ACAMS CAMS-FCI Dumps

The investigator should determine that a nephew of the general (Bank A’s customer) should be flagged as a senior PEP ©. This is because the nephew is related to a senior military official who is a customer of Bank A, which is a high-risk jurisdiction with strict capital controls. According to the ACAMS Advanced Financial Crimes Investigations Certification Study Guide1, “the FI should identify and flag any customers who are PEPs or have close associations with PEPs, such as family members or business partners” (p. 24). The FI should also conduct enhanced due diligence on these customers and monitor their transactions for any suspicious or unusual activity.

The other options are not correct. The investigator should not determine that a nephew of the general should be treated well to avoid reputational damage to the bank (A), as this could compromise the integrity and objectivity of the investigation, as well as expose the bank to legal or regulatory risks. The investigator should not determine that a nephew of the general is a high-net-worth individual (B), as this is not relevant or material to the investigation, as the nephew’s wealth does not affect his potential PEP status or risk level. The investigator should not determine that a nephew of the general is a trustworthy source (D), as this could be biased or inaccurate, as the nephew’s trustworthiness does not depend on his relation to the general or his involvement in the transaction.

References: 1: ACAMS Advanced Financial Crimes Investigations Certification Study Guide, available at ACAMS

The correct answer is C because reviewing the structure of the transactions to the three entities can help the investigator to identify any red flags or indicators of fraud, such as unusual amounts, frequency, destinations, or beneficiaries. The other options are not as relevant or effective in this scenario. Option A is not necessary because the investigator already knows the source of funds for the customer. Option B is not advisable because contacting the customer directly may alert them to the investigation and compromise its integrity. Option D is not helpful because inspecting electronic banking login records does not provide any information about the nature or purpose of the transactions.

References:

• Advanced CAMS-FCI Study Guide, page 281
• Financial Crime Typologies - Intermediate Certificate Course, Module 32

The first valid step in the Mutual Legal Assistance Treaty (MLAT) international cooperation process is for the central authority of the requesting country to send a letter of request to the central authority of the other country. The letter of request should provide a summary of the facts and information required, the reasons for the request, and any specific legal or procedural requirements that need to be met. (CAMS Manual, 6th Edition, Page 233).

The correct answer is A because this scenario describes a possible case of ticket laundering, which is a form of money laundering where criminals use gambling tickets to disguise the source of their illicit funds. The customers who deposit the tickets are either complicit or unaware of the scheme, and they receive a commission or a fee for their service. The other options are not likely because they do not explain why the customers would deposit multiple tickets from the same gambling company and withdraw cash the next day.

References: : Ticket Laundering: A Money Laundering Method

The Asian/Pacific Financial Action Task Force-Style Regional Body (APG) helps its members implement recommendations from the FATF by facilitating the adoption and implementation of internationally accepted AML measures by member jurisdictions (CAMS Manual, 6th Edition, Page 22). The APG also encourages cooperative AML efforts in the region, which can include information-sharing and mutual evaluations to assess member compliance with FATF recommendations (CAMS Manual, 6th Edition, Page 25). Therefore, options C and D are the correct answers.

According to the Certified Anti-Money Laundering Specialist (CAMS) study guide, 6th edition, page 105, the correct answer is C. It can be difficult to determine if there is negative media associated with counterparties solely from the customer's account activity and KYC file.

The study guide explains that negative media can include news articles, government sanctions lists, and other sources of public information that may indicate that a counterparty is involved in illicit activities. However, this information may not be readily available in a customer's account activity or KYC file, and may require additional research or investigation.

This information can be found in the Certified Anti-Money Laundering Specialist (CAMS) study guide, 6th edition, under the section on Unusual Customer Identification Scenarios. The guide explains that two indicators that should be included in awareness training for unusual customer identification scenarios are:

A. The customer opens the account in the name of a family member who begins making large deposits.

This is an indicator of potential structuring, where a customer may be attempting to avoid triggering reporting thresholds by depositing funds in smaller amounts over time. It is important for staff to be aware of this scenario and to monitor accounts for potential suspicious activity.

B. The customer's name and home address cannot be verified.

This is an indicator of potential identity theft or other fraudulent activity. If a customer's identifying information cannot be verified, it is important for staff to conduct additional due diligence to ensure that the customer is legitimate and that the account is not being used for illicit purposes.

The best next step in the investigation is to check the jurisdiction’s list of known charities with connections to terrorist activity ©. This is because the FI has a responsibility to verify the legitimacy and reputation of the beneficiary of the funds, especially if it is a charity or non-profit organization that operates in a high-risk jurisdiction or sector. 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 check if the beneficiary is consistent with the customer’s profile and expected activity.

