act.
Perform a search on the bank's client data platform to determine if the bank has had any business with the named individuals or any related parties. The search should include current and past accounts, transactions, wire transfers, and other relevant records. The AML Specialist should also review any existing customer due diligence (CDD) and enhanced due diligence (EDD) information on the potential suspects and update them as necessary.
The other options are not recommended or required actions for the AML Specialist at a bank in this scenario:
Sending out an email to all of the bank's client advisors to request information on any of the individuals could compromise the confidentiality of the alert and expose the bank to legal and reputational risks. It could also alert the suspects or their associates and hinder the law enforcement investigation.
Reporting findings back to law enforcement only if they are of any significance is not sufficient or compliant with the bank's obligations to cooperate with law enforcement and report any suspicious activity. The AML Specialist should report any relevant information or findings to law enforcement as soon as possible, regardless of their significance, and follow the established procedures and protocols for information sharing and reporting.
Responding to law enforcement that their request without a judicial order would breach the bank's GDPR duty with respect to its clients is not accurate or helpful. The GDPR does not prohibit the bank from sharing personal data with law enforcement for the purposes of preventing, detecting, or investigating money laundering or other criminal activities, as long as the bank has a legal basis and safeguards for doing so. The bank should consult with its legal and compliance function to determine the best way to respond to the law enforcement request and balance its GDPR obligations with its anti-money laundering (AML) duties.
References:
ACAMS CAMS Study Guide, 6th Edition, Chapter 4, Section 4.2
General Data Protection Regulation (GDPR)
Bank Secrecy Act (BSA)
USA PATRIOT Act
質問 # 100
An anti-money laundering specialist is concerned that several suspicious transaction reports will discuss potential illegal activity of bank employees. In this situation, which of the following is the immediate concern for the institution?
- A. Prohibiting distribution of suspicious transaction report copies to the Board.
- B. Ensuring no delay in informing the Board.
- C. The type of form to be used when reporting to the Board.
- D. The timing of the presentation of suspicious transaction reports to the competent authority.
正解：B
解説：
According to the BSA/AML Manual1, a financial institution's board of directors and senior management are ultimately responsible for ensuring that the institution has a comprehensive and effective BSA/AML compliance program and oversight framework. This includes ensuring that the institution timely identifies, reports, and responds to suspicious activity involving its products, services, customers, or employees.
Therefore, when an anti-money laundering specialist is concerned that several suspicious transaction reports will discuss potential illegal activity of bank employees, the immediate concern for the institution is to ensure no delay in informing the board of directors and senior management of the situation, as well as the actions taken or planned to address the risks and mitigate the potential harm. The board and senior management should be kept informed of the status and outcome of any internal or external investigations, as well as any regulatory or law enforcement inquiries or actions, related to the suspicious activity involving bank employees.
References:
BSA/AML Manual1
Suspicious Activity Reporting - Overview2
Suspicious Activity Report (SAR) Basics3
What's Suspicious? Here's How Banks Apply the Smell Test4
質問 # 101
What are two requirements of United States financial institutions when conducting business with an international institution as a result of the USA PATRIOT Act? (Choose two.)
- A. Complying with Special Measures issued under the USA PATRIOT Act
- B. Performing enhanced due diligence on shell banks
- C. Visiting the head office of the international financial institution
- D. Performing due diligence on correspondent accounts
正解：B、D
解説：
The USA PATRIOT Act imposes several requirements on U.S. financial institutions when dealing with foreign financial institutions, especially those that pose a high risk of money laundering or terrorist financing.
Two of these requirements are:
* Performing enhanced due diligence on shell banks: A shell bank is a bank that has no physical presence in any country and is not affiliated with a regulated financial group. The USA PATRIOT Act prohibits
U.S. financial institutions from opening or maintaining correspondent accounts for shell banks, and requires them to take reasonable steps to ensure that their correspondent accounts are not being used by shell banks indirectly12.
* Performing due diligence on correspondent accounts: A correspondent account is an account established by a financial institution to receive deposits from, make payments on behalf of, or handle other financial transactions for a foreign financial institution. The USA PATRIOT Act requires U.S. financial institutions to collect and verify certain information about the foreign financial institution, such as its ownership, licensing, and anti-money laundering policies, and to assess the risk of money laundering or terrorist financing associated with the correspondent account13.
