Question 1
Multiple choice
The law enforcement agency (LEA) of a foreign jurisdiction contacts a financial institution (Fl) regarding one of the Fl's clients. The LEA advises that the client is currently wanted for prosecution as a result of a series of human trafficking charges. What should the Fl do? (Select Two.)
-
A
Review the client's activity, determine if suspicious activity exists, and report accordingly.
-
B
Advise the LEA that the government needs to be contacted for extradition.
-
C
Comply immediately with the foreign jurisdiction and turn over all client information.
-
D
Inform local LEA and regulator of the request for awareness.
-
E
Close the clients accounts immediately to avoid any undue risk.
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Close answer details
Correct answersA, D
ExplanationAccording to the Certified Anti-Money Laundering Specialist (the 6th edition), the financial institution (Fl) should take the following actions:
A. Review the client's activity, determine if suspicious activity exists, and report accordingly. The Fl should
assess the risk of the situation and determine if there is any suspicious activity that needs to be reported to the appropriate authorities. This would involve conducting a review of the client's account activity and transactions to determine if there are any indicators of money laundering or terrorist financing. D. Inform local LEA and regulator of the request for awareness. The Fl should inform the local law enforcement agency and regulator of the request from the foreign jurisdiction to raise awareness of the situation and determine if any further actions need to be taken.
Which reputations risk consequence could a financial entity face for violating AML laws?
-
A
Loss of high-profile customers
-
B
-
C
Increased audit costs to monitor behavior
-
D
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Correct answerD
ExplanationAccording to the Certified Anti-Money Laundering Specialist (CAMS) Manual [1], 6th edition, financial entities that violate Anti-Money Laundering (AML) laws can face several reputational risks such as loss of high-profile customers, seizure of assets, increased audit costs to monitor behavior, and monetary penalties. For example, the US Treasury's Financial Crimes Enforcement Network (FinCEN) imposes civil money penalties on "persons who willfully violate, attempt to violate, conspire to violate, or cause any violation of any provision of the Bank Secrecy Act or its implementing regulations." (CAMS Manual, 6th edition, page 26).
Which information is it best practice to share at the very beginning of a well-written SAR/STR narrative?
-
A
A specific description of the involved accounts and transactions, including the origination and application of funds
-
B
The purpose of the SAR/STR narrative and a general description of the known or alleged violation
-
C
Information about any follow-up actions conducted by the financial institution on the account
-
D
Any and all relevant facts about the parties who facilitated the suspicious activity or transactions
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Close answer details
Correct answerB
ExplanationThe best information to share at the very beginning of a well-written SAR/STR narrative is the purpose of the SAR/STR narrative and a general description of the known or alleged violation. This is because this information provides an overview of why the SAR/STR is being filed and what type of suspicious activity or transaction is involved. It also helps to capture the attention of the reader and set the tone for the rest of the narrative.
References:
Reporting Suspicious Activity Certificate, Module 4, page 7.
Sanctions screening requirements include that a financial institution should:
-
A
report an individual whose name appears on a sanctions list to the police.
-
B
immediately freeze the bank account of an individual that appears on a sanctions list.
-
C
compare customer and transaction records against periodically updated sanctions lists provided by governmental bodies.
-
D
immediately close the bank account of an entity who appears on a sanctions list.
Reveal answer details
Close answer details
Correct answerC
ExplanationCompare customer and transaction records against periodically updated sanctions lists provided by governmental bodies. This is stated in the Certified Anti-Money Laundering Specialist (the 6th edition) manual on page 595, which states: "Sanctions screening requirements include that a financial institution should compare customer and transaction records against periodically updated sanctions lists provided by governmental bodies."
