Acams cams-fci practice test
Advanced CAMS-Financial Crimes Investigations
Question 1
The investigative department of a financial institution (Fl) receives an internal escalation notice from
the remittance department for a SWIFT message requesting a refund due to potential fraud. The
notice indicates that a total of three international incoming remittances were transferred to a
corporate customer from Country A, in the amount of approximately 5 million EUR for each. The first
two incoming remittances had been exchanged into currency B and transferred out to Country B a
few days ago. The third incoming remittance has been held by the remittance department.
As noted from the KYC profile, the corporate customer is working in the wood industry. with the last
account review completed 3 months ago. Since the account's opening. there has been no history of a
large amount of funds flowing through the account. The investigator conducts an Internet search and
finds that the remitter is a food beverage company.
The same morning, the investigator receives a call from a financial intelligence unit (FIU) inquiring
about the same incident. The FIU states that it will issue a warrant to freeze the account on the same
day.
After further review, the decision is made that transactions appear suspicious. Which are the next
steps the investigator should take? (Select Two.)
- A. Close the customer's accounts since the FIU is issuing a warrant to freeze the funds.
- B. Contact local LE and advise them of the investigation details to help speed up the investigation and prosecution.
- C. Provide additional information to the LE upon receiving a formal request.
- D. Close the investigation as the FIU is already on this matter, and they will inform LE if needed.
- E. Gather all the information that would be useful for law enforcement (LE) and recommend filing a SAR/STR
Answer:
C, E
Explanation:
The correct answer is C and E. The investigator should provide additional information to the LE upon
receiving a formal request, and gather all the information that would be useful for LE and
recommend filing a SAR/STR. These steps are consistent with the best practices of conducting
financial crime investigations and reporting suspicious activity. The investigator should not close the
customer’s accounts or the investigation, as this may interfere with the ongoing LE inquiry and
violate the FI’s policies and procedures. The investigator should also not contact local LE directly, as
this may compromise the confidentiality of the investigation and the FIU’s authority. Reference:
Advanced CAMS-FCI Study Guide, Chapter 4: Reporting Suspicious Activity, pages 40-411
Advanced CAMS-FCI Study Guide, Chapter 5: Governance of an AFC Investigations Unit, pages 48-491
Advanced CAMS-FCI Certification | ACAMS
Question 2
The investigative department of a financial institution (Fl) receives an internal escalation notice from
the remittance department for a SWIFT message requesting a refund due to potential fraud. The
notice indicates that a total of three international incoming remittances were transferred to a
corporate customer from Country A, in the amount of approximately 5 million EUR for each. The first
two incoming remittances had been exchanged into currency B and transferred out to Country B a
few days ago. The third incoming remittance has been held by the remittance department.
As noted from the KYC profile, the corporate customer is working in the wood industry. with the last
account review completed 3 months ago. Since the account's opening. there has been no history of a
large amount of funds flowing through the account. The investigator conducts an Internet search and
finds that the remitter is a food beverage company.
The same morning, the investigator receives a call from a financial intelligence unit (FIU) inquiring
about the same incident. The FIU states that it will issue a warrant to freeze the account on the same
day.
Which steps for documenting the final investigation decision are appropriate for the investigator in
this scenario?
- A. Exclude any open-source information from record-keeping since it is publicly available.
- B. Add all of the information the Fl has about the subject, their account(s) activity, research results. KYC information, etc. to the SAR/STR.
- C. Document the investigation process and retain all relevant documents in the case management system.
- D. Do not document the investigation process if a SAR/STR is not filed.
Answer:
C
Explanation:
The investigator should document the investigation process and retain all relevant documents in the
case management system. This is because documenting the investigation process is a good practice
to ensure the quality and consistency of the investigation, as well as to facilitate the review and audit
of the investigation. Retaining all relevant documents is also important to support the evidence and
findings of the investigation, as well as to comply with the record-keeping requirements of the
relevant authorities. The other options are incorrect because:
A . Excluding any open-source information from record-keeping is not advisable, as open-source
information can provide valuable insights and context for the investigation, and may not be easily
retrievable in the future.
