CAMS Suspicious Activity Reporting 3

Question 1

A bank employee inadvertently discloses to a customer that a SAR has been filed on their account. What is this called and what are the consequences?

Accepted Answer

Tipping off — a federal crime that can result in criminal prosecution

Answer

Disclosing a SAR filing to its subject is called 'tipping off' and is a federal crime under 31 U.S.C. § 5318(g)(2), with criminal penalties including fines and imprisonment for the employee involved.

Question 2

What is the primary use of SAR data by FinCEN?

Accepted Answer

Building financial intelligence databases used by law enforcement to investigate and prosecute money laundering, terrorism financing, and other financial crimes

Answer

FinCEN's primary use of SAR data is to maintain the BSA database that law enforcement agencies access to build cases — SARs themselves are intelligence tools, not prosecutorial evidence.

Question 3

Which of the following financial activity patterns is a classic red flag for trade-based money laundering (TBML)?

Accepted Answer

Significant over- or under-invoicing of goods in international trade transactions

Answer

Trade-based money laundering commonly involves manipulating the price, quantity, or quality of goods in international trade invoices to transfer value across borders, with over- and under-invoicing being the most common technique.

Question 4

What is 'placement' in the context of money laundering?

Accepted Answer

The first stage where illicit cash is introduced into the financial system

Answer

Placement is the first and most vulnerable stage of money laundering, where criminal proceeds (typically cash) are first introduced into the financial system through deposits, purchases, or other means.

Question 5

Under what circumstances should a financial institution file a SAR when law enforcement has asked it NOT to close a suspicious account?

Accepted Answer

The institution should still file the SAR as required and document law enforcement's request, as BSA obligations are not waived by law enforcement requests

Answer

Law enforcement may sometimes request that an institution keep a suspicious account open for investigative purposes, but this does not waive the institution's independent BSA obligation to file a SAR — both obligations can be fulfilled simultaneously.

CAMS - Certified Anti-Money Laundering Specialist Certification Practice Test

CAMS - Certified Anti-Money Laundering Specialist Certification Practice Test

CAMS Suspicious Activity Reporting 3