CLIENT INFORMATION FORM Client Name: ABC Tech Corp Client ID. Number: 08125 Name: ABC Tech Corp Registered Address: Mumbai, India Work Address: Mumbai, India Cell Phone: "*?quot;"; Alt
Phone:";"";* Email: ......."; Client Profile Information: Sector: Financial Engaged in business from (date): 02 Jan 2020 Sub-sector: Software-Cryptocurrency Exchange Expected Annual Transaction Amount: 125,000 USD Payment Nature: Transfer received from clients' fund Received from: Clients Received for: Sale of digital assets The client identified itself as Xryptocurrency Exchange." The client has submitted the limited liability partnership deed. However, the bank's auditing team is unable to identify the client's exact business profile as the cryptocurrency exchange specified by the client as their major business awaits clearance from the country's regulator. The client has submitted documents/communications exchanged with the regulator and has cited the lack of governing laws in the country of their operation as the reason for the delay. During the financial crime investigation, the investigator discovers that some of the customer due diligence (CDD) documents submitted by the client were fraudulent. The investigator also finds that some of the information in the financial institution's information depository is false. What should the financial crime investigator do next?
-
A
Report collusion between the cryptocurrency exchange and internal staff in the internal hotline or whistle-blowing channel.
-
B
Request that the relationship manager conduct a CDD refresh as it is a material trigger.
-
C
Escalate to the compliance officer/money laundering reporting officer to file a SAR/STR.
-
D
Contact the client directly and obtain the relevant notarized documents and information.
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Close answer details
Correct answerC
ExplanationThe correct answer is C. Escalate to the compliance officer/money laundering reporting officer to file a SAR/STR. This is because the financial crime investigator has found evidence of fraudulent documents and false information, which indicate a high risk of money laundering or other financial crimes. The investigator should not contact the client directly, as this may tip them off or compromise the investigation.
The investigator should also not report collusion between the cryptocurrency exchange and internal staff, as this is an assumption that has not been verified. The investigator should not request a CDD refresh, as this is not sufficient to address the serious issues identified.
References:
Advanced CAMS-FCI Study Guide, page 291 Advanced CAMS-FCI Study Guide, page 311 Advanced CAMS-FCI Study Guide, page 331 1: (https://www.acams.org/en/certifications/advanced-cams/advanced-financial-crimes-investigations)
Question 6
Multiple choice
During transaction monitoring. Bank A learns that one of its customers. Med Supplies 123, is attempting to make a payment via wire totaling 382.500 USD to PPE Business LLC located in Mexico to purchase a large order of personal protective equipment. specifically surgical masks and face shields. Upon further verification. Bank A decides to escalate and refers the case to investigators. Bank A notes that days prior to the above transaction, the same customer went to a Bank A location to wire 1,215,280 USD to Breath Well LTD located in Singapore. Breath Well was acting as an intermediary to purchase both 3-ply surgical masks and face shields from China. Bank A decided not to complete the transaction due to concerns with the involved supplier in China. Moreover, the customer is attempting to send a third wire in the amount of 350,000 USD for the purchase of these items, this time using a different vendor in China. The investigator must determine the next steps in the investigation and what actions, if any. should be taken against relevant parties. The investigator is gathering more information to determine if a SAR/STR filing is needed. Which steps are the correct ways of collecting the additional information? (Select Two.)
-
A
Reach out to the relationship manager asking if more up-to-date customer due diligence information can be collected on the customer.
-
B
Use available documentation received from law enforcement (e.g.. grand jury subpoena) as red flags in
SAR/STR filing.
-
C
Reach out to the customer and ask for supporting documentation for the conducted wires to avoid
SAR/STR filing.
-
D
Conduct open-source research to determine if the customer and involved counterparties are in the same business field.
-
E
Issue a USA PATRIOT ACT Section 314(b) request to participating financial institutions advising that information is needed to decide if the activity is suspicious.
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Close answer details
Correct answersA, D
ExplanationThe correct answer is A and C because these indicators suggest that the customer is using fraudulent documents and misrepresenting the goods to conceal the illicit nature of the transactions. Fentanyl traffickers often use front companies and falsified invoices to disguise their shipments as legitimate products, such as medical supplies or chemicals. Reviewing the invoices and transportation documents, as well as the FDA product certifications, can help to identify discrepancies or anomalies that indicate fraud or deception.
