ACAMS ACAMS Certifications CAMS-FCI Questions & Answers

• Question 91:

  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.

  Correct Answer: C

  The FI is required to ensure that the request includes an end date ?when it receives a keep open letter from LE for the identified account. This is because the FI has to balance its legal obligations to cooperate with LE and to protect its

  customers' privacy and rights. According to the ACAMS Advanced Financial Crimes Investigations Certification Study Guide1, "the FI should request a written confirmation from LE that includes a specific end date for the request, as well as a

  point of contact for any questions or concerns" (p.

  35). The FI should also document the request and its compliance with it, and continue to monitor the account for any suspicious activity.

  The other options are not correct. The FI should not contact the client for information relating to the account (A), as this could compromise the LE investigation or alert the client of the suspicion. The FI should not stop filing SAR/STR reports

  on the account and/or customer (B), as this could violate its regulatory obligations and expose it to legal risks. The FI should not notify LE immediately after new transactions (D), as this could also interfere with the LE investigation or tip off the

  client. The FI should follow the instructions of LE regarding when and how to share information.

• Question 92:

  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.

• Question 93:

  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. Signs of severe wear and poor maintenance at the site

  B. A site located in a commercial building

  C. Lights turned off at the site during operational hours

  D. Visible attendance with children being dropped off by parents

  E. Visible signage indicating the purpose of the building

  F. A full parking lot of cars with no staff at the site

  Correct Answer: ACF

  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

• Question 94:

  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 take to review the accounts held by the second client who is listed in the Paradise Papers? (Select Two.)

  A. Recommend a SAR/STR be filed regarding the second client's use of a questionable trust to open an account.

  B. Review all accounts being reviewed by AML investigators over the past year that have opened trust accounts.

  C. Inform Fl management of deficiencies in their AML program because the second client's activities were not detected.

  D. Monitor all accounts and entities related to the second client

  E. Inform Fl management of the start of a serious risk-based investigation that could result in losses and reputation risk.

  Correct Answer: AD

  The investigator should recommend a SAR/STR be filed regarding the second client's use of a questionable trust to open an account, as this could indicate an attempt to conceal the source and ownership of funds, and to evade taxes and sanctions. The investigator should also monitor all accounts and entities related to the second client, as they may be involved in illegal activities or pose a high risk to the FI. The investigator should not review all accounts that have opened trust accounts, as this would be too broad and inefficient. The investigator should not inform FI management of deficiencies in their AML program, as this is not their role or responsibility. The investigator should not inform FI management of the start of a serious risk-based investigation, as this may compromise the confidentiality and integrity of the investigation.

• Question 95:

  A client that runs a non-profit organization that aids refugees in leaving their home countries received a remittance from a money services business that was ten times the average. The client was recently detained for providing falsified passports to illegal immigrants. Which predicate offenses could be considered in the SAR/STR? (Select Two.)

  A. Human smuggling/trafficking

  B. Terrorist financing

  C. Narcotics trafficking

  D. Antiques smuggling

  E. Tax evasion

  Correct Answer: AB

  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.

• Question 96:

  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 marijuana. 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.

  E. Identify if the customer has opened accounts in an urban city area.

  Correct Answer: ACE

  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 and FATF: Where Adverse Media Screening Fits In Free Adverse Media Check | NameScan

• Question 97:

  An investigator receives an alert documenting a series of transactions. A limited liability corporation (LLC) wired 59.000,000 USD to an overseas account associated with a state- run oil company. A second account associated with the state-run oil company wired 600,000,000 USD to the LLC. The LLC then wired money to other accounts, a money brokerage firm, and real estate purchases.

  The investigator initiated an enhanced KYC investigation on the LLC. The financial institution opened the LLC account a couple of weeks prior to the series of transactions. The names associated with the LLC had changed multiple times since the account opened. A search of those names revealed relations with multiple LLCs. Public records about the LLCs did not show any identifiable business activities.

  Open-source research identified mixed reports about the brokerage firm. The firm indicated it purchased mutual funds for its clients and dispensed returns to clients.

  Media reports claimed the firm laundered money by holding money for a fee before returning it to investors.

  Which information should the investigator review first when examining the wire transaction documentation?

  A. The sanctions screening tool to see if the transaction was stopped

  B. Whether the wire transfers were initiated domestically

  C. The Travel Rule requirements for recordkeeping

  D. How the wire transfers were initiated (e.g., phone, online, branch visit)

  Correct Answer: D

  The investigator should review how the wire transfers were initiated first, because this could indicate the level of involvement and knowledge of the LLC account holders. If the wire transfers were initiated online or by phone, it could suggest that the account holders were trying to avoid face-to-face contact with the bank staff and reduce the chances of being questioned or identified. If the wire transfers were initiated in person at a branch, it could indicate that the account holders were confident or careless about their activities, or that they had some relationship with the bank staff. The method of initiation could also affect the quality and quantity of information collected by the bank about the wire transfers, such as the purpose, source, and destination of the funds. References: ACAMS Advanced Financial Crimes Investigations Certification Study Guide, page 65.

• Question 98:

  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 ...

• Question 99:

  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. Cash disbursements are not allowed for social welfare programs.

  C. Social welfare programs are difficult to document because the beneficiaries are from the informal sector.

  D. The entity is not implementing adequate internal controls according to what is expected, and mishandling of funds could be occurring.

  Correct Answer: D

  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.

• Question 100:

  The law enforcement agency (LEA) of a foreign jurisdiction contacts a financial institution (Fl) regarding one of the Fl's clients. The LEA advises that the client is currently wanted for prosecution as a result of a series of human trafficking charges. What should the Fl do? (Select Two.)

  A. Review the client's activity, determine if suspicious activity exists, and report accordingly.

  B. Advise the LEA that the government needs to be contacted for extradition.

  C. Comply immediately with the foreign jurisdiction and turn over all client information.

  D. Inform local LEA and regulator of the request for awareness.

  E. Close the clients accounts immediately to avoid any undue risk.

  Correct Answer: AD

  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.