ACAMS CAMS-FCI 問題集

質問 1：
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 2：
An unusual spike in activity has occurred for a customer who is a supplier of aviation parts to a military force.
The customer's current line of business is consistent with the banks records, and no adverse media hits have occurred. Which is the best reason for an investigator to continue an investigation?
A. The customer is a supplier of aviation parts.
B. The current line of business is consistent with the bank's records.
C. The end-user is a military force.
D. There are no adverse media hits.
正解：C
解説: (Topexam メンバーにのみ表示されます)

質問 3：
A SAR/STR regarding money-mule activity prompts law enforcement action. Under U.S. law, the alleged money mules can be prosecuted:
A. only if they were aware of their role and actively participated.
B. even if they were unaware that money was transferred.
C. unless they can prove they were not aware of the origin of the funds.
D. in a country only if funds were transferred between accounts maintained in the same country.
正解：B
解説: (Topexam メンバーにのみ表示されます)

質問 4：
A compliance officer of a financial institution is reviewing a payment for sanctions compliance between two parties in Europe and Asia. The payment is in Euros and involves the provision of services to a company located in a jurisdiction subject to Office of Foreign Assets Control secondary sanctions. Which factor is most important in determining the compliance officer's response?
A. Asset freezes only prohibit US companies from engaging in certain activities with counterparts from a sanctioned jurisdiction.
B. A one-off commercial transaction conducted between parties in Europe and Asia is not subject to secondary sanctions.
C. Secondary sanctions only target specific sectors of the economy such as the banking and finance sectors.
D. The threat of US sanctions against foreign individuals and entities continues to exist despite the absence of a US nexus.
正解：D
解説: (Topexam メンバーにのみ表示されます)

質問 5：
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. 600,000,000 USD
B. 659,000,000 USD
C. 59,000,000 USD
D. 541.000,000 USD
正解：B
解説: (Topexam メンバーにのみ表示されます)

質問 6：
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 7：
A government entity established a trust to provide social welfare programs. The entity wants cash payments made to persons without supporting documentation. These persons would oversee the allocation of funds to beneficiaries without complying with internal disbursement of government funds controls. Which is the main premise for filing a SAR/STR?
A. Social welfare programs are difficult to document because the beneficiaries are from the informal sector.
B. Cash disbursements are not allowed for social welfare programs.
C. Trust service providers are not obliged by law to follow government internal controls.
D. The entity is not implementing adequate internal controls according to what is expected, and mishandling of funds could be occurring.
正解：D
解説: (Topexam メンバーにのみ表示されます)

質問 8：
Potentially suspicious activity following an increase in the volume of transactions by an import company included outgoing wires to Indonesia and Uganda referencing invoice numbers. Incoming funds included large cash deposits and checks/wires from pet stores, breeders, and private individuals. What financial crime might the bank reference in the SAR/STR?
A. Illegal wildlife trade
B. International drug trafficking
C. Tax evasion scheme
D. Black market peso exchange
正解：A
解説: (Topexam メンバーにのみ表示されます)

質問 9：
Which are primary purposes of Financial Action Task Force {FATF)-Style Regional Bodies? (Select Two.)
A. Promoting effective implementation of FATF recommendations
B. Acting as a prudential regulatory body for financial institutions
C. Imposing special measures for non-cooperative jurisdictions
D. Providing due diligence for foreign correspondent banks
E. Providing expertise and input in FATF policy-making
正解：A,E
解説: (Topexam メンバーにのみ表示されます)