References:
Fentanyl and Fentanyl Analogues: Federal Trends and Trafficking Patterns, page 18
Fentanyl
Trafficking Offenses, page 2.
A client at a financial institution deposits large amounts of money into an account, and almost immediately, the funds are then distributed to numerous individuals' accounts. The transaction activity described in the scenario is a pattern of:
-
A
-
B
-
C
-
D
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Correct answerB
ExplanationDeposit trading is a pattern of suspicious activity where a client deposits large amounts of money into an account, and then transfers the funds to other accounts, often in different jurisdictions or countries. This could be an attempt to disguise the source or destination of the funds, or to avoid reporting requirements.
Deposit trading is also known as layering, which is the second stage of money laundering.
References:
ACAMS Advanced Financial Crimes Investigations Certification Study Guide, page 43
ACAMS Glossary,
page 34.
Question 8
Multiple choice
A SAR/STR on cash activity is filed for a company registered in the Marshall Islands operating a Mediterranean beach bar and hotel. The company has three nominee directors, one nominee shareholder, and another individual declared as both the beneficial owner and authorized signatory. Which information is key for law enforcement's physical surveillance of cash activity? (Select Two.)
-
A
The identification details o' the nominee shareholder
-
B
The company's operating address
-
C
The identification details of the beneficial owner and authorized signatory
-
D
The company's registered address
-
E
The identification details the nominee directors
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Close answer details
Correct answersB, C
ExplanationThe identification details of the beneficial owner and authorized signatory are key for law enforcement's physical surveillance of cash activity, as they would help identify the person who controls and operates the company and who is responsible for its financial transactions. The company's operating address is also key, as it would help locate the premises where the cash activity takes place and observe any suspicious movements or behaviors. The identification details of the nominee shareholder and directors are not relevant, as they are not involved in the management or operation of the company. The company's registered address is also not relevant, as it is likely to be a shell or mailbox address that does not reflect the actual location of the business.
References:
Advanced CAMS-FCI Study Guide, page 44-45
[FATF
Guidance on Transparency and Beneficial Ownership], page 12-13.
An investigator at a corporate bank is conducting transaction monitoring alerts clearance. KYC profile background: An entity customer, doing business offshore in Hong Kong, established a banking business relationship with the bank in 2017 for deposit and loan purposes. It acts as an offshore investment holding company. The customer declared that the ongoing source of funds to this account comes from group-related companies. 1. X is the UBO. and owns 97% shares of this entity customer;
2. Y is the authorized signatory of this entity customer. This entity customer was previously the subject of a SAR/STR. KYC PROFILE Customer Name: AAA International Company. Ltd Customer ID: 123456 Account Opened: June 2017 Last KYC review date: 15 Nov 2020 Country and Year of Incorporation: The British Virgin Islands, May 2017 AML risk level: High Account opening and purpose: Deposits, Loans and Trade Finance Anticipated account activities: 1 to 5 transactions per year and around 1 million per transaction amount During the investigation, the investigator reviewed remittance transactions activities for the period from Jul 2019 to Sep 2021 and noted the following transactions pattern: TRANSACTION JOURNAL Review dates: from July 2019 to Sept 2021 For Hong Kong Dollars (HKD) currency: Incoming transactions: 2 inward remittances of around 1.88 million HKD in total from different third parties Outgoing transactions: 24 outward remittances of around 9 4 million HKD in total to different third parties For United States Dollars (USD) currency: Incoming transactions: 13 inward remittances of around 3.3 million USD in total from different third parties Outgoing transactions: 10 outward remittances of around 9.4 million USD in total to different third parties. RFI Information and Supporting documents: According to the RFI reply received on 26 May 2021, the customer provided the bank with the information below: 1. All incoming funds received in HKD & USD currencies were monies lent from non-customers of the
bank. Copies of loan agreements had been provided as supporting documents. All of the loan agreements were in the same format and all the lenders are engaged in trading business.
