2024 Latest CAMS-FCI dumps Exam Material with 102 Questions
ACAMS CAMS-FCI Questions and Answers Guarantee you Oass the Test Easily
NEW QUESTION # 50
When crafting internal procedures on writing and submitting SARs/STRs, one should:
- A. use internal keywords and standard industry terms to better provide context within which the suspicious activity was identified.
- B. adhere to home junsdiction guidelines across the whole group when local requirements of the country of operation and home jurisdiction conflict.
- C. consider the guidelines issued by the national financial intelligence unit {FIU) and local regulator and incorporate any country-specific requirements.
- D. include attachments with the SARs/STRs as all information needs to be at the disposal of the financial intelligence unit (FIU)
Answer: C
Explanation:
Explanation
When writing and submitting SARs/STRs, one should consider the guidelines issued by the national financial intelligence unit (FIU) and local regulator and incorporate any country-specific requirements. This ensures that the reports are compliant with the relevant laws and regulations and provide useful information to the authorities. The other options are either incorrect or not best practices.
References: Advanced CAMS-FCI Study Guide, page 48-49.
NEW QUESTION # 51
A government entity established a trust to provide social welfare programs. The entity wants cash payments made to persons without supporting documentation. These persons would oversee the allocation of funds to beneficiaries without complying with internal disbursement of government funds controls. Which is the main premise for filing a SAR/STR?
- A. Trust service providers are not obliged by law to follow government internal controls.
- B. Social welfare programs are difficult to document because the beneficiaries are from the informal sector.
- C. Cash disbursements are not allowed for social welfare programs.
- D. The entity is not implementing adequate internal controls according to what is expected, and mishandling of funds could be occurring.
Answer: D
Explanation:
Explanation
The main premise for filing a SAR/STR is that the entity is not implementing adequate internal controls according to what is expected, and mishandling of funds could be occurring. This raises suspicion that the entity may be involved in corruption, fraud, or diversion of funds for illicit purposes. Trust service providers are obliged by law to follow government internal controls, as they are subject to AML/CFT regulations and supervision. Cash disbursements are allowed for social welfare programs, but they should be properly documented and verified. Social welfare programs are not necessarily difficult to document, as there are ways to identify and monitor the beneficiaries, such as biometric data or unique identifiers.
NEW QUESTION # 52
The intended benefits of section 314(b) of the USA PATRIOT Act include: (Select Three.)
- A. expediting the filing of SARs/STRs due to the information sharing facilitated by 314(b).
- B. participating FIs sharing information about suspicious activity by customers that may have otherwise gone unnoticed.
- C. obtaining additional information on customers or transactions regarding potential money laundering or terrorist financing (TF).
- D. sharing the existence and content of SARs/STRs with other participating FIs.
- E. detecting money laundering and TF approaches and schemes across multiple financial institutions (FIs).
- F. providing mandatory results to law enforcement agencies so that they can more easily obtain useful information.
Answer: B,C,E
Explanation:
Explanation
Section 314(b) of the USA PATRIOT Act allows financial institutions to share information with each other, under a safe harbor that offers protection from liability, in order to better identify and report potential money laundering or terrorist financing activities. The intended benefits of this information sharing include:
Participating financial institutions sharing information about suspicious activity by customers that may have otherwise gone unnoticed. For example, if a customer is conducting transactions with multiple financial institutions that individually do not appear suspicious, but collectively indicate a pattern of money laundering or terrorist financing, the financial institutions can share this information and report it to the authorities.
Detecting money laundering and terrorist financing approaches and schemes across multiple financial institutions. For example, if a financial institution identifies a new typology or modus operandi of money laundering or terrorist financing, it can share this information with other financial institutions to help them prevent or detect similar activities by their customers.
Obtaining additional information on customers or transactions regarding potential money laundering or terrorist financing. For example, if a financial institution has incomplete or insufficient information on a customer or a transaction that raises suspicion, it can request more information from another financial institution that may have dealt with the same customer or transaction.
