CAMS-CN Exam Question 211
對於提供客戶線上服務的金融機構來說,下列哪項洗錢風險最大?
Correct Answer: A
According to the Anti-Money Laundering Specialist (the 6th edition) study guide, one of the main challenges of providing on-line services to customers is the verification of their identity and the authentication of their transactions1. The lack of face-to-face contact and the use of electronic documents increase the risk of identity fraud, impersonation, and account takeover2. Therefore, financial institutions offering on-line services need to implement robust customer due diligence (CDD) measures, such as using multiple sources of information, verifying biometric data, and applying risk-based monitoring3.
References:
1: CAMS Study Guide, 6th Edition, Chapter 4, Section 4.1, page 103
2: CAMS Study Guide, 6th Edition, Chapter 4, Section 4.2, page 104
3: CAMS Study Guide, 6th Edition, Chapter 4, Section 4.3, page 105
References:
1: CAMS Study Guide, 6th Edition, Chapter 4, Section 4.1, page 103
2: CAMS Study Guide, 6th Edition, Chapter 4, Section 4.2, page 104
3: CAMS Study Guide, 6th Edition, Chapter 4, Section 4.3, page 105
CAMS-CN Exam Question 212
對反洗錢培訓文件的內部審查顯示,只有銷售人壽保險產品的金融機構僱用的新代理人接受了培訓。此外,通常需要機構
8個月開始新精算師培訓。合規官員解釋說,培訓僅限於精算師,因為他們執行唯一的高風險職能。該機構依賴電子學習技術,沒有後續評估。
內部審查最有可能建議解決下列哪些問題?
8個月開始新精算師培訓。合規官員解釋說,培訓僅限於精算師,因為他們執行唯一的高風險職能。該機構依賴電子學習技術,沒有後續評估。
內部審查最有可能建議解決下列哪些問題?
Correct Answer: B
The internal review would most likely recommend that the institution provide product-specific anti-money laundering training to all relevant employees, not just actuaries. This is because life insurance products can be used for money laundering purposes, such as purchasing policies with illicit funds, surrendering policies for cash value, or using policies as collateral for loans. Therefore, all employees who are involved in selling, servicing, or processing life insurance products should be aware of the money laundering risks and red flags associated with these products, and how to report any suspicious activity. The institution should also ensure that the training is timely, effective, and tailored to the specific roles and responsibilities of the employees.
The other options are not as relevant or appropriate as the correct answer. Option A is too broad, as not all staff need to be trained on anti-money laundering, only those who are relevant to the institution's business activities and exposure to money laundering risks. Option C is too narrow, as it only focuses on actuaries and does not address the need for training other employees who may deal with life insurance products. Option D is not sufficient, as e-learning alone may not be effective in ensuring that employees understand and retain the anti-money laundering content, and the institution should also conduct follow-up assessments to measure the impact and outcomes of the training.
References:
ACAMS Study Guide for the CAMS Certification Examination - 6th Edition, Chapter 3: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), page
57.
ACAMS CAMS Certification Video Training Course, Module 3: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), Lesson 3.5: Training and Testing.
Best Practices for Anti-Money Laundering Compliance - DIRO Original, Section 3: Adequate Training.
The other options are not as relevant or appropriate as the correct answer. Option A is too broad, as not all staff need to be trained on anti-money laundering, only those who are relevant to the institution's business activities and exposure to money laundering risks. Option C is too narrow, as it only focuses on actuaries and does not address the need for training other employees who may deal with life insurance products. Option D is not sufficient, as e-learning alone may not be effective in ensuring that employees understand and retain the anti-money laundering content, and the institution should also conduct follow-up assessments to measure the impact and outcomes of the training.
References:
ACAMS Study Guide for the CAMS Certification Examination - 6th Edition, Chapter 3: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), page
57.
ACAMS CAMS Certification Video Training Course, Module 3: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), Lesson 3.5: Training and Testing.
Best Practices for Anti-Money Laundering Compliance - DIRO Original, Section 3: Adequate Training.
CAMS-CN Exam Question 213
下列哪一項最精確地描述了巴塞爾銀行監理委員會關於客戶盡職調查的原則?
Correct Answer: B
The Basel Committee on Banking Supervision (BCBS) is a global standard-setting body for the prudential regulation of banks. It does not have any formal authority to enforce its standards, but relies on its members' commitment and peer pressure to implement them. The BCBS's principles on customer due diligence (CDD) are part of its guidelines on anti-money laundering and combating the financing of terrorism (AML/CFT), which aim to enhance the soundness and integrity of banking systems. The BCBS's principles on CDD provide guidance to banks and bank supervisors on the essential elements of a CDD programme, such as customer acceptance, identification, verification, risk assessment, monitoring, and record-keeping. The BCBS's principles on CDD are not legally binding, but are intended to be a benchmark for national practices and for banks to design their own policies and procedures. The BCBS's principles on CDD are consistent with the recommendations of the Financial Action Task Force (FATF), the global standard-setter for AML/CFT.
References:
Customer due diligence for banks 1, BCBS, October 2001.