2. Some loan agreements were signed among four parties, including among lenders. borrower (the bank's customer), guarantor, and guardian with supplemental agreements, which stated that the customer, as a borrower, who failed to repay the loan Based on the KYC profile and the transaction journal, the pattern of activity shows a deviation in:
-
A
expected vs. actual activity.
-
B
-
C
-
D
U.S. currency incoming vs. outgoing transaction rales.
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Close answer details
Correct answerA
ExplanationThe correct answer is A because the expected account activities were 1 to 5 transactions per year and around 1 million per transaction amount, but the actual activity showed much more frequent and varied transactions in different currencies and amounts. This indicates a deviation from the customer's profile and risk level.
References:
Advanced CAMS-FCI Study Guide, page 16
Question 10
Multiple choice
A client with many personal and business deposits with the financial institution (Fl) seeks a business loan.
The client wants to guarantee the loan with a trust for which they are the beneficiary. An investigator examines the trust. The trust has many layers, including shell companies in known tax havens. The client's ultimate beneficial ownership claim cannot be validated, and the loan is denied. Two months later, the Fl receives a law enforcement (LE) request on one of the client's business accounts.
While reviewing the business account, the Fl receives another LE request on the same account from another agency. The requested information is shared. Three months later, a branch manager receives a request to open a business deposit account related to a complex trust. The manager forwarded the request because of the complexity. The trust was the same as the previously examined trust, but the request came from a different client. The second client also has many accounts with the Fl. Further inspection finds links between the second client and the Paradise Papers. The Papers state the client led illegal activities and committed tax evasion. What steps should the investigator take to review the accounts held by the second client who is listed in the Paradise Papers? (Select Two.)
-
A
Recommend a SAR/STR be filed regarding the second client's use of a questionable trust to open an account.
-
B
Review all accounts being reviewed by AML investigators over the past year that have opened trust accounts.
-
C
Inform Fl management of deficiencies in their AML program because the second client's activities were not detected.
-
D
Monitor all accounts and entities related to the second client
-
E
Inform Fl management of the start of a serious risk-based investigation that could result in losses and reputation risk.
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Close answer details
Correct answersA, D
ExplanationThe investigator should recommend a SAR/STR be filed regarding the second client's use of a questionable trust to open an account, as this could indicate an attempt to conceal the source and ownership of funds, and to evade taxes and sanctions. The investigator should also monitor all accounts and entities related to the second client, as they may be involved in illegal activities or pose a high risk to the FI. The investigator should not review all accounts that have opened trust accounts, as this would be too broad and inefficient. The investigator should not inform FI management of deficiencies in their AML program, as this is not their role or responsibility. The investigator should not inform FI management of the start of a serious risk-based investigation, as this may compromise the confidentiality and integrity of the investigation.
Question 11
Single choice
Which might suggest misuse of crowdfunding resources by a terrorist?
-
A
A small charge at a gas station followed by a large charge at an electronics store
-
B
A large deposit followed by multiple charges at a sporting goods store
-
C
Multiple small deposits followed by a wire transfer to a large well-known international charity
-
D
Multiple small deposits followed by the purchase of airplane tickets >
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Close answer details
Correct answerD
ExplanationThe purchase of airplane tickets after receiving multiple small deposits from a crowdfunding platform might suggest that the funds are being used to facilitate travel for terrorist purposes. The other options are not necessarily indicative of terrorist financing, as they could be explained by legitimate reasons or other types of financial crimes.
Question 12
Multiple choice
A financial institution (Fl) banks a money transmitter business (MTB) located in Miami. The MTB regularly initiates wire transfers with the ultimate beneficiary in Cuba and legally sells travel packages to Cuba. The wire transfers for money remittances comply with the country's economic sanctions policies. A Fl investigator on the sanctions team reviews each wire transfer to ensure compliance with sanctions and to monitor transfer details. An airline located in Cuba, unrelated to the business, legally sells airline tickets in Cuba to Cuban citizens wanting to travel outside of Cuba. The airline tickets are purchased using Cuban currency (CUC). The MTB wants 100,000 USD worth of CUC. Purchasing CUC from a Cuban bank includes a 4% fee. The MTB contacts the airline to ask if the airline will trade its CUC for USD at a lower exchange fee than the Cuban bank. The airline agrees to a 1% fee. The MTB initiates a wire transfer to the airline which appears as normal activity in the monitoring system because of the business' travel package sales. Which investigative actions should the investigator take concerning the 100.000 USD wire transfer? (Select Three.)