References:
Section 314(b) | FinCEN.gov
Section 314(b) Fact Sheet - FinCEN.gov
NEW QUESTION # 53
A client at a financial institution deposits large amounts of money into an account, and almost immediately, the funds are then distributed to numerous individuals' accounts. The transaction activity described in the scenario is a pattern of:
- A. account usage.
- B. deposit trading.
- C. geographic usage.
- D. safe deposit custody.
Answer: B
Explanation:
Explanation
Deposit trading is a pattern of suspicious activity where a client deposits large amounts of money into an account, and then transfers the funds to other accounts, often in different jurisdictions or countries. This could be an attempt to disguise the source or destination of the funds, or to avoid reporting requirements. Deposit trading is also known as layering, which is the second stage of money laundering.
References: ACAMS Advanced Financial Crimes Investigations Certification Study Guide, page 43; ACAMS Glossary, page 34.
NEW QUESTION # 54
An investigator at a corporate bank is conducting transaction monitoring alerts clearance.
KYC profile background: An entity customer, doing business offshore in Hong Kong, established a banking business relationship with the bank in 2017 for deposit and loan purposes. It acts as an offshore investment holding company. The customer declared that the ongoing source of funds to this account comes from group-related companies.
* X is the UBO. and owns 97% shares of this entity customer;
* Y is the authorized signatory of this entity customer. This entity customer was previously the subject of a SAR/STR.
KYC PROFILE
Customer Name: AAA International Company. Ltd
Customer ID: 123456
Account Opened: June 2017
Last KYC review date: 15 Nov 2020
Country and Year of Incorporation: The British Virgin Islands, May 2017 AML risk level: High Account opening and purpose: Deposits, Loans, and Trade Finance Anticipated account activities: 1 to 5 transactions per year and around 1 million per transaction amount During the investigation, the investigator reviewed remittance transactions activities for the period from Jul
2019 to Sep 2021 and noted the following transactions pattern:
TRANSACTION JOURNAL
Review dates: from July 2019 to Sept 2021
For Hong Kong Dollars (HKD) currency:
Incoming transactions: 2 inward remittances of around 1.88 million HKD in total from different third parties Outgoing transactions: 24 outward remittances of around 9 4 million HKD in total to different third parties For United States Dollars (USD) currency:
Incoming transactions: 13 inward remittances of around 3.3 million USD in total from different third parties Outgoing transactions: 10 outward remittances of around 9.4 million USD in total to different third parties.
RFI Information and Supporting documents:
According to the RFI reply received on 26 May 2021, the customer provided the bank with the information below:
1J All incoming funds received in HKD & USD currencies were monies lent from non-customers of the bank.
Copies of loan agreements had been provided as supporting documents. All of the loan agreements were in the same format and all the lenders are engaged in trading business.
2) Some loan agreements were signed among four parties, including among lenders. borrower (the bank's customer), guarantor, and guardian with supplemental agreements, which stated that the customer, as a borrower, who failed to repay the loan Which additional information would support escalating this account for closure?
- A. A follow-up request reveals that the account receives funds from loans, collects payments from group-related companies, and sends the payments to the lenders.
- B. A review of X's personal bank account shows that X received wire transfers that aggregate the amounts transferred to the group-related companies.
- C. The bank files SARs/STRs indicating that Y opened accounts for small companies located in close proximity to the bank.
- D. A review of outward remittances reveals the same pattern of several simple steps for each transaction,
Answer: D
Explanation:
Explanation
A review of outward remittances reveals the same pattern of several simple steps for each transaction, which could indicate a layering scheme to obscure the origin and destination of the funds. This would support escalating this account for closure, as it is inconsistent with the customer's declared purpose and anticipated activities. The other options are not relevant or sufficient to warrant account closure.