B . Adding all of the information the FI has about the subject, their account(s) activity, research
results, KYC information, etc. to the SAR/STR is not necessary, as the SAR/STR should only contain the
essential information that is relevant and material to the suspicious activity. Adding too much
information may obscure the main points and make the SAR/STR less effective.
D . Not documenting the investigation process if a SAR/STR is not filed is not acceptable, as the
investigation process should be documented regardless of the outcome. Documenting the
investigation process can help justify why a SAR/STR was not filed, and also provide a reference for
future investigations involving the same subject or activity.
Reference:
Advanced CAMS-FCI Certification | ACAMS
, Section 3: Reporting Suspicious Activity, page 14
Leading Complex Investigations Certificate | ACAMS
, Module 4: Documenting Your Investigation,
page 4
Question 3
Refer to the exhibit.
In a review of the account activity associated with Nadine Kien, an investigator observes a large
number of small- to medium-size deposits from numerous individuals from several different global
regions. The money is then transferred to a numbered company. Which is the next best course of
action for the investigator?
- A. Complete the monthly review and note the activity for next month's review.
- B. File a SAR/STR on the account activity in relation to a potential funnel account.
- C. Recommend the account for exit due to frequent global transactions.
- D. No further action is required as the customer is already rated at high-risk and the monthly spending is within expectations.
Answer:
B
Explanation:
The next best course of action for the investigator is to file a SAR/STR on the account activity in
relation to a potential funnel account. This is because a funnel account is a type of money laundering
scheme that involves depositing funds from multiple sources into a single account, and then
transferring them to another account, often in a different jurisdiction. A funnel account can be used
to conceal the origin, ownership, and destination of illicit funds, and to evade currency transaction
reporting requirements. The investigator should report the suspicious activity to the relevant
authorities and document the findings and actions taken. The other options are incorrect because:
A . Completing the monthly review and noting the activity for next month’s review is not sufficient,
as it delays the reporting of a possible money laundering scheme and exposes the financial
institution to regulatory and reputational risks.
C . Recommending the account for exit due to frequent global transactions is not appropriate, as it
does not address the underlying issue of potential money laundering and may alert the customer of
the investigation.
D . No further action is required as the customer is already rated at high-risk and the monthly
spending is within expectations is not acceptable, as it ignores the red flags of a funnel account and
fails to comply with the anti-money laundering obligations of the financial institution.
Reference:
Advanced CAMS-FCI Certification | ACAMS, Section 2: Investigating Financial Crimes, page 9
Leading Complex Investigations Certificate | ACAMS, Module 2: Identifying Red Flags, page 5
Question 4
Refer to the exhibit.
During a review of the accounts related to Richard Aston, an investigator notices a high number of
incoming payments from various individuals. They also notice that these incoming payments
typically occur during large sporting events or conferences. As a result of the account review, of
which illegal activity does the investigator have reasonable grounds to suspect Richard Aston?
- A. Embezzling from the hotel
- B. Aftermarket sales of entertainment admission tickets
- C. Human trafficking
- D. Sports betting
Answer:
B
Explanation:
The illegal activity that the investigator has reasonable grounds to suspect Richard Aston of is
aftermarket sales of entertainment admission tickets. This is because aftermarket sales of
entertainment admission tickets involve reselling tickets for events, concerts, festivals, etc. at a
higher price than their face value, often through online platforms or scalpers. This practice can be
illegal or unethical, depending on the jurisdiction and the terms and conditions of the original ticket
seller. The investigator should look for indicators of aftermarket sales of entertainment admission
tickets, such as high volume or frequency of incoming payments from various individuals, correlation
between incoming payments and major events or conferences, and discrepancy between the
customer’s profile and the nature of the transactions. The other options are incorrect because:
A . Embezzling from the hotel is not likely, as it would involve stealing money or property from the
hotel by an employee or a person in a position of trust. There is no evidence that Richard Aston
works for or has access to the hotel’s assets.