The Basel Committee on Banking Supervision report on customer due diligence 2, Journal of Banking Regulation, 2002.
References:
Customer due diligence for banks 1, BCBS, October 2001.
The Basel Committee on Banking Supervision report on customer due diligence 2, Journal of Banking Regulation, 2002.
CAMS-CN Exam Question 214
從歷史上看,下列哪一種工具最常用於隱藏受益所有權?
Correct Answer: A
An offshore company is a legal entity that is incorporated or registered in a foreign jurisdiction, usually with low or no taxes, high confidentiality, and minimal regulation1. Offshore companies are often used to hide beneficial ownership, as they can create complex and opaque structures that obscure the identity and control of the real owners and beneficiaries of the assets or transactions involved2. Offshore companies can also use nominee directors and shareholders, trust and company service providers, and shell companies to further conceal beneficial ownership3. According to the web search results, offshore companies are among the most common vehicles for money laundering, tax evasion, corruption, and other illicit activities4 .
References:
* 1: What is an offshore company? - ACAMS
* 2: Guidance on Transparency and Beneficial Ownership - FATF
* 3: Concealment of Beneficial Ownership - FATF-Egmont Group
* 4: What's a Beneficial Owner and Why Does it Matter? - Dun & Bradstreet
* : The Panama Papers: Exposing the Rogue Offshore Finance Industry - ICIJ
References:
* 1: What is an offshore company? - ACAMS
* 2: Guidance on Transparency and Beneficial Ownership - FATF
* 3: Concealment of Beneficial Ownership - FATF-Egmont Group
* 4: What's a Beneficial Owner and Why Does it Matter? - Dun & Bradstreet
* : The Panama Papers: Exposing the Rogue Offshore Finance Industry - ICIJ
CAMS-CN Exam Question 215
恐怖分子融資通常青睞哪三種轉移恐怖分子相關資金的管道?選出 3 個答案
Correct Answer: B,C,D
Dealers in antiques, precious metals, precious stones, jewelry, and art are advised to follow these practices to reduce the element of money laundering risk:
* Verify the identities of all new vendors and customers and conduct due diligence on them. This is to ensure that the dealers know who they are dealing with and can assess the risk level of each customer or vendor. Due diligence may include obtaining and verifying identification documents, checking against sanctions lists or watchlists, obtaining information on the source and purpose of funds, and applying a risk-based approach to the level and frequency of due diligence.
* Avoid accepting cash payment from the buyers. This is to prevent the dealers from being used as a conduit for laundering illicit cash or facilitating cash smuggling. Cash transactions are more difficult to trace and may indicate attempts to evade reporting or record-keeping requirements. Dealers should encourage the use of non-cash payment methods, such as bank transfers, cheques, or credit cards, and keep records of all payment transactions.
* Insist all vendors submit an appropriate license issued by enforcement agencies authorizing the sale.
This is to ensure that the dealers are not involved in the trade of stolen, smuggled, or counterfeit goods, which may be linked to money laundering or other criminal activities. Dealers should verify the authenticity and validity of the licenses and keep copies of them for record-keeping purposes.
References:
* FATF Guidance on the Risk-Based Approach for Dealers in Precious Metals and Stones, pages 9-10,
13-14, 17-18, 21-22
* AML-CFT Handbook for Dealers in Precious Metals and Stones, pages 25-26, 37-38, 52-53
* The anti-money laundering framework for precious stones and metals dealers in Singapore, pages 7-8,
11-12, 15-16
* Dealers in Precious Metals, Stones or Jewels Required to Establish Anti-Money Laundering Programs, pages 2-3, 6-7, 10-11
* Verify the identities of all new vendors and customers and conduct due diligence on them. This is to ensure that the dealers know who they are dealing with and can assess the risk level of each customer or vendor. Due diligence may include obtaining and verifying identification documents, checking against sanctions lists or watchlists, obtaining information on the source and purpose of funds, and applying a risk-based approach to the level and frequency of due diligence.
* Avoid accepting cash payment from the buyers. This is to prevent the dealers from being used as a conduit for laundering illicit cash or facilitating cash smuggling. Cash transactions are more difficult to trace and may indicate attempts to evade reporting or record-keeping requirements. Dealers should encourage the use of non-cash payment methods, such as bank transfers, cheques, or credit cards, and keep records of all payment transactions.
* Insist all vendors submit an appropriate license issued by enforcement agencies authorizing the sale.
This is to ensure that the dealers are not involved in the trade of stolen, smuggled, or counterfeit goods, which may be linked to money laundering or other criminal activities. Dealers should verify the authenticity and validity of the licenses and keep copies of them for record-keeping purposes.
References:
* FATF Guidance on the Risk-Based Approach for Dealers in Precious Metals and Stones, pages 9-10,
13-14, 17-18, 21-22
* AML-CFT Handbook for Dealers in Precious Metals and Stones, pages 25-26, 37-38, 52-53
* The anti-money laundering framework for precious stones and metals dealers in Singapore, pages 7-8,
11-12, 15-16
* Dealers in Precious Metals, Stones or Jewels Required to Establish Anti-Money Laundering Programs, pages 2-3, 6-7, 10-11
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