References: Advanced CAMS-FCI Certification | ACAMS
NEW QUESTION # 55
A U.S. financial institution (Fl) receives a grand jury subpoena for a corporate client's account. The Fl should:
- A. provide the client with a copy of the subpoena.
- B. review the corporate account's activity and transactions.
- C. file a SAR/STR.
- D. request the client's consent for the disclosure of account information.
Answer: B
Explanation:
Explanation
The Fl should review the corporate account's activity and transactions. This is because a grand jury subpoena is a legal request for information or testimony that may be used in a criminal investigation or prosecution. The Fl should review the account for any suspicious or unusual activity that may be related to the subpoena or indicate money laundering, terrorist financing, or other financial crimes. The Fl should also document its review and retain any relevant records.
References: Leading Complex Investigations Certificate, Module 3, page 14.
NEW QUESTION # 56
Law enforcement (LE) suspects human trafficking to occur during a major sporting event LE officers asked several financial institutions (FIs) to monitor financial transactions occurring before, during, and after the event.
An investigator identified a pattern linked to a business. The business' account received multiple even dollar deposits between midnight and 4:00 AM. They occurred each day for several days prior to the date of the sporting event. Also, large cash deposits, typically between 2,000 USD and 3,000 USD. made by a person to the business' account occurred in many branches in the days after the sports event.
There was little information about the company. The company did not have any history of employee payroll expenses or paying taxes. Expenses from the business account included air travel and hotel expenses. Searches about the person making cash deposits showed little. An online social media platform webpage with the individual's name showed ads for dates1' and "companionship." The Fl wants to create an automated alert for human trafficking money laundering after this investigation.
Which activity type should they target?
- A. Payments made for virtual currency
- B. Deposits made within days of major sporting events
- C. Multiple deposits between midnight and 4:00 AM
- D. Payments made to multiple hotels in the same city
Answer: C
Explanation:
Explanation
The activity type that the FI should target for creating an automated alert for human trafficking money laundering is multiple deposits between midnight and 4:00 AM (B). This is because this pattern is consistent with the indicators of human trafficking identified by the Financial Action Task Force (FATF) and the Egmont Group1, which include:
Frequent cash deposits, often in round amounts, outside of normal business hours Deposits made at different branches or ATMs in various locations Lack of information about the nature and purpose of the business Involvement in online platforms that advertise sexual services Expenses related to travel and accommodation The other options are not as relevant or specific as option B. Payments made to multiple hotels in the same city (A) could be a legitimate business expense or a sign of other types of money laundering, such as tax evasion or fraud. Deposits made within days of major sporting events could also be explained by other factors, such as increased tourism or gambling. Payments made for virtual currency (D) are not directly related to human trafficking, although they could be used to facilitate money laundering in general.
References: 1: FATF and Egmont Group, Financial Flows from Human Trafficking, July 2018, available at FATF
NEW QUESTION # 57
Which action is part of the enhanced due diligence process?
- A. Verifying the source of wealth for entities and natural person clients
- B. Using standard monitoring procedures to monitor transactions and account activity
- C. Collecting beneficial ownership details regarding the client's account
- D. Applying higher ownership percentage requirement for beneficial ownership collection
Answer: C
Explanation:
Explanation
One of the actions that is part of the enhanced due diligence process is collecting beneficial ownership details regarding the client's account. This is important to identify the natural persons who ultimately own or control the client, and to assess the potential risks associated with them. According to the Financial Action Task Force (FATF), beneficial ownership information should include1:
The name, nationality, and country of residence of each beneficial owner.
The date of birth or incorporation of each beneficial owner.
The nature and extent of the beneficial interest held by each beneficial owner.
The means by which the beneficial ownership or control is exercised.
References:
FATF Guidance on Transparency and Beneficial Ownership
NEW QUESTION # 58
A retail bank prepares a yearly AML risk assessment. Which inherent risk factor is likely the most relevant?
