ACAMS CAMS-FCI 問題集

質問 1：
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 2：
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)

質問 3：
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)

質問 4：
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)

質問 5：
According to the Financial Action Task Force, as part of their risk assessment, which are important data and information that a Trust and Company Service Provider must understand when establishing and administering a trust? (Select Two.)
A. The general nature of business of the trust
B. The responsibility and authority in the structure
C. The source of funds in the structure
D. The general purpose behind the structure
E. The management structure of the trust
正解：B,D
解説: (Topexam メンバーにのみ表示されます)

質問 6：
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 7：
In a SAR/STR narrative concerning Individual A. which statement indicates a product of analysis rather than a fact or judgement?
A. Individual A was the originator of nine wires totaling 225.000 USD between January and March 2020.
B. Individual A made structured cash deposits on almost consecutive days.
C. Individual A made structured cash deposits possibly to circumvent regulatory reporting requirements
D. Individual A is a college student and employed part-time at a car wash.
正解：C
解説: (Topexam メンバーにのみ表示されます)

質問 8：
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 (Bank A's customer) is a customer at Bank B.
Which step should the investigator take next?
A. Determine whether there is a business relationship between the nephew and the general.
B. File a SAR/STR in relation to corruption involving the nephew and the general.
C. Seek senior management approval to continue the relationship with the nephew.
D. Flag the nephew as a PEP by association.
正解：D
解説: (Topexam メンバーにのみ表示されます)

質問 9：
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)