CAMS Suspicious Activity Reporting 2

Question 1

What is 'structuring' as defined under the Bank Secrecy Act?

Accepted Answer

Breaking up transactions specifically to evade the $10,000 CTR reporting threshold, which is itself a federal crime

Answer

Structuring (or 'smurfing') involves deliberately breaking cash transactions into smaller amounts — typically below $10,000 — to avoid triggering a Currency Transaction Report, and is itself a federal crime under 31 U.S.C. § 5324.

Question 2

What is a 'continuing SAR' and when is it appropriate?

Accepted Answer

A SAR filed at 90-day intervals while suspicious activity by the same subject continues, after the initial SAR has been filed

Answer

After an initial SAR is filed, if the suspicious activity continues, institutions should file continuing SARs every 90 days until the activity ceases, maintaining the law enforcement alert.

Question 3

Which of the following would NOT typically be included in the narrative of a well-written SAR?

Accepted Answer

The institution's opinion on whether the subject is guilty of money laundering

Answer

SAR narratives should document facts (who, what, when, where, how) and explain why activity is suspicious, but should avoid legal conclusions or opinions about guilt, as that determination is for law enforcement.

Question 4

What is 'layering' in the three stages of money laundering?

Accepted Answer

The process of conducting complex transactions to distance funds from their criminal origin

Answer

Layering is the second stage of money laundering, involving complex financial transactions designed to obscure the audit trail and distance the funds from their criminal source — often through wire transfers, currency conversions, or shell companies.

Question 5

When is a financial institution NOT required to file a SAR even if it suspects illegal activity?

Accepted Answer

When the transaction is below $5,000 and involves an unknown customer

Answer

For most financial institutions, SAR filing is only required when transactions meet or exceed minimum dollar thresholds ($5,000 for banks), so transactions below this threshold involving unknown suspects may not trigger a mandatory filing obligation.

CAMS - Certified Anti-Money Laundering Specialist Certification Practice Test

CAMS - Certified Anti-Money Laundering Specialist Certification Practice Test

CAMS Suspicious Activity Reporting 2