ACAMS Conducting Investigations 2

Question 1

What is the primary difference between an AML investigation and a standard audit?

Accepted Answer

Investigations follow a specific suspicious transaction or pattern to determine if illegal activity occurred, while audits systematically evaluate the overall effectiveness of AML controls

Answer

An AML investigation is triggered by specific suspicious activity and aims to determine whether money laundering or financial crime occurred, while an AML audit systematically evaluates the overall design and effectiveness of the institution's AML compliance program.

Question 2

What information should be gathered during the initial stage of an AML investigation triggered by a transaction monitoring alert?

Accepted Answer

Customer identity information, account history, related party information, transaction patterns, and any prior SAR or alert history

Answer

A thorough AML investigation requires gathering comprehensive information from multiple sources: customer identity and KYC file, full account and transaction history, related party connections, prior alert/SAR history, and external sources such as public records and adverse media.

Question 3

What does the legal term 'tipping off' mean in the AML context, and what is its consequence?

Accepted Answer

Disclosing to a subject that a SAR has been filed or is being considered about them; it is a federal crime under 31 USC 5318(g)(2)

Answer

Tipping off is the illegal act of notifying a customer or any person that they are the subject of a SAR investigation. Under 31 USC 5318(g)(2), tipping off is a federal crime that can result in imprisonment and fines.

Question 4

When conducting an AML investigation, how should investigators handle 'link analysis'?

Accepted Answer

Link analysis maps the connections between accounts, individuals, entities, and transactions to identify networks of related parties and hidden relationships that may indicate coordinated money laundering

Answer

Link analysis in AML investigations involves visually mapping and analyzing connections between accounts, people, businesses, transactions, and addresses to uncover networks of related parties potentially engaged in coordinated financial crime.

Question 5

What is the role of the 'BSA Officer' (BSAO) in an AML investigation?

Accepted Answer

The BSAO oversees the AML compliance program and typically makes or approves final SAR filing decisions, ensuring investigations are thorough and documented

Answer

The BSA Officer (also called the AML Compliance Officer) is responsible for overseeing the AML program, which includes ensuring investigations are properly conducted, documented, and that SAR filing decisions are sound and well-supported.

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

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

ACAMS Conducting Investigations 2