- A. The provision of remote check deposit services
- B. The provision of cash services
- C. The provision of brokerage services
- D. The provision of payable through accounts
Answer: B
Explanation:
Explanation
Retail banks typically have a high inherent risk of money laundering due to their provision of cash services.
This is because cash is a preferred medium of exchange for criminals and terrorists, and retail banks provide a convenient way for them to move large sums of money without detection. Retail banks are also vulnerable to money laundering through the use of false identities and other deceptive practices. (CAMS Manual, 6th Edition, Page 8).
NEW QUESTION # 59
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. Exit the relationship with the customer.
- D. Discuss the investigation findings with the customer.
- E. Re-evaluate the customer risk profile.
Answer: A,E
Explanation:
Explanation
The actions that the investigator should recommend to mitigate risk are conducting enhanced due diligence (D) and re-evaluating the customer risk profile (E). These actions are appropriate and prudent, as they allow the investigator to obtain more information and evidence about the nature and purpose of the transactions, the source and destination of the funds, and the identity and legitimacy of the parties involved. According to the ACAMS Advanced Financial Crimes Investigations Certification Study Guide1, "the FI should conduct enhanced due diligence on all parties involved in the investigation, including checking various sources of information, such as watch lists, sanctions lists, negative news, and official registries" (p. 24). The FI should also "re-assess the customer risk profile based on any new information obtained during the investigation, and adjust the customer due diligence and monitoring requirements accordingly" (p. 25).
The other options are not as appropriate or effective as options D and E. The investigator should not recommend exiting the relationship with the customer (A), as this could be premature or disproportionate, as well as potentially discriminatory or illegal. The investigator should not recommend documenting and maintaining a file with the investigative findings (B), as this is not an action to mitigate risk, but rather a standard procedure for any investigation. The investigator should not recommend discussing the investigation findings with the customer , as this could compromise the integrity and objectivity of the investigation, as well as expose the FI to legal or regulatory risks.
References: 1: ACAMS Advanced Financial Crimes Investigations Certification Study Guide
NEW QUESTION # 60
An investigator at a bank triggered a review in relation to potential misuse of legal persons and a complex network of corporate entities owned by customer A. For the investigator to provide a holistic view of the underlying risk, which action should be the initial focus of the investigation?
- A. Find out whether customer A has relationships with other financial institutions.
- B. Conduct a network link analysis on all customers of the bank.
- C. Review the customer due diligence documents of each entity and examine the year of incorporation and onboarding channel.
- D. Use data analytics to extract and analyze the linkages between the different entities.
Answer: C
Explanation:
Explanation
The initial focus of the investigation should be to review the customer due diligence documents of each entity and examine the year of incorporation and onboarding channel, as this would help identify the beneficial owners, the source of funds, and the purpose of the business relationship. This would also help determine if the entities are shell companies or have any red flags that indicate potential misuse of legal persons. Using data analytics to extract and analyze the linkages between the different entities would be a subsequent step, not the initial one. Conducting a network link analysis on all customers of the bank would be too broad and time-consuming. Finding out whether customer A has relationships with other financial institutions would be relevant, but not the initial focus. References: [Advanced CAMS-FCI Study Guide], page 44-45; [FATF Guidance on Transparency and Beneficial Ownership], page 12-13.
NEW QUESTION # 61
A SAR/STR on cash activity is filed for a company registered in the Marshall Islands operating a Mediterranean beach bar and hotel. The company has three nominee directors, one nominee shareholder, and another individual declared as both the beneficial owner and authorized signatory. Which information is key for law enforcement's physical surveillance of cash activity? (Select Two.)
- A. The identification details o' the nominee shareholder
- B. The company's registered address
- C. The identification details the nominee directors
- D. The identification details of the beneficial owner and authorized signatory
- E. The company's operating address
Answer: D,E
Explanation:
Explanation
The identification details of the beneficial owner and authorized signatory are key for law enforcement's physical surveillance of cash activity, as they would help identify the person who controls and operates the company and who is responsible for its financial transactions. The company's operating address is also key, as it would help locate the premises where the cash activity takes place and observe any suspicious movements or behaviors. The identification details of the nominee shareholder and directors are not relevant, as they are not involved in the management or operation of the company. The company's registered address is also not relevant, as it is likely to be a shell or mailbox address that does not reflect the actual location of the business.
