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ACAMS CAMS-FCI 問題集

試験コード：CAMS-FCI

試験名称：Advanced CAMS-Financial Crimes Investigations

最近更新時間：2024-04-28

問題と解答：全102問

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質問 1：
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.
While reviewing the account activity, it is noted that several transfers are sent to a company located in an offshore jurisdiction. Which step should the investigator take next?
A. Request information about the beneficiaries related to the company.
B. File a SAR/STR to the FIU where the company is located.
C. Conduct an open-source search to determine the ownership and registration of the company.
D. Request information from the company.
正解：A
解説: (Topexam メンバーにのみ表示されます)

質問 2：
A financial institution <FI> might use which option as intelligence to file a SAR/STR?
A. The Fl discovers a large number of securities transactions that appear to be related to day trading.
B. A customer makes several deposits in one month that appear to exceed their expected monthly income.
C. A customer receives a large, one-time wire from a law firm.
D. The Fl is unable to obtain evidence of required licensing or registration despite suspicion of money transmitting.
正解：D
解説: (Topexam メンバーにのみ表示されます)

質問 3：
Which action is part of the enhanced due diligence process?
A. Applying higher ownership percentage requirement for beneficial ownership collection
B. Verifying the source of wealth for entities and natural person clients
C. Using standard monitoring procedures to monitor transactions and account activity
D. Collecting beneficial ownership details regarding the client's account
正解：D
解説: (Topexam メンバーにのみ表示されます)

質問 4：
While each is potentially important, which allows an investigations analyst to better write a SAR/STR narrative that is useful to law enforcement? (Select Two.)
A. Including contact information for individuals at other institutions with whom correspondence has occurred
B. Ensuring all information in the SAR/STR is complete and accurate based on what the institution knows
C. Including a detailed description of the known or suspected criminal violation or suspicious activity
D. Including information about the general activity trends in the area where the suspicious transactions were conducted
E. Including an explanation of the internal process that brought the transaction to the attention of the analyst
正解：B,C
解説: (Topexam メンバーにのみ表示されます)

質問 5：
A KYC specialist from the first line of defense at a bank initiates an internal escalation based on a letter of credit received by the bank.
MEMO
To: Jane Doe. Compliance Manager, Bank B From: Jack Brown, KYC Specialist, Bank B RE: Concerning letter of credit A letter of credit (LC) was received from a correspondent bank. Bank A. in Country A. in Asia with strict capital controls, providing guarantee of payment to Bank B's client for the export of 10 luxury cars located in Country B. located in Europe. Bank A's customer is a general in the army where Bank A is headquartered.
The information contained in the LC is as follows:
* Advising amount per unit 30.000.00 EU *10 units of BMW
* Model IX3
* Year of registration: 2020
Upon checks on Bank B's client, the exporter mentioned that the transactions were particularly important, and a fast process would be much appreciated in order to avoid reputational damage to the firm and the banks involved in the trade finance process. The exporter has a longstanding relationship with Bank B and was clearly a good income generator. The exporter indicated that, as a general, the importer was trustworthy.
The relationship manager <RM) was contacted to conduct a full review of the exporter and to conduct a site visit.
Feedback from the RM:
The RM contacted the exporter for a client courtesy visit, but it was rearranged four times as the exporter kept cancelling the appointments. When the exporter was finally pinned down for an interview, employees were reluctant to provide clear answers about the basis of the transaction. The employees were evasive when asked about the wider business and trade activity in the country.
Findings from the investigation from various internal and external sources of information:
* There were no negative news or sanctions hits on the exporter company, directors, and shareholders.
* The registered address of the exporting business was a residential address.
* The price of the cats was checked and confirmed to be significantly below the market price of approximately
70,000 EU, based on manufacturer's new price guide.
* The key controllers behind the exporting company, that is the directors and During the investigation, the investigator determines that a nephew of the general.....
A. is a trustworthy source.
B. should be treated well to avoid reputational damage to the bank
C. should be flagged as a senior PEP.
D. is a high-net-worth individual
正解：C
解説: (Topexam メンバーにのみ表示されます)

質問 6：
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)

質問 7：
A financial institution (Fl) receives an urgent request for information from the financial intelligence unit (Fl country. According to FATF recommendations, which is the best action for the FI to take?
A. Establish a committee from different areas of the Fl to determine if the request should be answered.
B. ling the financing of terrorism that could imply an imminenl threat in the
C. Request an official court subpoena with details of the investigation.
D. Inform the public relations department to prepare for negative news.
E. Provide as much information as possible to the FIU immediately.
正解：E
解説: (Topexam メンバーにのみ表示されます)

質問 8：
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 dates" and "companionship." The Fl receives a keep open' letter from LE for the identified account and agrees to keep the account open.
What is the Fl required to do?
A. Contact the client for information relating to the account.
B. Notify LE immediately after new transactions.
C. Ensure that the request includes an end date.
D. Stop filing SAR/STR reports on the account and/or customer.
正解：C
解説: (Topexam メンバーにのみ表示されます)

質問 9：
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 is mostly dormant or has little activity
B. If there is negative media associated with counterparties
C. If the activity is materially different from related businesses
D. If the account has multiple transfers to the same, related businesses
正解：B
解説: (Topexam メンバーにのみ表示されます)

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ACAMS Advanced CAMS-Financial Crimes Investigations 認定 CAMS-FCI 試験問題:

1. 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) Signs of severe wear and poor maintenance at the site
B) Lights turned off at the site during operational hours
C) Visible attendance with children being dropped off by parents
D) A site located in a commercial building
E) Visible signage indicating the purpose of the building
F) A full parking lot of cars with no staff at the site

2. 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.
Which steps for documenting the final investigation decision are appropriate for the investigator in this scenario?

A) Document the investigation process and retain all relevant documents in the case management system.
B) Do not document the investigation process if a SAR/STR is not filed.
C) Add all of the information the Fl has about the subject, their account(s) activity, research results. KYC information, etc. to the SAR/STR.
D) Exclude any open-source information from record-keeping since it is publicly available.

3. 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

4. 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 are the best next steps for the investigator to take? (Select Three.)

A) Research other customer accounts for transactions to the same website.
E Conduct adverse media and open-source searches on the customer's background.
B) Identify if the customer has opened accounts in an urban city area.
C) Check internal KYC information.
D) Review the customer's transaction history.
E) Request information from the internet service provider who hosts the website.

5. 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.

質問と回答：

質問 # 1
正解： A、B、F

質問 # 2
正解： A

質問 # 3
正解： D

質問 # 4
正解： B、C、D

質問 # 5
正解： B

CAMS-FCI 関連試験: CAMS-CN - Certified Anti-Money Laundering Specialists (CAMS中文版); CAMS-KR - Certified Anti-Money Laundering Specialists (CAMS Korean Version); CAMS - Certified Anti-Money Laundering Specialists; CAMS-JP - Certified Anti-Money Laundering Specialists (CAMS日本語版); CAMS-Deutsch - Certified Anti-Money Laundering Specialists (CAMS Deutsch Version)

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