ACAMS - Association of Certified Anti-Money Laundering Specialists Conducting Investigations Questions and Answers 1

Question 1

An AML investigator is reviewing a corporate account for a company that imports electronics. The account shows several large, round-figure wire transfers to a new supplier in a high-risk jurisdiction, which is inconsistent with the company's established payment patterns. The investigator has already reviewed all internal customer due diligence (CDD) information. What is the most appropriate next step to gather more context?

Accepted Answer

Conduct open-source intelligence (OSINT) research on the new supplier and review public records.

Answer

The most appropriate next step is to gather more information discreetly. Open-source intelligence (OSINT) allows the investigator to research the new supplier, check for adverse media, verify its business legitimacy, and look for any connections to sanctioned or high-risk entities without alerting the customer. Filing a SAR may be premature without further context. Contacting the customer could lead to tipping off, and closing the account is an action taken after a risk decision is made, not typically as an investigative step.

Question 2

During an AML investigation, a relationship manager receives an inquiry from a customer asking why a recent transaction is being delayed. Which of the following responses by the relationship manager would most likely be considered illegal 'tipping off'?

Accepted Answer

"Your transaction has been flagged by our AML system, and we must investigate it before deciding whether to report it to the authorities."

Answer

Tipping off is the act of informing a person who is the subject of a suspicious activity report (or is under investigation) in a way that could prejudice the investigation. Stating explicitly that the transaction was flagged by the AML system and that a report to authorities is being considered directly reveals the suspicion and the potential for law enforcement involvement. The other options provide plausible, non-alarming business reasons for a delay or a request for information.

Question 3

When an AML investigator concludes an investigation and decides *not* to file a Suspicious Activity Report (SAR), what is a critical component that must be included in the investigation file?

Accepted Answer

A detailed justification for the decision, including the specific factors and evidence reviewed.

Answer

Auditors and regulators will scrutinize the rationale for not filing a SAR. The investigation file must contain a clear and detailed justification explaining why the activity, although initially flagged, was determined not to be suspicious upon review. This demonstrates a sound and defensible decision-making process. While not always a strict regulatory requirement, it is a widely accepted best practice. The other options are either part of the standard customer file or are not directly relevant to documenting the conclusion of a specific investigation.

Question 4

A financial institution receives a grand jury subpoena for the financial records of one of its customers. What is the most critical action the institution must take upon receipt?

Accepted Answer

Comply with the subpoena's request for information while maintaining strict confidentiality about its existence.

Answer

A grand jury subpoena is a formal legal order that must be complied with. A critical aspect of such subpoenas is the requirement for secrecy to avoid compromising the investigation. Notifying the customer could be considered obstruction of justice. While the receipt of a subpoena should prompt a review of the customer's activity to determine if a SAR is warranted, it does not automatically require one to be filed. Freezing the account is not typically required by a subpoena alone and should only be done with a specific court order, such as a seizure warrant.

Question 5

At the conclusion of a complex money laundering investigation, the compliance officer has determined that a SAR must be filed. The investigation revealed a sophisticated network of shell companies moving funds. Which of the following is the most important element to include in the SAR narrative?

Accepted Answer

A chronological and detailed description of the suspicious activity, covering the 'who, what, where, when, and why'.

Answer

The primary purpose of the SAR narrative is to provide a clear, concise, and comprehensive account of the suspicious activity for law enforcement. Covering the 'who, what, where, when, why, and how' provides law enforcement with the actionable intelligence they need. Personal opinions are unprofessional, legal conclusions are the responsibility of law enforcement, and including non-suspicious activity clutters the report and obscures the key facts.

(ACAMS) Association of Certified Anti-Money Laundering Specialists Practice Test

(ACAMS) Association of Certified Anti-Money Laundering Specialists Practice Test

ACAMS - Association of Certified Anti-Money Laundering Specialists Conducting Investigations Questions and Answers 1