References: Advanced CAMS-FCI Study Guide, page 44-45; [FATF Guidance on Transparency and Beneficial Ownership], page 12-13.
NEW QUESTION # 62
A financial institution (Fl) has considered the available relevant factors in a transaction and has determined it will file a SAR^STR. Which is needed to support the contents of the report to the financial intelligence unit?
- A. Enough circumstantial evidence about the suspicious activity for a criminal proceeding
- B. Low evidentiary threshold about the suspicious activity
- C. Definitive proof that suspicious activity occurred
- D. No factual description of the suspicious activity
Answer: B
Explanation:
Explanation
A SAR/STR does not require definitive proof or enough circumstantial evidence of suspicious activity, as these are high evidentiary thresholds that may be difficult or impossible to obtain by the FI. A SAR/STR should include a factual description of the suspicious activity, as this is essential for the FIU to analyze and disseminate the information. A low evidentiary threshold means that the FI has reasonable grounds to suspect that the activity is related to money laundering, terrorism financing, or other financial crimes, based on the available relevant factors. This is the main criterion for filing a SAR/STR.
References: Advanced CAMS-FCI Certification | ACAMS, Suspicious activity report - Wikipedia, Suspicious Transaction Report (STR) / Suspicious Activity Report (SAR ...
NEW QUESTION # 63
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 exhibiting transactions with declared counterparties
- B. Entities whose principal place of business is a non-residential address
- C. Entities with high paid-up capital relative to monthly value of transactions
- D. Entities transacting with or having relation to tax haven or high-risk countries
- E. Entities with a large number and variety of beneficiaries not declared at the time of onboarding
Answer: B,D
Explanation:
Explanation
The data points that the compliance team should include in its data analytics program to detect shell or front company red flags are entities whose principal place of business is a non-residential address and entities transacting with or having relation to tax haven or high-risk countries. These data points may indicate that the entities are not conducting legitimate business activities, but rather are used to conceal the identity or location of the true beneficiaries or owners, or to facilitate money laundering, tax evasion, or other illicit activities.
Some of the sources that support these data points as red flags are4567:
Entities whose principal place of business is a non-residential address may indicate that they have no physical presence, operations, assets, or employees. They may use addresses such as post office boxes, mail forwarding services, registered agents, or virtual offices to avoid detection or scrutiny.
Entities transacting with or having relation to tax haven or high-risk countries may indicate that they are involved in offshore financial activities that are designed to evade taxes, regulations, or sanctions. They may also be exposed to higher risks of money laundering, terrorist financing, corruption, or fraud.
References:
How to Identify a Shell Company and the Associated Red Flags
Difference between Shell, Shelf & Front Company | Sigma Ratings
Shell Companies and Money Laundering | ComplyAdvantage
General Comments Incorporation of shell companies - Singapore Police Force
NEW QUESTION # 64
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. Including an explanation of the internal process that brought the transaction to the attention of the analyst
- C. Including a detailed description of the known or suspected criminal violation or suspicious activity
- D. Ensuring all information in the SAR/STR is complete and accurate based on what the institution knows
- E. Including information about the general activity trends in the area where the suspicious transactions were conducted
Answer: C,D
Explanation:
Explanation
A SAR/STR narrative that is useful to law enforcement should include a detailed description of the known or suspected criminal violation or suspicious activity, as well as ensure that all information in the SAR/STR is complete and accurate based on what the institution knows. These elements help law enforcement to understand the nature and scope of the suspicious activity, and to follow up with further investigation if needed. The other options are not essential for a useful SAR/STR narrative, as they either provide irrelevant or redundant information, or could compromise the confidentiality of the report.