C . Human trafficking is not probable, as it would involve exploiting people for forced labor or
commercial sexual exploitation. There is no indication that Richard Aston is involved in any form of
human trafficking or has any connection to victims or perpetrators.
D . Sports betting is not plausible, as it would involve wagering money on the outcome of sporting
events or games. There is no sign that Richard Aston is engaged in any sports betting activity or has
any association with bookmakers or gamblers.
Reference:
Advanced CAMS-FCI Certification | ACAMS, Section 2: Investigating Financial Crimes, page 10
TicketSwap: The safest way to buy and sell tickets
Ticketing 101 | Ticketmaster
10 Types of Tickets For Events (+ Why & When To Use Them) - Eventbrite
Question 5
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 marijuan
a. 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. Review the customer's transaction history.
- B. Request information from the internet service provider who hosts the website.
- C. Check internal KYC information.
- D. Research other customer accounts for transactions to the same website.
- E. Conduct adverse media and open-source searches on the customer's background.
- F. Identify if the customer has opened accounts in an urban city area.
Answer:
A, C, E
Explanation:
The best next steps for the investigator to take are:
A . Review the customer’s transaction history. This can help the investigator identify any patterns or
anomalies in the customer’s account activity, such as changes in transaction volume, frequency,
amount, source, destination, purpose, etc. The investigator can also compare the customer’s
transaction history with their KYC profile and risk rating to assess if there are any discrepancies or
inconsistencies.
C . Check internal KYC information. This can help the investigator verify the customer’s identity,
business nature, ownership structure, expected activity, source of funds, etc. The investigator can
also update or enhance the customer’s KYC information based on any new or relevant information
obtained from other sources.
E Conduct adverse media and open-source searches on the customer’s background. This can help the
investigator find out if there is any negative or adverse information about the customer in public data
sources, such as news articles, social media posts, blogs, forums, etc. Adverse media and open-
source searches can also provide additional context and insight into the customer’s reputation,
behavior, associations, etc. The other options are incorrect because:
B . Request information from the internet service provider who hosts the website is not feasible, as it
may require a legal process or a court order to obtain such information. Moreover, the internet
service provider may not have or disclose any useful information about the website or its owner.
D . Research other customer accounts for transactions to the same website is not relevant, as it may
not provide any meaningful information about the customer under investigation. Furthermore, it
may violate the privacy and confidentiality of other customers who are not related to the
investigation.
F . Identify if the customer has opened accounts in an urban city area is not helpful, as it may not
have any bearing on the customer’s involvement in a drug or drug paraphernalia purchase.
Additionally, it may not be possible to access or verify such information without the customer’s
consent or authorization.
Reference:
Advanced CAMS-FCI Certification | ACAMS, Section 2: Investigating Financial Crimes, page 11
Leading Complex Investigations Certificate | ACAMS, Module 3: Conducting Research and Analysis,
page 6
Adverse Media Screening - Using AI to Mitigate Risk
Legal requirements for adverse media screening - Thomson Reuters
Electronic client due diligence | Ethics helpsheets | ICAEW
6AMLD & FATF: Where Adverse Media Screening Fits In
Free Adverse Media Check | NameScan
Question 6
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 marijuan
a. 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 information should be included in the SAR/STR?
- A. The customer information, including KYC background
- B. A transaction that is commensurate with the customer's background
- C. The fact that one of the transactors occasionally smelled of marijuana smoke
- D. Details of the transactor's social media accounts
Answer:
C
Explanation:
The SAR/STR should include any information that is relevant to the suspicious activity, such as the
customer information, the transaction details, and any other indicators of potential money
laundering or criminal activity. The fact that one of the transactors occasionally smelled of marijuana
smoke is an indicator that the customer may be involved in the illicit drug trade, which is a predicate
offense for money laundering. Therefore, this information should be included in the SAR/STR.
Reference: Advanced CAMS-FCI Study Guide, page 25.
