ACAMS CAMS-FCI 問題集

質問 1：
Law enforcement agents arrive at a broker-dealer's premises with a search warrant. In addition to cooperation with the warrant, which instructions should the person in charge of the broker-dealer provide to their employees?
A. Volunteer information not requested by the agents that the employees think may be useful.
B. Take notes on the questions and comments made by the agents.
C. Provide agents with unlimited access to customers' personal data.
D. Sign consent forms permitting the agents to search employees' offices.
正解：B
解説: (Topexam メンバーにのみ表示されます)

質問 2：
An investigator is reviewing a case generated from the transaction monitoring system, with two large amounts of incoming remittance (IR) to an individual customer. Based on the KYC profile, the customer is a plant manager of a famous multi-national electronics manufacturing firm. As the customer has no similarly large transaction patterns for the past 2 years, the investigator sends an inquiry to the relationship manager (RM) about the nature of the transaction. The RM replies that the transaction is a consultancy fee provided from two different electronics companies with a debit note provided However, there is no detail of service provided on the debit note, and the remitters are two individuals.
Which actions should the investigator recommend to mitigate risk? (Select Two.)
A. Conduct enhanced due diligence.
B. Document and maintain a file with the investigative findings.
C. Re-evaluate the customer risk profile.
D. Exit the relationship with the customer.
E. Discuss the investigation findings with the customer.
正解：A,C
解説: (Topexam メンバーにのみ表示されます)

質問 3：
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 perform in reference to the first client's existing accounts? (Select Three.)
A. Perform secondary scans of the client's other owners/authorized signers
B. File SARs/STRs for all accounts at the beginning of the discovery phase and amend later as necessary.
C. Prepare a relationship flow chart of all existing accounts to better understand the client's activities.
D. Review all client-signed documents relating to all accounts.
E. Review Fl approved policies regarding the existing accounts to ensure regulatory requirements were followed.
F. Inform Fl management of all processes used to investigate the client due to LE inquiry.
正解：A,C,D
解説: (Topexam メンバーにのみ表示されます)

質問 4：
In which case should an investigator avoid escalating a suspicious event to the chief compliance officer and pursue other channels?
A. The transaction chain is likely connected to a known member of a terrorist organization.
B. An individual involved in a large sum transaction is a foreign PEP.
C. A trade entity engages in complex trade deals involving numerous third-party intermediaries in incongruent lines of business.
D. A close family member of the chief compliance officer is the beneficiary of a cross-border transfer.
正解：D
解説: (Topexam メンバーにのみ表示されます)

質問 5：
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 6：
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 7：
Each month the automated transaction monitoring system generates alerts based on predetermined scenarios.
An alert was generated in relation to the account activity of ABC Foundation. Below is the transaction history for ABC Foundation (dates are in DD/MM/YYYY format).

The relationship manager for ABC Foundation contacts the client to request more information on the beneficiary of the transfer in Turkey. ABC Foundation advises that this is a not-for-profit charity group called
'Forever Free." Which is the best next step in the investigation?
A. Check the junsdiction's list of known chanties with connections to terrorist activity.
B. Update the customer profile to include Forever Free as the recipient of the funds.
C. Contact the financial institution in Turkey that has a relationship with Forever Free and advise them of the investigation.
D. File a SAR/STR with the new information learned about the beneficiary.
正解：A
解説: (Topexam メンバーにのみ表示されます)

質問 8：
When writing or reviewing a SAR/STR, it is important to:
A. avoid mentioning suspect names in case it is seen by someone involved in criminal activity, effectively tipping them off.
B. ensure the narrative is kept to the point; easy to read; and addresses the who, what, when, where, why, and how.
C. ensure that the narrative is detailed with all available information so that law enforcement can decide what is relevant.
D. keep the introduction brief but ensure all relevant transactions, account numbers, and suspect names are listed in the conclusion summary.
正解：B
解説: (Topexam メンバーにのみ表示されます)

質問 9：
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.
Which red flags would be an indicator that activity is connected to a corruption/bribery typology? (Select Two.)
A. The same beneficial owner owning several daycare centers in different locations
B. Large checks issued to various individuals with the memos noting "gift", "thank you", "favor"
C. Negative news found on the customer related to government-issued violations for safety
D. Checks issued to an unrelated entity referencing "rent" and "utilities" in the memos
E. Multiple daycare locations with no active business operations or related account activity
正解：B,C
解説: (Topexam メンバーにのみ表示されます)