NEW QUESTION # 65
Which scenarios are common to money laundering through online marketplaces and trade-based money laundering? (Select Two.)
- A. Use of multiple freight forwarding or export companies
- B. Use of fraudulent letters of credit
- C. No evidence of delivery of goods or shipping expenses
- D. Frequent conversion of foreign currency
- E. Over-valuation of the stated price of goods
Answer: C,E
Explanation:
Explanation
Money laundering through online marketplaces and trade-based money laundering both involve the manipulation of the value or quantity of goods to disguise the illicit origin of funds. Over-valuation of the stated price of goods and no evidence of delivery of goods or shipping expenses are two common indicators of such schemes. The other options are not specific to these methods of money laundering.
References: Advanced CAMS-FCI Study Guide, page 29-30.
NEW QUESTION # 66
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. Review Fl approved policies regarding the existing accounts to ensure regulatory requirements were followed.
- B. Inform Fl management of all processes used to investigate the client due to LE inquiry.
- C. Review all client-signed documents relating to all accounts.
- D. Perform secondary scans of the client's other owners/authorized signers
- E. Prepare a relationship flow chart of all existing accounts to better understand the client's activities.
- F. File SARs/STRs for all accounts at the beginning of the discovery phase and amend later as necessary.
Answer: C,D,E
Explanation:
Explanation
The investigator should review all client-signed documents relating to all accounts (A) to check for any discrepancies or red flags. The investigator should also perform secondary scans of the client's other owners/authorized signers (D) to identify any possible connections or associations with the second client or the Paradise Papers. Additionally, the investigator should prepare a relationship flow chart of all existing accounts (F) to better understand the client's activities and patterns. These steps are consistent with the ACAMS Advanced Financial Crimes Investigations Certification Study Guide1, which states that investigators should
"review all relevant documentation, including account opening documents, transaction records, and customer correspondence" (p. 23), "conduct enhanced due diligence on all parties involved in the investigation" (p. 24), and "use data visualization tools to map out complex relationships and transactions" (p. 25).
References: 1: ACAMS Advanced Financial Crimes Investigations Certification Study Guide, available at ACAMS
NEW QUESTION # 67
In which case should an investigator avoid escalating a suspicious event to the chief compliance officer and pursue other channels?
- A. A close family member of the chief compliance officer is the beneficiary of a cross-border transfer.
- B. The transaction chain is likely connected to a known member of a terrorist organization.
- C. A trade entity engages in complex trade deals involving numerous third-party intermediaries in incongruent lines of business.
- D. An individual involved in a large sum transaction is a foreign PEP.
Answer: A
Explanation:
Explanation
An investigator should avoid escalating a suspicious event to the chief compliance officer if there is a potential conflict of interest, such as when a close family member of the officer is involved in the transaction. In such a case, the investigator should pursue other channels, such as reporting to a higher authority or an independent committee. The other options do not present a conflict of interest and should be escalated to the chief compliance officer as part of the normal procedure.
References: Advanced CAMS-FCI Certification Handbook, page 18.
NEW QUESTION # 68
A criminal is engaged in chain hopping while trying to launder ransomware payments. The criminal will likely:
- A. store the funds in a cold wallet.
- B. convert the funds to a different type of cryptocurrency.
- C. obscure the funds using a mixer.
- D. move the funds to an offshore cryptocurrency wallet.
Answer: B
Explanation:
Explanation
Chain hopping is a technique used by criminals to obscure the traceability of cryptocurrency transactions by converting the funds to a different type of cryptocurrency, often using multiple exchanges or platforms. The other options are not related to chain hopping. References: Advanced CAMS-FCI Study Guide, page 38.
NEW QUESTION # 69
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.
The analyst determines that site visits should be conducted for the three daycare businesses. Which observations at the on-site visits would justify writing a SAR/STR? (Select Three.)