The other options are not as appropriate or effective as option C. Contacting the financial institution in Turkey that has a relationship with Forever Free and advising them of the investigation (A) could violate confidentiality or data protection laws, as well as compromise the investigation or alert the customer or beneficiary of the suspicion. Updating the customer profile to include Forever Free as the recipient of the funds (B) could be premature or inaccurate, as it does not verify the nature and purpose of the transfer or the identity and legitimacy of the beneficiary. Filing a SAR/STR with the new information learned about the beneficiary (D) could also be premature or incomplete, as it does not confirm if there is any suspicious or criminal activity involved in the transfer or if there are any other red flags or indicators.

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.

References: 1: FinCEN’s 314(a) Fact Sheet

The correct answers are B and C because these are the most relevant and reasonable steps for the investigations team to perform enhanced due diligence on the operations of the foreign bank and its customers. Asking for the risk rating, customer profiles, and official licenses would help the team assess the level of risk and compliance of the foreign bank and its customers, who are engaged in a high-risk activity of exporting scrap gold and silver. The other options are not appropriate because they are either premature or ineffective. Rescinding the contract, filing a SAR/STR, or closing the accounts would require more evidence and justification, and they may also damage the relationship with the foreign bank.

References: : Precious Metals & Stones

The purchase of airplane tickets after receiving multiple small deposits from a crowdfunding platform might suggest that the funds are being used to facilitate travel for terrorist purposes. The other options are not necessarily indicative of terrorist financing, as they could be explained by legitimate reasons or other types of financial crimes.

A more robust supervisory approach is needed by regulators when overseeing small- and medium-sized MSBs compared to larger MSBs for combatting TF because small- and medium-sized MSBs are more at risk of allowing transactions linked to TF due to the lack of skilled compliance resources. Small- and medium-sized MSBs may face challenges in implementing effective AML/CFT controls, such as conducting risk assessments, applying customer due diligence measures, monitoring transactions, detecting suspicious activities, and reporting to the authorities. They may also have limited access to training, guidance, and tools to enhance their compliance capabilities. Therefore, regulators need to provide more supervision and support to small- and medium-sized MSBs to ensure that they comply with the AML/CFT requirements and mitigate the TF risks.

References:

• Sustainable Growth for Small and Medium-Sized Enterprises … - MDPI
• Lessons on Resilience for Small and Midsize Businesses - HBR

A country that does not have strong predicate offenses and is lax in prosecuting AML cases could suffer increased organized crime and corruption as a social/economic consequence. "Weaknesses in the AML/CFT regime can lead to a range of economic and social consequences, including...increased crime and corruption." (CAMS Manual, 6th Edition, page 32)

The primary purposes of Financial Action Task Force (FATF)-Style Regional Bodies are to promote effective implementation of FATF recommendations and to provide expertise and input in FATF policy-making. (CAMS Manual, 6th Edition, Page 180)

According to the Certified Anti-Money Laundering Specialist (the 6th edition), the financial institution (Fl) should take the following actions:

A. Review the client's activity, determine if suspicious activity exists, and report accordingly. The Fl should assess the risk of the situation and determine if there is any suspicious activity that needs to be reported to the appropriate authorities. This would involve conducting a review of the client's account activity and transactions to determine if there are any indicators of money laundering or terrorist financing.

D. Inform local LEA and regulator of the request for awareness. The Fl should inform the local law enforcement agency and regulator of the request from the foreign jurisdiction to raise awareness of the situation and determine if any further actions need to be taken.

According to the CAMS study guide, the Financial Action Task Force (FATF) Regional Style Bodies are organizations created by the FATF to promote the implementation of anti-money laundering and countering the financing of terrorism (AML/CFT) measures in specific regions. One of the key characteristics of these bodies is the implementation of regional mutual evaluation procedures.

Regional mutual evaluations involve member countries evaluating each other's AML/CFT regimes to identify strengths and weaknesses and to develop best practices for improvement. This process allows for greater cooperation between countries and can help to identify and address regional AML/CFT risks more effectively. It also promotes consistency in AML/CFT standards and practices within the region.

According to the CAMS manual 6th edition, the USA PATRIOT Act allows the US government to subpoena documents from foreign financial institutions (FIs) that have no presence in the US (option B). The manual states that "The USA PATRIOT Act provides US law enforcement agencies with the power to subpoena documents from foreign banks that maintain correspondent accounts with US banks or have no presence in the United States" (p. 77).

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.

