ACAMS CAMS-FCI 問題集

質問 1：
A financial institution (Fl) banks a money transmitter business (MTB) located in Miami. The MTB regularly initiates wire transfers with the ultimate beneficiary in Cuba and legally sells travel packages to Cuba. The wire transfers for money remittances comply with the country's economic sanctions policies. A Fl investigator on the sanctions team reviews each wire transfer to ensure compliance with sanctions and to monitor transfer details.
An airline located in Cuba, unrelated to the business, legally sells airline tickets in Cuba to Cuban citizens wanting to travel outside of Cuba. The airline tickets are purchased using Cuban currency (CUC).
The MTB wants 100,000 USD worth of CUC. Purchasing CUC from a Cuban bank includes a 4% fee. The MTB contacts the airline to ask if the airline will trade its CUC for USD at a lower exchange fee than the Cuban bank. The airline agrees to a 1% fee. The MTB initiates a wire transfer to the airline which appears as normal activity in the monitoring system because of the business' travel package sales.
Which investigative actions should the investigator take concerning the 100.000 USD wire transfer? (Select Three.)
A. Review the wire transfer protocols for this customer.
B. Review a sampling of wire transfers initiated by travel companies with Cuba travel packages.
C. Locate and review licenses, registrations, and account operating agreements associated with the MTB account.
D. Gather all account activity for Fl clients that purchased packages from the airline.
E. Recommend a plan for the Fl's management to restrict the account relationship.
F. Review regulations applicable to foreign currency trading transactions.
正解：A,C,F
解説: (Topexam メンバーにのみ表示されます)

質問 2：
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. Deposits made within days of major sporting events
B. Payments made for virtual currency
C. Payments made to multiple hotels in the same city
D. Multiple deposits between midnight and 4:00 AM
正解：D
解説: (Topexam メンバーにのみ表示されます)

質問 3：
Which is the first valid step in the Mutual Legal Assistance Treaties international cooperation process?
A. The central authority of the requesting country sends a letter of request to the central authority of the other country.
B. An investigator from the requesting country visits the country where the information is sought and takes statements from the identified witnesses or suspects.
C. The central authority that receives the request sends it to a local judicial officer to find out if the information is available.
D. The investigator may remove the evidence collected without asking permission to do so.
正解：A
解説: (Topexam メンバーにのみ表示されます)

質問 4：
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 5：
A client with many personal and business deposits with the financial institution (Fl) seeks a business loan. The client wants to guarantee the loan with a trust for which they are the beneficiary.
An investigator examines the trust. The trust has many layers, including shell companies in known tax havens.
The client's ultimate beneficial ownership claim cannot be validated, and the loan is denied.
Two months later, the Fl receives a law enforcement (LE) request on one of the client's business accounts.
While reviewing the business account, the Fl receives another LE request on the same account from another agency. The requested information is shared.
Three months later, a branch manager receives a request to open a business deposit account related to a complex trust. The manager forwarded the request because of the complexity. The trust was the same as the previously examined trust, but the request came from a different client. The second client also has many accounts with the Fl. Further inspection finds links between the second client and the Paradise Papers. The Papers state the client led illegal activities and committed tax evasion.
What steps should the investigator take to review the accounts held by the second client who is listed in the Paradise Papers? (Select Two.)
A. Inform Fl management of the start of a serious risk-based investigation that could result in losses and reputation risk.
B. Review all accounts being reviewed by AML investigators over the past year that have opened trust accounts.
C. Inform Fl management of deficiencies in their AML program because the second client's activities were not detected.
D. Monitor all accounts and entities related to the second client
E. Recommend a SAR/STR be filed regarding the second client's use of a questionable trust to open an account.
正解：D,E
解説: (Topexam メンバーにのみ表示されます)

質問 6：
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)

質問 7：

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. File a SAR/STR on the account activity in relation to a potential funnel account.
B. Recommend the account for exit due to frequent global transactions.
C. Complete the monthly review and note the activity for next month's review.
D. No further action is required as the customer is already rated at high-risk and the monthly spending is within expectations.
正解：A
解説: (Topexam メンバーにのみ表示されます)

質問 8：
Why is a more robust supervisory approach needed by regulators when overseeing small- and medium-sized money service businesses (MSBs) compared to larger MSBs for combatting terrorist financing (TF)?
A. Small- and medium-sized MSBs are more at risk of allowing transactions linked to TF due to the lack of skilled compliance resources.
B. Small- and medium-sized MSBs need to be targeted to ensure that competition in the industry remains constant and uniform.
C. Small- and medium-sized MSBs need to be robustly supervised so the regulator can maintain visibility in combatting TF.
D. Small- and medium-sized MSBs are more likely to falsify records to appear less risky in order to keep the banking relationship.
正解：A
解説: (Topexam メンバーにのみ表示されます)

質問 9：
How does the Financial Action Task Force (FATF) measure the effectiveness of a country's efforts to combat money laundering and terrorist financing?
A. FATF Evaluation Committee
B. Basel Committee
C. Mutual evaluation
D. Series of internal audits followed by reporting to FATF
正解：C
解説: (Topexam メンバーにのみ表示されます)