- A. A full parking lot of cars with no staff at the site
- B. Visible attendance with children being dropped off by parents
- C. Visible signage indicating the purpose of the building
- D. Lights turned off at the site during operational hours
- E. A site located in a commercial building
- F. Signs of severe wear and poor maintenance at the site
Answer: A,D,F
Explanation:
Explanation
The observations at the on-site visits that would justify writing a SAR/STR are signs of severe wear and poor maintenance at the site (A), lights turned off at the site during operational hours , and a full parking lot of cars with no staff at the site (F). These observations suggest that the daycare businesses are not operating legitimately or providing adequate services to their customers, and that they may be misusing governmental grants or laundering money through their accounts. These observations are consistent with some of the red flags for fraud identified by ACAMS2, such as:
Inadequate facilities or equipment for the type of business
Lack of visible activity or customers at the business location
Discrepancy between reported income and expenses
Unusual volume or frequency of transactions
The other observations are not as relevant or indicative of fraud as options A, C, and F. A site located in a commercial building (B) could be a normal or legitimate choice for a daycare business, depending on its size, location, and availability. Visible attendance with children being dropped off by parents (D) could show that the daycare business is providing genuine services to its customers, although it does not rule out possible fraud or money laundering. Visible signage indicating the purpose of building (E) could also show that the daycare business is transparent and legitimate, although it does not guarantee its quality or compliance.
References: 1: ACAMS Advanced Financial Crimes Investigations Certification Study Guide, available at ACAMS 2: ACAMS Fraud Prevention eLearning Course Module 3: Fraud Detection Techniques
NEW QUESTION # 70
CLIENT INFORMATION FORM Client Name: ABC Tech Corp Client ID. Number: 08125 Name: ABC Tech Corp Registered Address: Mumbai, India Work Address: Mumbai, India Cell Phone: "**"'" Alt Phone:
"*""* Email: ........"
Client Profile Information:
Sector: Financial
Engaged in business from (date): 02 Jan 2020 Sub-sector: Software-Cryptocurrency Exchange Expected Annual Transaction Amount: 125,000 USD Payment Nature: Transfer received from clients' fund Received from: Clients Received for: Sale of digital assets The client identified itself as Xryptocurrency Exchange." The client has submitted the limited liability partnership deed. However, the bank's auditing team is unable to identify the client's exact business profile as the cryptocurrency exchange specified by the client as their major business awaits clearance from the country's regulator. The client has submitted documents/communications exchanged with the regulator and has cited the lack of governing laws in the country of their operation as the reason for the delay.
During the financial crime investigation, the investigator discovers that some of the customer due diligence (CDD) documents submitted by the client were fraudulent. The investigator also finds that some of the information in the financial institution's information depository is false. What should the financial crime investigator do next?
- A. Escalate to the compliance officer/money laundering reporting officer to file a SAR/STR.
- B. Request that the relationship manager conduct a CDD refresh as it is a material trigger.
- C. Contact the client directly and obtain the relevant notarized documents and information.
- D. Report collusion between the cryptocurrency exchange and internal staff in the internal hotline or whistle-blowing channel.
Answer: A
Explanation:
Explanation
The correct answer is C. Escalate to the compliance officer/money laundering reporting officer to file a SAR/STR. This is because the financial crime investigator has found evidence of fraudulent documents and false information, which indicate a high risk of money laundering or other financial crimes. The investigator should not contact the client directly, as this may tip them off or compromise the investigation. The investigator should also not report collusion between the cryptocurrency exchange and internal staff, as this is an assumption that has not been verified. The investigator should not request a CDD refresh, as this is not sufficient to address the serious issues identified.
References:
Advanced CAMS-FCI Study Guide, page 291
Advanced CAMS-FCI Study Guide, page 311
Advanced CAMS-FCI Study Guide, page 331
1: https://www.acams.org/en/certifications/advanced-cams/advanced-financial-crimes-investigations
NEW QUESTION # 71
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