References: Advanced CAMS-FCI Study Guide, page 16

Compare customer and transaction records against periodically updated sanctions lists provided by governmental bodies. This is stated in the Certified Anti-Money Laundering Specialist (the 6th edition) manual on page 595, which states: “Sanctions screening requirements include that a financial institution should compare customer and transaction records against periodically updated sanctions lists provided by governmental bodies.”

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:

The correct answer is A and B because human smuggling/trafficking and terrorist financing are both predicate offenses for money laundering that could be related to the client’s activities. Option C is incorrect because there is no indication of narcotics trafficking in the scenario. Option D is incorrect because there is no indication of antiques smuggling in the scenario. Option E is incorrect because there is no indication of tax evasion in the scenario.

References: Advanced CAMS-FCI Certification Handbook, page 10; Financial Crime Typologies - Intermediate Certificate, Module 2.

The FIU should cross-reference the databases of international commerce/logistics transactions between the country and WMD proliferation sanctioned states with the corresponding international financial operations of those transactions, as this would help identify any discrepancies or anomalies that could indicate sanctions evasion. The FIU should also evaluate a sample of the amount of false-positive and false-negative alerts that FIs have regarding proliferation sanctions evasion to determine root causes of non-detection, such as inadequate screening systems, lack of training, or human error. These actions would help the FIU assess the proliferation financing risk and provide feedback and guidance to FIs on how to improve their detection and prevention capabilities.

References: Advanced CAMS-FCI Study Guide, page 32-33; [FATF Guidance on Counter Proliferation Financing], page 15-16.

The correct answer is C because the FI is unable to obtain evidence of required licensing or registration despite suspicion of money transmitting, which is a red flag for money laundering and a violation of federal and state laws. Option A is incorrect because making several deposits in one month that appear to exceed their expected monthly income might not be indicative of suspicious activity, depending on the customer’s profile and source of funds. Option B is incorrect because receiving a large, one-time wire from a law firm might not be indicative of suspicious activity, depending on the customer’s relationship with the law firm and the purpose of the wire. Option D is incorrect because discovering a large number of securities transactions that appear to be related to day trading might not be indicative of suspicious activity, depending on the customer’s investment strategy and risk tolerance.

References: Money transmitter - Wikipedia; The Quick Guide To Money Transmitter Licenses - Surety Bond Insider; Financial Crime Typologies - Intermediate Certificate, Module 3.

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.

References: [Advanced CAMS-FCI Study Guide], page 17-18

The best reason the EU bank should file a SAR/STR is that the events raise concerns that the payment represents proceeds from illegal wildlife trade, which is a serious financial crime and a predicate offense for money laundering in many jurisdictions3. The fact that the incoming funds came from pet stores, breeders, and private individuals suggests that the import company may be involved in smuggling or trafficking endangered or protected animals or their parts4. The outgoing wires to Indonesia and Uganda, which are known source countries for wildlife trafficking, may indicate payments to suppliers or facilitators of this illicit activity.

References: 3: Financial Action Task Force Report on Money Laundering from the Illegal Wildlife Trade, page 9 4: Financial Crime Typologies - Intermediate, page 18 : [World Wildlife Crime Report], page 16

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.

References:

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

Weaker cybersecurity controls are a main vulnerability that has led to an increase in ransomware attacks on small businesses, as they make them easier targets for cybercriminals who can exploit their systems and demand payment for restoring access to their data. The other options are not relevant to the vulnerability, as they relate to the consequences or responses of the victims.

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 …

Financial institutions should perform the following actions to ensure proper data governance:

Establish an appropriate data management method for collecting and storing information. This is important to ensure that the data is consistent, reliable, and accessible for various purposes, such as risk assessment, compliance reporting, and customer service. Data management methods may include defining data standards, policies, and procedures; implementing data quality controls and validation checks; and using appropriate data storage systems and formats.

Ensure the accuracy of customer identification records and transaction records and appropriately manage data as a prerequisite for the effective use of IT systems. This is important to comply with the anti-money laundering and counter-terrorist financing (AML/CFT) requirements, such as customer due diligence, transaction monitoring, and suspicious activity reporting. Accurate and complete customer and transaction data also enables financial institutions to use IT systems more effectively for data analysis, risk management, and decision making.

Periodically validate integrity and accuracy of information used for IT systems such as customer information, customer identification records, and transaction records. This is important to ensure that the data remains up-to-date, relevant, and reliable over time. Data validation may include verifying the source and quality of the data; identifying and correcting any errors or inconsistencies; and updating or deleting any obsolete or redundant data.

References:

• Data Governance for Financial Institutions - Capgemini
• Small and Medium-Sized Deposit-Taking Institutions (SMSBs) Capital and Liquidity Requirements - OSFI