Question 7
A financial institution (Fl) banks a money transmitter business (MTB) located in Miami. The MTB
regularly initiates wire transfers with the ultimate beneficiary in Cuba and legally sells travel
packages to Cub
a. The wire transfers for money remittances comply with the country's economic sanctions policies. A
Fl investigator on the sanctions team reviews each wire transfer to ensure compliance with sanctions
and to monitor transfer details.
An airline located in Cuba, unrelated to the business, legally sells airline tickets in Cuba to Cuban
citizens wanting to travel outside of Cuba. The airline tickets are purchased using Cuban currency
(CUC).
The MTB wants 100,000 USD worth of CUC. Purchasing CUC from a Cuban bank includes a 4% fee.
The MTB contacts the airline to ask if the airline will trade its CUC for USD at a lower exchange fee
than the Cuban bank. The airline agrees to a 1% fee. The MTB initiates a wire transfer to the airline
which appears as normal activity in the monitoring system because of the business' travel package
sales.
Which investigative actions should the investigator take concerning the 100.000 USD wire transfer?
(Select Three.)
- A. Review the wire transfer protocols for this customer.
- B. Gather all account activity for Fl clients that purchased packages from the airline.
- C. Review a sampling of wire transfers initiated by travel companies with Cuba travel packages.
- D. Recommend a plan for the Fl's management to restrict the account relationship.
- E. Review regulations applicable to foreign currency trading transactions.
- F. Locate and review licenses, registrations, and account operating agreements associated with the MTB account.
Answer:
A, E, F
Explanation:
The investigator should take the following investigative actions concerning the 100,000 USD wire
transfer:
Review the wire transfer protocols for this customer. This will help the investigator to determine if
the wire transfer is consistent with the customer’s normal business activity and risk profile, or if it
deviates from the established patterns or thresholds.
Review regulations applicable to foreign currency trading transactions. This will help the investigator
to assess if the wire transfer violates any laws or regulations related to currency exchange, such as
reporting requirements, licensing requirements, or sanctions compliance.
Locate and review licenses, registrations, and account operating agreements associated with the
MTB account. This will help the investigator to verify if the MTB has the necessary authorization and
documentation to conduct currency exchange transactions and if it has disclosed this activity to the
FI. Reference: Advanced CAMS-FCI Study Guide, pages 32-33.
Question 8
A financial institution (Fl) banks a money transmitter business (MTB) located in Miami. The MTB
regularly initiates wire transfers with the ultimate beneficiary in Cuba and legally sells travel
packages to Cub
a. The wire transfers for money remittances comply with the country's economic sanctions policies. A
Fl investigator on the sanctions team reviews each wire transfer to ensure compliance with sanctions
and to monitor transfer details.
An airline located in Cuba, unrelated to the business, legally sells airline tickets in Cuba to Cuban
citizens wanting to travel outside of Cuba. The airline tickets are purchased using Cuban currency
(CUC).
The MTB wants 100,000 USD worth of CUC. Purchasing CUC from a Cuban bank includes a 4% fee.
The MTB contacts the airline to ask if the airline will trade its CUC for USD at a lower exchange fee
than the Cuban bank. The airline agrees to a 1% fee. The MTB initiates a wire transfer to the airline
which appears as normal activity in the monitoring system because of the business' travel package
sales.
The investigator recommends that a SAR/STR be filed. What documentation should be referenced in
the SAR/STR filing? (Select Three.)
- A. All documents related to the agreement between the airline and the MTB
- B. Cumulative dollar amount of the wire transfer activity
- C. Airline's ticket sales and passenger list
- D. Cumulative dollar amount for transactions listing for all the MTB account's wire activity regarding travel packages
- E. Licensing information regarding the travel agency providing tourist sales to Cuba
- F. Account documentation on all related accounts maintained by the MTB
Answer:
B
Explanation:
The most likely reason for conducting a reverse transaction is to conceal or launder illicit funds. A
reverse transaction is a transaction that reverses a previous transaction, such as a refund, a
chargeback, or a cancellation. Reverse transactions can be used by money launderers to obscure the
source, ownership, or destination of funds, or to create false records or invoices. For example, a
money launderer may initiate a wire transfer from a high-risk jurisdiction to a low-risk jurisdiction,
and then reverse the transaction after receiving confirmation of the funds. This way, the money
launderer can create a paper trail that shows legitimate funds coming from a low-risk jurisdiction,
while hiding the true origin of the funds.
