ACAMS CAMS-FCI Online Practice Questions and Exam Preparation

ACAMS CAMS-FCI Online Questions & Answers

• Question 31:

  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.
  A. Review the wire transfer protocols for this customer.
  E. Review regulations applicable to foreign currency trading transactions.
  F. Locate and review licenses, registrations, and account operating agreements associated with the MTB account.

  ---

  Explanation/Reference:

  The 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 32:

  Potentially suspicious activity following an increase in the volume of transactions by an import company included outgoing wires to Indonesia and Uganda referencing invoice numbers. Incoming funds included large cash deposits and checks/ wires from pet stores, breeders, and private individuals. What financial crime might the bank reference in the SAR/STR?

  A. Tax evasion scheme
  B. International drug trafficking
  C. Illegal wildlife trade
  D. Black market peso exchange
  C. Illegal wildlife trade

  ---

  Explanation/Reference:

  The best reason the EU bank should file a SAR/STR is that the events raise concerns that the payment represents proceeds from illegal wildlife trade, which is a serious financial crime and a predicate offense for money laundering in many jurisdictions3. The fact that the incoming funds came from pet stores, breeders, and private individuals suggests that the import company may be involved in smuggling or trafficking endangered or protected animals or their parts4. The outgoing wires to Indonesia and Uganda, which are known source countries for wildlife trafficking, may indicate payments to suppliers or facilitators of this illicit activity. References: 3: Financial Action Task Force Report on Money Laundering from the Illegal Wildlife Trade, page 9 4: Financial Crime Typologies - Intermediate, page 18 : [World Wildlife Crime Report], page 16

• Question 33:

  A SAR/STR regarding money-mule activity prompts law enforcement action. Under U.S. law, the alleged money mules can be prosecuted:

  A. only if they were aware of their role and actively participated.
  B. in a country only if funds were transferred between accounts maintained in the same country.
  C. unless they can prove they were not aware of the origin of the funds.
  D. even if they were unaware that money was transferred.
  D. even if they were unaware that money was transferred.

  ---

  Explanation/Reference:

  According to U.S. law, money mules can be prosecuted even if they were unaware that money was transferred, as long as they acted with reckless disregard of the source of the funds or the purpose of the transaction1. This is because money mules are considered to be aiding and abetting money laundering, which does not require proof of specific intent2. References: 1: Money Mule Awareness Booklet, page 8 2: Money Laundering: An Overview of 18 U.S.C. ?1956 and Related Federal Criminal Law, page 7

• Question 34:

  Which most likely indicates that a business email compromise attack has occurred?

  A. A company sends a recurring payment to a new account number.
  B. A company sends a larger-than-normal check to an existing supplier.
  C. A company adds a new employee as an authorized signer.
  D. A company has a new beneficial owner.
  A. A company sends a recurring payment to a new account number.

  ---

  Explanation/Reference:

  When writing or reviewing a SAR/STR, it is important to ensure that the narrative is kept to the point; easy to read; and addresses the who, what, when, where, why, and how. This is because the narrative is the most crucial part of the SAR/

  STR, as it provides a clear and concise summary of the suspicious activity or transaction that triggered the report. The narrative should include all the relevant information that would help law enforcement or regulators to understand the nature

  and context of the activity or transaction, such as123:

  The who: The names, addresses, account numbers, and other identifying information of the parties involved in the activity or transaction, such as customers, beneficiaries, intermediaries, or third parties.

  The what: The type, amount, frequency, and purpose of the activity or transaction, such as cash deposits, wire transfers, check payments, or purchases of goods or services.

  The when: The date, time, and duration of the activity or transaction, and whether it was a one-time occurrence or part of a pattern or trend. The where: The location or channel of the activity or transaction, such as branches, ATMs, online

  platforms, or mobile applications. The why: The reason or rationale for the activity or transaction, and why it was considered suspicious or unusual based on the customer's profile, behavior, or expected activity.

  The how: The method or mechanism of the activity or transaction, such as cash, check, debit card, credit card, cryptocurrency, or prepaid card.

