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Download DemoVendor: ACAMS
Certifications: CAMS Certification
Exam Code: CAMS-FCI
Exam Name: Advanced CAMS-Financial Crimes Investigations
Updated: Nov 24, 2024
Q&As: 101
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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 'care1. 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.
During the investigation, it was determined that some of the checks were issued to a mother-in-law of a PEP and deposited into her account with the Fl. This customer was not found on the Fl's PEP list How should the investigator proceed in
this situation"? (Select Two.)
A. Conduct the investigation as usual, since the activity in question is not directly connected to the PEP.
B. Reter the newly identified customers account for closure due to the high risk associated with the potential PEP.
C. Use this case as an example to train employees to recognize potential PEPs during their investigation process.
D. Send a referral to Sanctions/List Screening, or similar department/responsible individual, to ensure that the customer due diligence information is up to date.
E. File a SAR/STR due to the potential involvement of a PEP.
Correct Answer: AD
The investigator should proceed in this situation by conducting the investigation as usual, since the activity in question is not directly connected to the PEP (A) and sending a referral to Sanctions/List Screening, or similar department/
responsible individual, to ensure that the customer due diligence information is up to date (D). These actions are appropriate and prudent, as they allow the investigator to continue their analysis of the suspicious activity without being biased
by the potential PEP status of the customer's relative, and they ensure that the FI has accurate and current information about its customers and their associates. 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 "update the customer profile with any new information obtained during the investigation" (p. 25).
The other options are not correct. The investigator should not refer the newly identified customer's account for closure due to the high risk associated with the potential PEP (B), as this could be premature or disproportionate, as well as
potentially discriminatory or illegal. The investigator should not file a SAR/STR due to the potential involvement of a PEP (E), as this could also be premature or unnecessary, as well as potentially misleading or inaccurate. The investigator
should not use this case as an example to train employees to recognize potential PEPs during their investigation process ? as this could violate confidentiality or data protection laws, as well as compromise the investigation or alert the
customer or their relative of the suspicion.
References: 1: ACAMS Advanced Financial Crimes Investigations Certification Study Guide, available at ACAMS
In a SAR/STR narrative concerning Individual A. which statement indicates a product of analysis rather than a fact or judgement?
A. Individual A was the originator of nine wires totaling 225.000 USD between January and March 2020.
B. Individual A made structured cash deposits possibly to circumvent regulatory reporting requirements
C. Individual A made structured cash deposits on almost consecutive days.
D. Individual A is a college student and employed part-time at a car wash.
Correct Answer: B
A product of analysis is a conclusion or inference that is derived from facts or judgments, using analytical techniques or tools. Option B is a product of analysis because it implies that the investigator has used a tool or technique, such as a
threshold analysis, to identify a pattern of structured cash deposits that may indicate an attempt to evade reporting requirements. The other options are facts or judgments that can be verified by evidence or observation.
References: Advanced CAMS-FCI Certification Handbook, page 23.
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. Definitive proof that suspicious activity occurred
B. Enough circumstantial evidence about the suspicious activity for a criminal proceeding
C. No factual description of the suspicious activity
D. Low evidentiary threshold about the suspicious activity
Correct Answer: D
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 ...
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