Reference: Advanced CAMS-FCI Study Guide, page 40-41.
Question 9
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:
1) 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
Based on the KYC profile and the transaction journal, the pattern of activity shows a deviation in:
- A. expected vs. actual activity.
- B. customer risk rating
- C. product risk rating.
- D. U.S. currency incoming vs. outgoing transaction rales.
Answer:
A
Explanation:
The correct answer is A because the expected account activities were 1 to 5 transactions per year and
around 1 million per transaction amount, but the actual activity showed much more frequent and
varied transactions in different currencies and amounts. This indicates a deviation from the
customer’s profile and risk level.
Reference: Advanced CAMS-FCI Study Guide, page 16
Question 10
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 since 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 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 a loan
Which suspicious activity should the investigator identify during the review of the loan agreements?
- A. AAA International Company Ltd.'s account has transactions in HKD and USD.
- B. Y is the authorized signatory on the beneficial ownership form.
- C. Online information found that X is the chairman of a business group of companies.
- D. Y signed on behalf of the lenders.
Answer:
D
Explanation:
The correct answer is D because it is a suspicious activity that Y, who is the authorized signatory of
the customer, also signed on behalf of the lenders. This indicates a possible conflict of interest,
collusion, or fraud. The other options are not suspicious activities based on the information given.
Reference: [Advanced CAMS-FCI Study Guide], page 17-18
Question 11
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. The bank files SARs/STRs indicating that Y opened accounts for small companies located in close proximity to the bank.
- B. 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.
- C. A review of outward remittances reveals the same pattern of several simple steps for each transaction,
- D. A review of X's personal bank account shows that X received wire transfers that aggregate the amounts transferred to the group-related companies.
Answer:
C
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.
Reference: Advanced CAMS-FCI Certification | ACAMS
Question 12
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 since 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 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:
1) 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
After reviewing the transaction journal, request for information response, and supporting
documentation, the investigator determines that additional information is needed. Which additional
information should the investigator request?
- A. Previously filed SARVSTR unrelated to the customer, but similar in content
- B. Formation document/description of the group-related companies
- C. Source of the incoming funds to the group-related companies
- D. Adverse news screening on all names listed in the formation documents
Answer:
C
Explanation:
The additional information that the investigator should request is the source of the incoming funds to
the group-related companies. This is because the customer declared that the ongoing source of
funds to this account comes from group-related companies, but the transaction journal shows that
the customer received funds from different third parties, not from group-related companies.
Therefore, the investigator should verify the relationship and legitimacy of these third parties and
their funds with the customer and the group-related companies. The other options are not relevant
or necessary for this investigation.
Reference: Advanced CAMS-FCI Certification | ACAMS
Question 13
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. Report collusion between the cryptocurrency exchange and internal staff in the internal hotline or whistle-blowing channel.
- B. Request that the relationship manager conduct a CDD refresh as it is a material trigger.
- C. Escalate to the compliance officer/money laundering reporting officer to file a SAR/STR.
- D. Contact the client directly and obtain the relevant notarized documents and information.
Answer:
C
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.
Reference:
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
Question 14
CLIENT INFORMATION FORM Client Name: ABC Tech Corp Client I.D. 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 client’s fund
Received from: Clients
Received for: Sale of digital assets
The client identified themselves as "Cryptocurrency Exchange" 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.
Investigators determine the ultimate beneficial owner of ABC Tech Corp is a high-net-worth client.
The client owns a real estate agency left to her when her spouse died. The spouse provided seed
capital for ABC Tech Corp through a direct 1,000.000 Great British Pound (GBP) deposit.
What additional information would trigger filing a SAR/STR?
- A. The client's spouse's source of wealth was a salary of 250,000 GBP per annum for the past 4 years and rental of properties of 150,000 GBP per annum for the past 6 years.
