A new customer has just been onboarded in a securities firm. After a few weeks, there are unusual trading patterns that are being flagged. Which pattern is most concerning to the compliance officer?
A. The customer accumulates securities of a low volume counter in small increments on a weekly basis.
B. The customer's repeated trading in securities that are low priced and low volume counters.
C. The customer engages in large trading in securities that are liquid or highly priced from the trading account.
D. The customer receives many incoming wire transfers from related parties to the trading account.
正解:A
解説: (Pass4Test メンバーにのみ表示されます)
質問 2:
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. Series of internal audits followed by reporting to FATF
C. Basel Committee
D. Mutual evaluation
正解:D
解説: (Pass4Test メンバーにのみ表示されます)
質問 3:
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. Request information from the internet service provider who hosts the website.
B. Review the customer's transaction history.
C. Identify if the customer has opened accounts in an urban city area.
D. Research other customer accounts for transactions to the same website.
E Conduct adverse media and open-source searches on the customer's background.
E. Check internal KYC information.
正解:B,C,E
解説: (Pass4Test メンバーにのみ表示されます)
質問 4:
A national financial intelligence unit (FIU) is undertaking the country risk assessment for the financing of the proliferation of weapons of mass destruction (WMD). The evaluation involves determining the exposure that financial institutions (FIs) have to operations that evade sanctions. Which should be performed by the FIU to assess proliferation financing risk? (Select Two.)
A. Prepare new regulations that increase fines for FIs that allow financial operations on behalf of WMD proliferation sanctioned states.
B. Compare the international finance operations with national PEP lists to determine if the systems used by FIs are properly calibrated to detect WMD proliferation financing.
C. Evaluate a sample of the amount of false-positive and false-negative alerts that FIs have regarding proliferation sanctions evasion to determine root causes of non-detection.
D. Cross-reference the databases of international commerce/logistics transactions between the country and WMD proliferation sanctioned states with the corresponding international financial operations of those transactions.
E. Analyze the domestic financial operations that are above the reporting threshold and have similar names to high-level officials of WMD proliferation sanctioned states.
正解:C,D
解説: (Pass4Test 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 source of funds in the structure
B. The management structure of the trust
C. The general nature of business of the trust
D. The general purpose behind the structure
E. The responsibility and authority in the structure
正解:D,E
解説: (Pass4Test 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. Full transaction history of the correspondent bank's customer
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 last 6 months of transactional history
E. The contract pertaining to the purchase of property in another country
F. The account profile of the customer and their KYC data
正解:B,E,F
解説: (Pass4Test メンバーにのみ表示されます)
質問 7:
Which main vulnerability has led to an increase in the ransomware attacks perpetuated on small businesses?
A. Weaker cybersecurity controls
B. Tendency not to contact law enforcement
C. Inability to recover the encrypted information
D. Ability to pay larger ransoms
正解:A
解説: (Pass4Test 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.....
A. should be treated well to avoid reputational damage to the bank
B. is a high-net-worth individual
C. is a trustworthy source.
D. should be flagged as a senior PEP.
正解:D
解説: (Pass4Test メンバーにのみ表示されます)
質問 9:
The compliance learn is reviewing multiple data points to include in its data analytics program to detect shell or front company red flags. Which data points should the compliance team include? (Select Two.)
A. Entities transacting with or having relation to tax haven or high-risk countries
B. Entities whose principal place of business is a non-residential address
C. Entities exhibiting transactions with declared counterparties
D. Entities with a large number and variety of beneficiaries not declared at the time of onboarding
E. Entities with high paid-up capital relative to monthly value of transactions
正解:A,B
解説: (Pass4Test メンバーにのみ表示されます)
関え** -
素晴らしい問題集に出会いさせてもらったACAMSに感謝しかないです。CAMS-FCIにやっと再受験して合格だよ!!早速次に受験したいCAMSの問題集を購入させていただきました。今回もいい結果が出そう。