-
A
Review the wire transfer protocols for this customer.
-
B
Gather all account activity for Fl clients that purchased packages from the airline.
-
C
Review a sampling of wire transfers initiated by travel companies with Cuba travel packages.
-
D
Recommend a plan for the Fl's management to restrict the account relationship.
-
E
Review regulations applicable to foreign currency trading transactions.
-
F
Locate and review licenses, registrations, and account operating agreements associated with the MTB account.
Reveal answer details
Close answer details
Correct answersA, E, F
ExplanationThe investigator should take the following investigative actions concerning the 100,000 USD wire transfer: Review the wire transfer protocols for this customer. This will help the investigator to determine if the wire transfer is consistent with the customer's normal business activity and risk profile, or if it deviates from the established patterns or thresholds. Review regulations applicable to foreign currency trading transactions.
This will help the investigator to assess if the wire transfer violates any laws or regulations related to currency exchange, such as reporting requirements, licensing requirements, or sanctions compliance.
Locate and review licenses, registrations, and account operating agreements associated with the MTB account. This will help the investigator to verify if the MTB has the necessary authorization and documentation to conduct currency exchange transactions and if it has disclosed this activity to the FI.
References:
Advanced CAMS-FCI Study Guide, pages 32-33.
Question 13
Single choice
An investigator at a corporate bank is conducting transaction monitoring alerts clearance. KYC profile background: An entity customer, doing business offshore in Hong Kong, established a banking business relationship with the bank in 2017 for deposit and loan purposes. It acts as an offshore investment holding company. The customer declared that the ongoing source of funds to this account comes from group-related companies. 1. X is the UBO. and owns 97% shares of this entity customer;
2. Y is the authorized signatory of this entity customer. This entity customer was previously the subject of a SAR/STR. KYC PROFILE Customer Name: AAA International Company. Ltd Customer ID: 123456 Account Opened: June 2017 Last KYC review date: 15 Nov 2020 Country and Year of Incorporation: The British Virgin Islands, May 2017 AML risk level: High
Account opening and purpose: Deposits, Loans, and Trade Finance Anticipated account activities: 1 to 5 transactions per year and around 1 million per transaction amount During the investigation, the investigator reviewed remittance transactions activities for the period from Jul 2019 to Sep 2021 and noted the following transactions pattern: TRANSACTION JOURNAL Review dates: from July 2019 to Sept 2021 For Hong Kong Dollars (HKD) currency: Incoming transactions: 2 inward remittances of around 1.88 million HKD in total from different third parties Outgoing transactions: 24 outward remittances of around 9 4 million HKD in total to different third parties For United States Dollars (USD) currency: Incoming transactions: 13 inward remittances of around 3.3 million USD in total from different third parties Outgoing transactions: 10 outward remittances of around 9.4 million USD in total to different third parties. RFI Information and Supporting documents: According to the RFI reply received on 26 May 2021, the customer provided the bank with the information below: 1J All incoming funds received in HKD & USD currencies were monies lent from non-customers of the bank. Copies of loan agreements had been provided as supporting documents. All of the loan agreements were in the same format and all the lenders are engaged in trading business. 2. Some loan agreements were signed among four parties, including among lenders. borrower (the bank's
customer), guarantor, and guardian with supplemental agreements, which stated that the customer, as a borrower, who failed to repay the loan Which additional information would support escalating this account for closure?
-
A
The bank files SARs/STRs indicating that Y opened accounts for small companies located in close proximity to the bank.