- B. The client's current net asset value is 8 million GBP, of which 7.5 million GBP was derived from the inheritance.
- C. An open-source search revealed that the client's spouse was a PEP.
- D. The funds for the seed capital were in the form of 50 cashier's checks of 10,000 GBP each and 50 money orders of 10,000 GBP.
Answer:
D
Explanation:
The additional information that would trigger filing a SAR/STR is the fact that the funds for the seed
capital were in the form of 50 cashier’s checks of 10,000 GBP each and 50 money orders of 10,000
GBP. This is because this indicates a possible attempt to avoid the reporting threshold of 10,000 GBP
for cash transactions, which is a common money laundering technique known as structuring or
smurfing12. The other options are not necessarily suspicious, as they do not involve cash
transactions or indicate any illicit source of funds. The fact that the client’s spouse was a PEP does
not automatically make the transaction suspicious unless there are other red flags or risk factors
associated with the PEP34
Reference: 1: Money Laundering Techniques 2: Structuring 3: Politically exposed person 4: PEP
Definition & Meaning - Merriam-Webster
Question 15
During transaction monitoring. Bank A learns that one of their customers. Med Supplies 123. is
attempting to make a payment via wire totaling 382,500 USD to PPE Business LLC located in Mexico
to purchase a large order of personal protective equipment. specifically surgical masks and face
shields. Upon further verification. Bank A decides to escalate and refers the case to investigators.
Bank A notes that, days prior to the above transaction, the same customer went to a Bank A location
to wire 1,215,280 USD to Breath Well LTD located in Singapore. Breath Well was acting as an
intermediary to purchase both 3-ply surgical masks and face shields from Chin
a. Bank A decided not to complete the transaction due to concerns with the involved supplier in
China. Moreover, the customer is attempting to send a third wire in the amount of 350,000 USD for
the purchase of these items, this time using a different vendor in China. The investigator must
determine next steps in the investigation and what actions, if any. should be taken against relevant
parties.
During the investigation, Bank A receives a USA PATRIOT Act Section 314(a) request related to Med
Supplies 123. Which steps should the investigator take when fulfilling the request? (Select Three.)
- A. Exit the relationship with the business since it appears that customer is under investigation.
- B. Do not respond to Financial Crimes Enforcement Network (FinCEN) if the requested information is not present in the financial institution's system of records.
- C. Review the account(s) activity and proactively file a SAR/STR using the 314(a) request as the basis for the filing.
- D. Report to Financial Crimes Enforcement Network (FinCEN) that a match was found without revealing any other details.
- E. Report back to the Financial Crimes Enforcement Network (FinCEN) within 15 days of receipt of the request via a secure internet website.
- F. Search its records expeditiously to determine whether it maintains(ed) any accounts for the subject(s) listed in the request.
Answer:
D, E, F
Explanation:
According to the FinCEN’s 314(a) Fact Sheet1, the steps that the investigator should take when
fulfilling the request are:
Search its records expeditiously to determine whether it maintains(ed) any accounts for the
subject(s) listed in the request. This is option F.
Report back to the Financial Crimes Enforcement Network (FinCEN) within 15 days of receipt of the
request via a secure internet website. This is option E.
Report to Financial Crimes Enforcement Network (FinCEN) that a match was found without revealing
any other details. This is option D.
The other options are incorrect because:
Exiting the relationship with the business since it appears that customer is under investigation is not
required by the 314(a) program and may interfere with law enforcement’s investigation. This is
option A.
Not responding to Financial Crimes Enforcement Network (FinCEN) if the requested information is
not present in the financial institution’s system of records is contrary to the 314(a) program, which
requires financial institutions to respond whether or not they have a match. This is option B.
Reviewing the account(s) activity and proactively filing a SAR/STR using the 314(a) request as the
basis for the filing is not appropriate, as the 314(a) request itself is not a sufficient reason to file a
SAR/STR. The financial institution should only file a SAR/STR if it has its own independent suspicion
of money laundering or terrorist financing. This is option C.
Reference: 1: FinCEN’s 314(a) Fact Sheet