Conducting Investigations Flashcards
6 cards from real ACAMS practice questions. Tap to flip, then mark Knew It or Still Learning — missed cards come back until you master them.
Read the first 6 Conducting Investigations flashcards as text
What is a '314(b) information sharing request' and how does it support AML investigations?
Answer: A voluntary program under the USA PATRIOT Act allowing financial institutions to share information with each other about potential money laundering or terrorist financing activity
Section 314(b) of the USA PATRIOT Act created a voluntary information-sharing program allowing financial institutions that have registered with FinCEN to share information with each other about individuals, entities, and transactions suspected of money laundering or terrorist financing.
What is the significance of 'SAR continuations' (continuing activity SARs)?
Answer: SARs filed to report that suspicious activity previously reported is continuing, typically filed every 90 days as long as the suspicious activity persists
Continuing activity SARs are filed approximately every 90 days to report that suspicious activity that was the subject of a prior SAR is still occurring. They maintain a current record with FinCEN and help law enforcement track ongoing criminal activity.
What role does 'adverse media screening' play in an AML investigation?
Answer: It searches news databases and other public sources for negative information about a customer that may indicate financial crime, corruption, or sanctions exposure
Adverse media screening (also called negative news screening) searches public sources — news articles, court records, regulatory actions — for information that might indicate a customer poses elevated AML, sanctions, or reputational risk.
What is the purpose of an 'exit interview' when closing an account due to suspicious activity?
Answer: There should be no exit interview — institutions should close the account without indicating that suspicious activity concerns are the reason, to avoid tipping off the customer
Institutions closing accounts due to suspicious activity must not reveal that AML concerns are the reason, as this would constitute tipping off under 31 USC 5318(g)(2). Account closures are typically handled without detailed explanation to avoid alerting the subject.
What is the '60-day rule' for SAR filing?
Answer: SARs must be filed no later than 60 days after the date the financial institution initially detected the suspicious activity, with an option for an additional 30 days if needed to identify a subject
Under BSA regulations, SARs must generally be filed within 30 days of initial detection of suspicious activity. If additional time is needed to identify the subject involved, an extension of up to 60 days from initial detection is permitted, for a maximum of 60 days total.
What is a 'law enforcement freeze request' and how must financial institutions respond?
Answer: A request from law enforcement asking a financial institution to maintain an account and not alert the customer while an investigation is ongoing, typically supported by legal process such as a court order
Law enforcement may request that financial institutions keep suspicious accounts open and operational during ongoing investigations, supported by legal process, so that investigators can gather additional evidence while the subjects remain unaware.