  References:

  How to write the perfect "Suspicious Activity Reports" (SAR)? | i-AML Writing for Prosecution: Best Practices For Composing SAR Narratives That Assist Prosecutors | ACAMS

  SAR Writing Examples and Proper Formatting: Write for Your Reader - Alessa

• Question 35:

  A new customer has just been onboarded in a securities firm. After a few weeks, there are unusual trading patterns that are being flagged. Which pattern is most concerning to the compliance officer?

  A. The customer engages in large trading in securities that are liquid or highly priced from the trading account.
  B. The customer's repeated trading in securities that are low priced and low volume counters.
  C. The customer receives many incoming wire transfers from related parties to the trading account.
  D. The customer accumulates securities of a low volume counter in small increments on a weekly basis.
  D. The customer accumulates securities of a low volume counter in small increments on a weekly basis.

  ---

  Explanation/Reference:

  The most concerning trading pattern for a compliance officer when a new customer has been onboarded in a securities firm is the customer accumulating securities of a low volume counter in small increments on a weekly basis. This type of

  behavior could indicate that the customer is attempting to obscure their identity or the true purpose of their trading activity, which can be indicative of money laundering or other suspicious activity.

  (CAMS Manual, 6th Edition, Page 170).

• Question 36:

  A financial institution (Fl) receives an urgent request for information from the financial intelligence unit (Fl country. According to FATF recommendations, which is the best action for the FI to take?

  A. Request an official court subpoena with details of the investigation.
  B. Provide as much information as possible to the FIU immediately.
  C. Establish a committee from different areas of the Fl to determine if the request should be answered.
  D. Inform the public relations department to prepare for negative news.
  E. ling the financing of terrorism that could imply an imminenl threat in the
  B. Provide as much information as possible to the FIU immediately.

  ---

  Explanation/Reference:

  The correct answer is B because the FATF recommendations state that financial institutions should provide feedback to the FIU as quickly as possible, especially in cases involving the financing of terrorism that could imply an imminent threat to the country. Option A is incorrect because requesting an official court subpoena would delay the response and might not be necessary for the FIU to access the information. Option C is incorrect because establishing a committee would also delay the response and might not be in compliance with the FIU's request. Option D is incorrect because informing the public relations department is irrelevant to the question and might compromise the confidentiality of the investigation. References: FATF Recommendations, Recommendation 29; Leading Complex Investigations Certificate, Module 4.

• Question 37:

  An investigator is reviewing a case generated from the transaction monitoring system, with two large amounts of incoming remittance (IR) to an individual customer. Based on the KYC profile, the customer is a plant manager of a famous multi-national electronics manufacturing firm. As the customer has no similarly large transaction patterns for the past 2 years, the investigator sends an inquiry to the relationship manager (RM) about the nature of the transaction. The RM replies that the transaction is a consultancy fee provided from two different electronics companies with a debit note provided However, there is no detail of service provided on the debit note, and the remitters are two individuals.

  Which actions should the investigator recommend to mitigate risk? (Select Two.)

  A. Exit the relationship with the customer.
  B. Document and maintain a file with the investigative findings.
  C. Discuss the investigation findings with the customer.
  D. Conduct enhanced due diligence.
  E. Re-evaluate the customer risk profile.
  D. Conduct enhanced due diligence.
  E. Re-evaluate the customer risk profile.

  ---

  Explanation/Reference:

  The actions that the investigator should recommend to mitigate risk are conducting enhanced due diligence (D) and re-evaluating the customer risk profile (E). These actions are appropriate and prudent, as they allow the investigator to obtain more information and evidence about the nature and purpose of the transactions, the source and destination of the funds, and the identity and legitimacy of the parties involved. According to the ACAMS Advanced Financial Crimes Investigations Certification Study Guide1, "the FI should conduct enhanced due diligence on all parties involved in the investigation, including checking various sources of information, such as watch lists, sanctions lists, negative news, and official registries" (p. 24). The FI should also "re-assess the customer risk profile based on any new information obtained during the investigation, and adjust the customer due diligence and monitoring requirements accordingly" (p. 25).