-
B
A follow-up request reveals that the account receives funds from loans, collects payments from group-related companies, and sends the payments to the lenders.
-
C
A review of outward remittances reveals the same pattern of several simple steps for each transaction,
-
D
A review of X's personal bank account shows that X received wire transfers that aggregate the amounts transferred to the group-related companies.
Reveal answer details
Close answer details
Correct answerC
ExplanationA review of outward remittances reveals the same pattern of several simple steps for each transaction, which could indicate a layering scheme to obscure the origin and destination of the funds. This would support escalating this account for closure, as it is inconsistent with the customer's declared purpose and anticipated activities. The other options are not relevant or sufficient to warrant account closure.
References:
Advanced CAMS-FCI Certification | ACAMS
Question 14
Multiple choice
During transaction monitoring. Bank A learns that one of their customers. Med Supplies 123. is attempting to make a payment via wire totaling 382,500 USD to PPE Business LLC located in Mexico to purchase a large order of personal protective equipment. specifically surgical masks and face shields. Upon further verification. Bank A decides to escalate and refers the case to investigators. Bank A notes that, days prior to the above transaction, the same customer went to a Bank A location to wire 1,215,280 USD to Breath Well LTD located in Singapore. Breath Well was acting as an intermediary to purchase both 3-ply surgical masks and face shields from China. Bank A decided not to complete the transaction due to concerns with the involved supplier in China. Moreover, the customer is attempting to send a third wire in the amount of 350,000 USD for the purchase of these items, this time using a different vendor in China. The investigator must determine next steps in the investigation and what actions, if any. should be taken against relevant parties. During the investigation, Bank A receives a USA PATRIOT Act Section 314(a) request related to Med Supplies 123. Which steps should the investigator take when fulfilling the request? (Select Three.)
-
A
Exit the relationship with the business since it appears that customer is under investigation.
-
B
Do not respond to Financial Crimes Enforcement Network (FinCEN) if the requested information is not present in the financial institution's system of records.
-
C
Review the account(s) activity and proactively file a SAR/STR using the 314(a) request as the basis for the filing.
-
D
Report to Financial Crimes Enforcement Network (FinCEN) that a match was found without revealing any other details.
-
E
Report back to the Financial Crimes Enforcement Network (FinCEN) within 15 days of receipt of the request via a secure internet website.
-
F
Search its records expeditiously to determine whether it maintains(ed) any accounts for the subject(s) listed in the request.
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Close answer details
Correct answersD, E, F
ExplanationAccording to the FinCEN's 314(a) Fact Sheet1, the steps that the investigator should take when fulfilling the request are: Search its records expeditiously to determine whether it maintains(ed) any accounts for the subject(s) listed in the request. This is option
F. Report back to the Financial Crimes Enforcement Network (FinCEN) within 15 days of receipt of the request via a secure internet website. This is option
E. Report to Financial Crimes Enforcement Network (FinCEN) that a match was found without revealing any other details. This is option
D.
The other options are incorrect because: Exiting the relationship with the business since it appears that customer is under investigation is not required by the 314(a) program and may interfere with law enforcement's investigation. This is option A.
Not responding to Financial Crimes Enforcement Network (FinCEN) if the requested information is not present in the financial institution's system of records is contrary to the 314(a) program, which requires financial institutions to respond whether or not they have a match. This is option
B. Reviewing the account (s) activity and proactively filing a SAR/STR using the 314(a) request as the basis for the filing is not appropriate, as the 314(a) request itself is not a sufficient reason to file a SAR/STR. The financial institution should only file a SAR/STR if it has its own independent suspicion of money laundering or terrorist financing. This is option
C.
