CAMS-CN Exam Question 56
評估客戶風險評級時考慮哪些風險因素?(選三。)
Correct Answer: A,B,C
When assessing the risk rating of customers, financial institutions should consider various factors that may indicate the potential for money laundering, terrorist financing, or other illicit activities. According to the ACAMS Study Guide for the CAMS Certification Examination1, some of the key risk factors are:
Customer risk: This refers to the characteristics of the customer that may affect their risk profile, such as their identity, occupation, source of funds, business activities, reputation, and political exposure. For example, customers who are politically exposed persons (PEPs), cash-intensive businesses, non-resident customers, or customers with complex ownership structures may pose a higher risk of money laundering or terrorist financing.
Geographic risk: This refers to the location of the customer, their business, or their transactions, and the level of risk associated with that location. For example, customers who are based in, operate in, or transact with jurisdictions that have weak anti-money laundering (AML) regulations, high levels of corruption, or are subject to sanctions or embargoes may pose a higher risk of money laundering or terrorist financing.
Product risk: This refers to the type of products or services that the customer uses or offers, and the level of risk associated with those products or services. For example, customers who use or offer products or services that are anonymous, complex, or facilitate cross-border transactions may pose a higher risk of money laundering or terrorist financing.
Other risk factors that may be considered include transaction risk, delivery channel risk, and industry risk2.
However, these are not among the options given in the question.
References: = Some of the references that support this answer are:
ACAMS Study Guide for the CAMS Certification Examination, Chapter 4, Section 4.1, pages 97-99:
"Customer Risk Factors", "Geographic Risk Factors", "Product Risk Factors".
Customer Risk Rating: Connecting Customer Risk Rating With Due Diligence, Section "Customer Risk Rating Factors": "Transaction Risk Factors", "Delivery Channel Risk Factors", "Industry Risk Factors".
Customer risk: This refers to the characteristics of the customer that may affect their risk profile, such as their identity, occupation, source of funds, business activities, reputation, and political exposure. For example, customers who are politically exposed persons (PEPs), cash-intensive businesses, non-resident customers, or customers with complex ownership structures may pose a higher risk of money laundering or terrorist financing.
Geographic risk: This refers to the location of the customer, their business, or their transactions, and the level of risk associated with that location. For example, customers who are based in, operate in, or transact with jurisdictions that have weak anti-money laundering (AML) regulations, high levels of corruption, or are subject to sanctions or embargoes may pose a higher risk of money laundering or terrorist financing.
Product risk: This refers to the type of products or services that the customer uses or offers, and the level of risk associated with those products or services. For example, customers who use or offer products or services that are anonymous, complex, or facilitate cross-border transactions may pose a higher risk of money laundering or terrorist financing.
Other risk factors that may be considered include transaction risk, delivery channel risk, and industry risk2.
However, these are not among the options given in the question.
References: = Some of the references that support this answer are:
ACAMS Study Guide for the CAMS Certification Examination, Chapter 4, Section 4.1, pages 97-99:
"Customer Risk Factors", "Geographic Risk Factors", "Product Risk Factors".
Customer Risk Rating: Connecting Customer Risk Rating With Due Diligence, Section "Customer Risk Rating Factors": "Transaction Risk Factors", "Delivery Channel Risk Factors", "Industry Risk Factors".
CAMS-CN Exam Question 57
一份關於汽車經銷商安排存款的可疑交易報告啟動了刑事調查。經銷商更換了分支機構,並開始與經銷商贈送大量禮物的第一線員工進行交易。
該員工負責處理經銷商的所有結構性存款,並且不會在內部報告可疑活動。
主管機關已建議反洗錢專家在調查結束前避免向該員工舉報。
專家接下來該採取什麼行動?
該員工負責處理經銷商的所有結構性存款,並且不會在內部報告可疑活動。
主管機關已建議反洗錢專家在調查結束前避免向該員工舉報。
專家接下來該採取什麼行動?
Correct Answer: C
it describes the action that the anti-money laundering specialist should take next, which is to consult with senior management and the legal advisor. This is because the specialist needs to seek guidance and approval from the higher authorities and the legal experts on how to handle the situation without compromising the ongoing criminal investigation or violating the anti-money laundering laws and regulations. The specialist also needs to ensure that the institution's internal policies and procedures are followed and that the appropriate measures are taken to mitigate the risks and protect the reputation of the institution.
The other options are not necessarily actions that the anti-money laundering specialist should take next, although they may be considered or implemented later depending on the outcome of the consultation and the investigation. Option A describes a possible consequence for the employee, which is to recommend the immediate termination of the employee, but this may not be the best course of action at this stage, as it may alert the employee or the dealer of the investigation, or it may be premature or disproportionate without sufficient evidence or due process. Option B describes a possible measure for the dealer, which is to advise that the dealer's accounts should be closed, but this may not be feasible or advisable at this stage, as it may also tip off the dealer or the employee of the investigation, or it may interfere with the collection of evidence or the prosecution of the case. Option D describes a possible reporting obligation for the institution, which is to inform the institution's regulatory agency of the situation, but this may not be required or appropriate at this stage, as it may conflict with the instructions of the competent authority or the confidentiality of the investigation, or it may expose the institution to legal or regulatory liabilities or sanctions.
