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ACAMS CAMS-FCI - Advanced CAMS-Financial Crimes Investigations

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Total 101 questions

SAR/STR NARRATIVE

A SAR/STR has been submitted on five transactions conducted on the correspondent banking relationship with ABC Bank.

Client Information:

Remitter information: DEF Oil Resource Ltd. is the oldest member of the DEF Group. It was founded in 1977 as a general trading business with a primary focus on exports from Africa and North America. The group has business activities that span the entire energy value chain. Their core field of endeavor is centered within the oil and gas industry and its associated sub-sectors.

Beneficiary Information:

As per the response received from ABC Bank, it was determined that the beneficiaries are related to DEF Oil Resource Ltd. These were created by DEF Oil Resource Ltd. to purchase property in a foreign country on behalf of their senior management as part of a bonus scheme. The purpose behind this payment was for the purchase of property in another country.

Payment Reference:

ABCXXXXX31PZFG2H

ABCXXXXXX51PQGEH

ABCXXXXXX214QWVG

ABCXXXXXX41PSXA2

ABCXXXXXX815QWS3

Concerns:

• We are unsure about the country of incorporation of the beneficiaries.

• We are concerned about the transactional activity since the payment made towards entities (conducted on behalf of individuals) appears to be possible tax evasion.

• There appears to be an attempt to conceal the identity of individuals (senior management), which again raises concerns about the source of funds.

• Referring to the response received from ABC Bank, we are unclear about the ultimate beneficiary of funds.

• The remitter is involved in a high-risk business, (i.e., oil and crude products trading), and the beneficiary is involved in real estate business which again poses a higher risk.

While reviewing the account activity, it is noted that several transfers are sent to a company located in an offshore jurisdiction. Which step should the investigator take next?

A.

Request information from the company.

B.

File a SAR/STR to the FIU where the company is located.

C.

Request information about the beneficiaries related to the company.

D.

Conduct an open-source search to determine the ownership and registration of the company.

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.

Use data analytics to extract and analyze the linkages between the different entities.

B.

Conduct a network link analysis on all customers of the bank.

C.

Find out whether customer A has relationships with other financial institutions.

D.

Review the customer due diligence documents of each entity and examine the year of incorporation and onboarding channel.

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 an explanation of the internal process that brought the transaction to the attention of the analyst

B.

Including information about the general activity trends in the area where the suspicious transactions were conducted

C.

Including contact information for individuals at other institutions with whom correspondence has occurred

D.

Including a detailed description of the known or suspected criminal violation or suspicious activity

E.

Ensuring all information in the SAR/STR is complete and accurate based on what the institution knows

The investigations team of a financial institution (Fl) wants to perform enhanced due diligence measures on operations done by a foreign bank related to transactions of companies that export scrap gold and silver. What would be the next best steps for the investigations team? (Select Two.)

A.

Ask the legal department if it can proceed to rescind the contract of the correspondent banking relationship since the export of scrap gold and silver is a high-risk activity.

B.

Ask the respondent bank if it has a risk rating for the exporting companies, if the customer profiles are updated, and if so. when was the last time it was done.

C.

Ask the respondent bank if the exporting companies have obtained an official license that permits the exporting of scrap gold and silver.

D.

Ask the respondent bank if it can file a SAR/STR in its jurisdiction since the investigations team also plans to do the same in the Fl's home country.

E.

Ask the business manager who handles the relationship of the respondent bank if they can persuade the bank to close the accounts of the export companies.

Online payments from a customer's account to three foreign entities trigger an investigation. The investigator knows the funds originated from family real estate after an investment company approached the customer online. Funds were remitted for pre-lPO shares. Which should now occur in the investigation?

A.

Seek evidence for the customer's source of wealth.

B.

Have the relationship manager contact the customer to understand the nature of the transaction.

C.

Review the structure of the transactions to the three entities.

D.

Inspect electronic banking login records.

A SAR/STR regarding money-mule activity prompts law enforcement action. Under U.S. law, the alleged money mules can be prosecuted:

A.

only if they were aware of their role and actively participated.

B.

in a country only if funds were transferred between accounts maintained in the same country.

C.

unless they can prove they were not aware of the origin of the funds.

D.

even if they were unaware that money was transferred.

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.

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

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 dates" and "companionship."

The Fl receives a keep open' letter from LE for the identified account and agrees to keep the account open. What is the Fl required to do?

A.

Contact the client for information relating to the account.

B.

Stop filing SAR/STR reports on the account and/or customer.

C.

Ensure that the request includes an end date.

D.

Notify LE immediately after new transactions.

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.