References:
1: FinCEN's 314(a) Fact Sheet
Question 15
Multiple choice
An analyst reviews an alert for high volume Automated Clearing House (ACH) activity in an account. The analyst's initial research finds the account is for a commercial daycare account that receives high volumes of large government-funded ACH transactions to support the programs. The account activity consists of checks (cheques) made payable to individual names in varying dollar amounts. One check indicates rent to another business. An Internet search finds that the daycare company owner has previous government-issued violations for safety and classroom size needs, such as not having enough chairs and tables per enrollee. These violations were issued to a different daycare name. Simultaneous to this investigation, another analyst sends an email about negative news articles referencing local child/adult daycare companies misusing governmental grants. This prompts the financial institution (Fl) to search all businesses for names containing 'daycare' or are'. Text searches return a number of facilities as customers at the Fl and detects that three of these businesses have a similar transaction flow of high volume government ACH funding with little to no daycare expenses. Which red flags would be an indicator that activity is connected to a corruption/bribery typology? (Select
Two.)
-
A
Large checks issued to various individuals with the memos noting "gift", "thank you", "favor"
-
B
Negative news found on the customer related to government-issued violations for safety
-
C
Checks issued to an unrelated entity referencing "rent" and "utilities" in the memos
-
D
Multiple daycare locations with no active business operations or related account activity
-
E
The same beneficial owner owning several daycare centers in different locations
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Close answer details
Correct answersA, B
ExplanationThe red flags that would be an indicator that activity is connected to a corruption/bribery typology are large checks issued to various individuals with the memos noting "gift", "thank you", "favor" (A) and negative news found on the customer related to government-issued violations for safety (B). These red flags suggest that the customer is involved in paying or receiving bribes or kickbacks to or from government officials or other parties in exchange for favorable treatment or contracts. These red flags are consistent with some of the indicators of corruption/bribery identified by ACAMS1, such as: Payments made to or from third parties that are not directly related to the business Payments made to or from high-risk jurisdictions or sectors Payments made with vague or incomplete descriptions or justifications Negative news or reputation of the customer or its associates.
The other options are not as relevant or indicative of corruption/bribery as options A and B. Checks issued to an unrelated entity referencing "rent" and "utilities" in the memos ?could be a legitimate business expense or a sign of other types of fraud or money laundering, such as tax evasion or shell company schemes. Multiple daycare locations with no active business operations or related account activity (D) could also be a sign of other types of fraud or money laundering, such as embezzlement or front company schemes. The same beneficial owner owning several daycare centers in different locations (E) could be a normal or legitimate business practice, depending on the size, location, and profitability of the centers.
Question 16
Multiple choice
During transaction monitoring. Bank A learns that one of their customers. Med Supplies 123, is attempting to make a payment via wire totaling 382,500 USD to PPE Business LLC located in Mexico to purchase a large order of personal protective equipment. specifically surgical masks and face shields. Upon further verification. Bank A decides to escalate and refers the case to investigators. Bank A notes that, days prior to the above transaction, the same customer went to a Bank A location to wire 1,215,280 USD to Breath Well LTD located in Singapore. Breath Well was acting as an intermediary to purchase both 3-ply surgical masks and face shields from China. Bank A decided not to complete the transaction due to concerns with the involved supplier in China. Moreover, the customer is attempting to send a third wire in the amount of 350,000 USD for the purchase of these items, this time using a different vendor in China. The investigator must determine next steps in the investigation and what actions, if any. should be taken against relevant parties. Upon further investigation. Bank As investigator learns that both the Mexico-and Singapore-based companies are linked to the alleged suppliers in China. Which additional indicators would the investigator need to identify to determine if this fits a fentanyl (drug) trafficking typology? (Select Two.)
-
A
Review of the invoices and transportation documents, provided by the customer, reveal significant discrepancies between the description of goods.
Internet research reveals that suppliers are newly established companies with no history of sales of medical equipment.
-
B
Review of the account activity reveals that wires were mainly funded by multiple cash deposits, conducted in amounts of 10.000 USD or below.
-
C
Review of the Food and Drug Administration (FDA) product certifications provided by the customer reveals that documents were falsified.
-
D
Review of the account activity reveals that account is inconsistent with the expected business activity as it shows multiple charges at various hotels, transportation tickets for unrelated 3rd parties, etc.
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