References:
* ACAMS CAMS Certification Video Training Course - 6th Edition1
* Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)2
* ACAMS CAMS Study Guide - 6th Edition, Chapter 6, pages 132-133
https://www.acams.org/wp-content/uploads/2019/09/ACAMS-CAMS-Study-Guide-6th-Edition-Chapter-6.pdf
The other options are not necessarily actions that the anti-money laundering specialist should take next, although they may be considered or implemented later depending on the outcome of the consultation and the investigation. Option A describes a possible consequence for the employee, which is to recommend the immediate termination of the employee, but this may not be the best course of action at this stage, as it may alert the employee or the dealer of the investigation, or it may be premature or disproportionate without sufficient evidence or due process. Option B describes a possible measure for the dealer, which is to advise that the dealer's accounts should be closed, but this may not be feasible or advisable at this stage, as it may also tip off the dealer or the employee of the investigation, or it may interfere with the collection of evidence or the prosecution of the case. Option D describes a possible reporting obligation for the institution, which is to inform the institution's regulatory agency of the situation, but this may not be required or appropriate at this stage, as it may conflict with the instructions of the competent authority or the confidentiality of the investigation, or it may expose the institution to legal or regulatory liabilities or sanctions.
References:
* ACAMS CAMS Certification Video Training Course - 6th Edition1
* Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)2
* ACAMS CAMS Study Guide - 6th Edition, Chapter 6, pages 132-133
https://www.acams.org/wp-content/uploads/2019/09/ACAMS-CAMS-Study-Guide-6th-Edition-Chapter-6.pdf
CAMS-CN Exam Question 58
在審查了金融機構的全企業反洗錢風險評估後,新任合規官發現了一些需要注意的缺陷。
哪一種缺陷最有可能導致未緩解的風險?
哪一種缺陷最有可能導致未緩解的風險?
Correct Answer: A
having an outdated and incomplete risk assessment could expose the financial institution to significant money laundering and terrorist financing risks that are not identified, measured, or mitigated. The risk assessment is a key component of an effective anti-money laundering program, and it should be updated regularly to reflect the changes in the business environment, customer profile, product offerings, delivery channels, and regulatory requirements12. A risk assessment that is several years old and does not cover all current products and services could fail to capture the emerging threats and vulnerabilities that the financial institution faces, and could result in inadequate or inappropriate controls, policies, and procedures. This could lead to the highest potential for unmitigated risk, as the financial institution could be exploited by money launderers and terrorist financiers, and face regulatory sanctions, reputational damage, and financial losses.
References:
Anti-Money Laundering (AML) Risk Assessment | ACAMS1
Risk assess your business for money laundering supervision - GOV.UK2
References:
Anti-Money Laundering (AML) Risk Assessment | ACAMS1
Risk assess your business for money laundering supervision - GOV.UK2
CAMS-CN Exam Question 59
哪一項聲明確定了政府金融情報機構的職責之一?
Correct Answer: A
A financial intelligence unit (FIU) is a national body or government agency that collects, analyzes, and disseminates financial information related to potential financial crimes, such as money laundering and terrorist financing. One of the core functions of an FIU is to receive disclosures filed by reporting entities, such as banks, money service businesses, casinos, and other obliged entities, that are required to report suspicious or unusual financial activity. These disclosures, also known as suspicious activity reports (SARs) or suspicious transaction reports (STRs), provide valuable intelligence for the FIU and other competent authorities to identify and investigate financial crimes and trace illicit funds. The other statements do not describe the duties of an FIU, but rather the roles of other agencies or bodies, such as the Office of Foreign Assets Control (OFAC) in the US, which administers and enforces economic and trade sanctions, or the Financial Action Task Force (FATF), which sets international standards for anti-money laundering and counter-terrorist financing (AML/CFT) supervision and regulation.
References:
* ACAMS CAMS Certification Video Training Course, Module 1: Risks and Methods of Money Laundering and Terrorist Financing, Lesson 1: The Financial Intelligence Unit
* The Financial Intelligence Unit: Role of the FIU and International Cooperation, Financial Crime Academy
* What We Do, Financial Crimes Enforcement Network (FinCEN)
References:
* ACAMS CAMS Certification Video Training Course, Module 1: Risks and Methods of Money Laundering and Terrorist Financing, Lesson 1: The Financial Intelligence Unit
* The Financial Intelligence Unit: Role of the FIU and International Cooperation, Financial Crime Academy
* What We Do, Financial Crimes Enforcement Network (FinCEN)
CAMS-CN Exam Question 60
金融行動特別工作組 (FATF) 式的區域機構為其成員提供哪些協助,以協助打擊洗錢和恐怖主義融資?
Correct Answer: A
Financial Action Task Force (FATF)-style regional bodies (FSRBs) are organizations that associate countries from the same region or that face similar challenges to combat money laundering and terrorist financing.
FSRBs have the same objectives as the FATF, which are to set international standards and promote effective implementation of legal, regulatory and operational measures to prevent and combat money laundering and terrorist financing. One of the main functions of FSRBs is to provide technical assistance and training to their members in implementing the FATF recommendations, which are the global standards for anti-money laundering and counter-terrorist financing. FSRBs also conduct mutual evaluations of their members to assess their level of compliance with the FATF recommendations and provide follow-up reports and actions.
References:
* CAMS Study Guide, 6th Edition, Chapter 2, Section 2.11
* Certification Candidate Handbook, Section 3.22
* FATF website, About Us, FATF-Style Regional Bodies3
FSRBs have the same objectives as the FATF, which are to set international standards and promote effective implementation of legal, regulatory and operational measures to prevent and combat money laundering and terrorist financing. One of the main functions of FSRBs is to provide technical assistance and training to their members in implementing the FATF recommendations, which are the global standards for anti-money laundering and counter-terrorist financing. FSRBs also conduct mutual evaluations of their members to assess their level of compliance with the FATF recommendations and provide follow-up reports and actions.
References:
* CAMS Study Guide, 6th Edition, Chapter 2, Section 2.11
* Certification Candidate Handbook, Section 3.22
* FATF website, About Us, FATF-Style Regional Bodies3
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