ACAMS CAMS-FCI 問題集

質問 1：
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 2：
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 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 a real estate business which again poses a higher risk.
The monitoring system of the correspondent institution flags the transaction as suspicious activity. The correspondent bank needs to send a request for information to the respondent bank. Which elements should be included in the request? (Select Three.)
A. The account profile of the customer and their KYC data
B. Details of DEF Oil Resource Ltd parent company and the name(s) of the beneficial owner(s)
C. The respondent bank's customer's senior management bonus plan
D. The contract pertaining to the purchase of property in another country
E. The last 6 months of transactional history
F. Full transaction history of the correspondent bank's customer
正解：A,B,D
解説: (Topexam メンバーにのみ表示されます)

質問 3：
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 4：
A country that does not have strong predicate offenses and is lax in prosecuting AML cases could suffer which social/economic consequence?
A. Reputation risk for the port
B. US sanctions
C. Loss of tax revenue
D. Increased organized crime and corruption
正解：D
解説: (Topexam メンバーにのみ表示されます)

質問 5：
Which pattern of activity most strongly indicates an individual is a foreign terrorist fighter?
A. A series of small cash deposits made in rapid succession totaling just over 10,000 USD followed by a purchase at a jewelry store
B. A large purchase at a gas station immediately followed by several smaller purchases at an electronics store
C. A large cash advance on a credit card and purchases at travel and sporting goods websites
D. A series of small deposits followed by a large international wire to a well-known international charity
正解：C
解説: (Topexam メンバーにのみ表示されます)

質問 6：
An EU bank account received 1.8 million EUR from a Swiss bank. The EU bank determines the originator was indicted by U.S. law enforcement, arrested in Switzerland, and extradited for alleged insider trading.
Which is the best reason the EU bank should file a SAR/STR?
A. Insider trading is a predicate offense in the U.S. and Switzerland.
B. The Swiss bank filed a SAR/STR with the Money Laundering Reporting Office Switzerland.
C. The originator was indicted by U.S. law enforcement.
D. The events raise concerns that the payment represents proceeds from insider trading.
正解：D
解説: (Topexam メンバーにのみ表示されます)

質問 7：
A financial regulator is evaluating the effectiveness of a financial institution's (Fl) anti-financial crime program. Which condition should be met to satisfy the regulator?
A. The program is aligned with the financial industry's anti-financial crime priorities.
B. The program is drafted using a risk-based approach to avoid the Fl being used as a conduit for criminal activities.
C. In the past 3 years, internal auditing results show no high-severity issues and a maximum of three medium-seventy and four low-severity issues.
D. The program meets the minimum requirements of anti-financial crime standards, which are published by a financial industry association.
正解：B
解説: (Topexam メンバーにのみ表示されます)

質問 8：
Sanctions screening requirements include that a financial institution should:
A. compare customer and transaction records against periodically updated sanctions lists provided by governmental bodies.
B. immediately freeze the bank account of an individual that appears on a sanctions list.
C. report an individual whose name appears on a sanctions list to the police.
D. immediately close the bank account of an entity who appears on a sanctions list.
正解：A
解説: (Topexam メンバーにのみ表示されます)