References:
* CAMS Certification Package - 6th Edition | ACAMS, Chapter 3: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), pages 82-84
* CAMS Certifications: How to Get CAMS Certified | ACAMS, Candidate Handbook, page 14
* ACAMS CAMS Certification Video Training Course - Exam-Labs, Video 3.4: Correspondent Banking and Money Laundering Risks
質問 # 102
According to the Financial Action Task Force 40 Recommendations, Designated Non-Financial Businesses and Professionals include which entities?
- A. Commodities traders
- B. Real estate agents
- C. Money services businesses
- D. Hawala operators
正解：B
解説：
Reference:http://www.fatfgafi.org/media/fatf/documents/recommendations/pdfs/FATF%20Recommendations%20(approved %20February%202012)%20reprint%20May%202012%20web%20version.pdf(page 19, DNFBPs: customer due diligence, bulleted point (b))
質問 # 103
In many jurisdictions, financial institutions are prohibited from hiring a person who has been convicted of what type of offense?
- A. Kidnapping
- B. Protests of government action
- C. Offenses involving dishonesty
- D. Driving while under the influence
正解：C
解説：
Explanation
Explanation/Reference:
質問 # 104
Which key aspect of the Office of Foreign Assets Control's extraterritorial reach specifically relates to prohibited transactions?
- A. Prohibit or reject licensed trade and financial transactions with specified countries, entities and U.S.
individuals - B. Prohibit or reject unlicensed trade and financial transactions with specified countries, entities, and individuals
- C. Prohibit or reject licensed trade and financial transactions with specified countries, entities and non-U.S.
individuals - D. Prohibit or reject unlicensed foreign trade and financial transactions with specified countries, entities, and individuals.
正解：B
解説：
the Office of Foreign Assets Control (OFAC) has the authority to prohibit or reject any trade or financial transactions involving specified countries, entities, and individuals that are subject to U.S. economic sanctions, unless such transactions are authorized by a general or specific license issued by OFAC. This applies to transactions that occur within the U.S. territory, as well as transactions that involve U.S. persons, U.S. goods, or the U.S. financial system, regardless of where they take place. This is one of the key aspects of OFAC's extraterritorial reach, which means that OFAC can enforce its sanctions programs beyond the U.S. borders.
References:
* Home | Office of Foreign Assets Control, section "Mission": "The Office of Foreign Assets Control ("OFAC") of the US Department of the Treasury administers and enforces economic and trade sanctions based on US foreign policy and national security goals against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the United States."
* The Aggressive Extraterritorial Reach of U.S. Economic Sanctions: Foreign Company Exposure to OFAC Enforcement, section "A. Bases for OFAC jurisdiction over foreign parties", paragraph 1: "One key aspect of the Office of Foreign Assets Control's extraterritorial reach includes the blocking of certain non-United States initiated transactions for or through the United States (U.S.) for benefit of a restricted person or entity."
* The global reach of OFAC sanctions, section "The global reach of OFAC sanctions", paragraph 1:
"OFAC sanctions are trade and economic sanctions administered by The U.S. Treasury Department's Office of Foreign Asset Control (OFAC). They are often intended to have extra-territorial effect, meaning that they apply outside the U.S. territory. In some instances a connection with the U.S. territory is required."
"Prohibit or reject unlicensed trade and financial transactions with specified countries, entities, and individuals. "
質問 # 105
During a law enforcement investigative interview regarding potential money laundering, the suspect starts making assertions and statements that the investigator believes are false.
How should the investigator respond?
- A. Advise the suspect that the interview will be terminated if there is suspicion of deception
- B. Inform the suspect that deception is obvious and continue the interview
- C. Direct the interview in another direction until there is better rapport before returning back to the troubling question
- D. Ask question of a material nature about the suspected false statements without revealing the suspected deception
正解：D
質問 # 106
Which is the main objective when a financial institution (FI) conducts an investigation?
- A. Know the customer
- B. Track the movement of the money
- C. Keep all the documentation
- D. Keep policies and procedures updated
正解：D
質問 # 107
......
あなたを合格させるCAMS Certification CAMS試験問題集で2025年04月08日には645問あります：https://jp.fast2test.com/CAMS-premium-file.html
最新のACAMS CAMSPDFと問題集で（2025）無料試験問題解答：https://drive.google.com/open?id=1M3Z2mdSueIepFFvpVptnUQUWenOKqCBn