  The other options are not as appropriate or effective as options D and E. The investigator should not recommend exiting the relationship with the customer (A), as this could be premature or disproportionate, as well as potentially discriminatory or illegal. The investigator should not recommend documenting and maintaining a file with the investigative findings (B), as this is not an action to mitigate risk, but rather a standard procedure for any investigation. The investigator should not recommend discussing the investigation findings with the customer ? as this could compromise the integrity and objectivity of the investigation, as well as expose the FI to legal or regulatory risks. References: 1: ACAMS Advanced Financial Crimes Investigations Certification Study Guide

• Question 38:

  During a review of the accounts related to Richard Aston, an investigator notices a high number of incoming payments from various individuals.

  

  They also notice that these incoming payments typically occur during large sporting events or conferences. As a result of the account review, of which illegal activity does the investigator have reasonable grounds to suspect Richard Aston?

  A. Embezzling from the hotel
  B. Aftermarket sales of entertainment admission tickets
  C. Human trafficking
  D. Sports betting
  B. Aftermarket sales of entertainment admission tickets

  ---

  Explanation/Reference:

  The illegal activity that the investigator has reasonable grounds to suspect Richard Aston of is aftermarket sales of entertainment admission tickets. This is because aftermarket sales of entertainment admission tickets involve reselling tickets for events, concerts, festivals, etc. at a higher price than their face value, often through online platforms or scalpers. This practice can be illegal or unethical, depending on the jurisdiction and the terms and conditions of the original ticket seller. The investigator should look for indicators of aftermarket sales of entertainment admission tickets, such as high volume or frequency of incoming payments from various individuals, correlation between incoming payments and major events or conferences, and discrepancy between the customer's profile and the nature of the transactions. The other options are incorrect because:

  A. Embezzling from the hotel is not likely, as it would involve stealing money or property from the hotel by an employee or a person in a position of trust. There is no evidence that Richard Aston works for or has access to the hotel's assets. C. Human trafficking is not probable, as it would involve exploiting people for forced labor or commercial sexual exploitation. There is no indication that Richard Aston is involved in any form of human trafficking or has any connection to victims or perpetrators. D. Sports betting is not plausible, as it would involve wagering money on the outcome of sporting events or games. There is no sign that Richard Aston is engaged in any sports betting activity or has any association with bookmakers or gamblers. References: Advanced CAMS-FCI Certification | ACAMS, Section 2: Investigating Financial Crimes, page 10 TicketSwap: The safest way to buy and sell tickets Ticketing 101 | Ticketmaster 10 Types of Tickets For Events (+ Why and When To Use Them) - Eventbrite

• Question 39:

  While each is potentially important, which allows an investigations analyst to better write a SAR/STR narrative that is useful to law enforcement? (Select Two.)

  A. Including an explanation of the internal process that brought the transaction to the attention of the analyst
  B. Including information about the general activity trends in the area where the suspicious transactions were conducted
  C. Including contact information for individuals at other institutions with whom correspondence has occurred
  D. Including a detailed description of the known or suspected criminal violation or suspicious activity
  E. Ensuring all information in the SAR/STR is complete and accurate based on what the institution knows
  D. Including a detailed description of the known or suspected criminal violation or suspicious activity
  E. Ensuring all information in the SAR/STR is complete and accurate based on what the institution knows

  ---

  Explanation/Reference:

  A SAR/STR narrative that is useful to law enforcement should include a detailed description of the known or suspected criminal violation or suspicious activity, as well as ensure that all information in the SAR/STR is complete and accurate based on what the institution knows. These elements help law enforcement to understand the nature and scope of the suspicious activity, and to follow up with further investigation if needed. The other options are not essential for a useful SAR/STR narrative, as they either provide irrelevant or redundant information, or could compromise the confidentiality of the report.

• Question 40:

  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
  B. The purpose of the SAR/STR narrative and a general description of the known or alleged violation

  ---

  Explanation/Reference:

  The 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.