ACAMS CAMS-FCI 問題集

質問 1：
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 of 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.
Which information should the investigator review first when examining the wire transaction documentation?
A. Whether the wire transfers were initiated domestically
B. The Travel Rule requirements for recordkeeping
C. How the wire transfers were initiated (e.g., phone, online, branch visit)
D. The sanctions screening tool to see if the transaction was stopped
正解：C
解説: (Topexam メンバーにのみ表示されます)

質問 2：
In the past 6 months, a small financial institution (Fl) has received regular remittances that are increasing in value from a country with high piracy activity. The Fl's AML officer (AMLO) has also noted that piracy in this country has increased in the same time frame. Which recommendation should the AMLO make?
A. Conduct an in-depth investigation into accumulated remittance information in the past year to find the trend of such transactions.
B. File a SAR/STR to the appropriate AML authority immediately.
C. Upgrade the transaction monitoring system of the Fl to include more fields so that more in-depth information is collected about the inward remittances.
D. Request the operations department to return inbound remittances when the sender of funds is from this country.
正解：A
解説: (Topexam メンバーにのみ表示されます)

質問 3：
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. Enough circumstantial evidence about the suspicious activity for a criminal proceeding
B. Definitive proof that suspicious activity occurred
C. Low evidentiary threshold about the suspicious activity
D. No factual description of the suspicious activity
正解：C
解説: (Topexam メンバーにのみ表示されます)

質問 4：
An AML investigator at a bank identifies an unusually high number of deposits from a few customers resulting from the encashment of multiple gambling tickets from a legitimate gambling company. It is noted that the transactions are inconsistent with the customers' profiles and that reverse (corrective) transactions did not occur. Which suspicious activity is most likely?
A. The customers deposited fake winning tickets.
B. The winning tickets are traded to criminals who. in turn, use the customers' accounts.
C. The customers are attempting to evade income tax.
D. The gambling company created fictitious transactions in an attempt to misrepresent the size of its business activity.
正解：B
解説: (Topexam メンバーにのみ表示されます)

質問 5：
An investigator at a corporate bank is conducting transaction monitoring alerts clearance.
KYC profile background: An entity customer, doing business offshore in Hong Kong, established a banking business relationship with the bank in 2017 for deposit and loan purposes. It acts as an offshore investment holding company. The customer declared that the ongoing source of funds to this account comes from group-related companies.
* X is the UBO. and owns 97% shares of this entity customer;
* Y is the authorized signatory of this entity customer. This entity customer was previously the subject of a SAR/STR.
KYC PROFILE
Customer Name: AAA International Company. Ltd
Customer ID: 123456
Account Opened: June 2017
Last KYC review date: 15 Nov 2020
Country and Year of Incorporation: The British Virgin Islands, May 2017 AML risk level: High Account opening and purpose: Deposits, Loans and Trade Finance Anticipated account activities: 1 to 5 transactions per year and around 1 million per transaction amount During the investigation, the investigator reviewed remittance transactions activities for the period from Jul
2019 to Sep 2021 and noted the following transactions pattern:
TRANSACTION JOURNAL
Review dates: from July 2019 to Sept 2021
For Hong Kong Dollars (HKD) currency:
Incoming transactions: 2 inward remittances of around 1.88 million HKD in total from different third parties Outgoing transactions: 24 outward remittances of around 9 4 million HKD in total to different third parties For United States Dollars (USD) currency:
Incoming transactions: 13 inward remittances of around 3.3 million USD in total from different third parties Outgoing transactions: 10 outward remittances of around 9.4 million USD in total to different third parties.
RFI Information and Supporting documents:
According to the RFI reply received on 26 May 2021, the customer provided the bank with the information below:
1) All incoming funds received in HKD & USD currencies were monies lent from non-customers of the bank.
Copies of loan agreements had been provided as supporting documents. All of the loan agreements were in the same format and all the lenders are engaged in trading business.
2) Some loan agreements were signed among four parties, including among lenders. borrower (the bank's customer), guarantor, and guardian with supplemental agreements, which stated that the customer, as a borrower, who failed to repay the loan Based on the KYC profile and the transaction journal, the pattern of activity shows a deviation in:
A. expected vs. actual activity.
B. customer risk rating
C. product risk rating.
D. U.S. currency incoming vs. outgoing transaction rales.
正解：A
解説: (Topexam メンバーにのみ表示されます)

質問 6：
A client that runs a non-profit organization that aids refugees in leaving their home countries received a remittance from a money services business that was ten times the average. The client was recently detained for providing falsified passports to illegal immigrants. Which predicate offenses could be considered in the SAR/STR? (Select Two.)
A. Tax evasion
B. Antiques smuggling
C. Narcotics trafficking
D. Human smuggling/trafficking
E. Terrorist financing
正解：D,E
解説: (Topexam メンバーにのみ表示されます)

質問 7：
The compliance learn is reviewing multiple data points to include in its data analytics program to detect shell or front company red flags. Which data points should the compliance team include? (Select Two.)
A. Entities exhibiting transactions with declared counterparties
B. Entities with high paid-up capital relative to monthly value of transactions
C. Entities whose principal place of business is a non-residential address
D. Entities with a large number and variety of beneficiaries not declared at the time of onboarding
E. Entities transacting with or having relation to tax haven or high-risk countries
正解：C,E
解説: (Topexam メンバーにのみ表示されます)

質問 8：
Due to an ever-diversifying business model and multi-jurisdictional footprint, a casino has decided to outsource the source of funds and wealth checks to a third-party provider. Why is it important for the casino to maintain control of the output from the provider?
A. Clients of the casino prefer to know that the casino is keeping their information secure when being held by a third-party.
B. The casino maintains ultimate responsibility for this activity and should maintain control to avoid non-compliance.
C. Other casinos are frequently looking to reduce costs and share ideas, so if this relationship is successful, the model can be used by other businesses.
D. As with all third-party relationships, proper control must be maintained to ensure profitability.
正解：B
解説: (Topexam メンバーにのみ表示されます)

質問 9：
Which information is it best practice to share at the very beginning of a well-written SAR/STR narrative?
A. Any and all relevant facts about the parties who facilitated the suspicious activity or transactions
B. The purpose of the SAR/STR narrative and a general description of the known or alleged violation
C. A specific description of the involved accounts and transactions, including the origination and application of funds
D. Information about any follow-up actions conducted by the financial institution on the account
正解：B
解説: (Topexam メンバーにのみ表示されます)