ACAMS Advanced CAMS-Financial Crimes Investigations : CAMS-FCI Exam

In a SAR/STR narrative concerning Individual A. which statement indicates a product of analysis rather than a fact or judgement?

• A. Individual A is a college student and employed part-time at a car wash.
• B. Individual A made structured cash deposits possibly to circumvent regulatory reporting requirements
• C. Individual A was the originator of nine wires totaling 225.000 USD between January and March 2020.
• D. Individual A made structured cash deposits on almost consecutive days.

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 *care'. 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. Checks issued to an unrelated entity referencing "rent" and "utilities" in the memos
• C. The same beneficial owner owning several daycare centers in different locations
• D. Multiple daycare locations with no active business operations or related account activity
• E. Negative news found on the customer related to government-issued violations for safety

Potential indicators of money laundering associated with Trust and Company Service Providers include:
(Select Two.)

• A. structuring cash deposits into third party accounts.
• B. use of legal persons in jurisdictions with strict secrecy laws.
• C. frequent deposits to or withdrawals from bank accounts.
• D. generation of rental income to legitimize illicit funds.
• E. multi-jurisdictional wire transfers with no legal purpose.

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 care*. 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.
The analyst determines that site visits should be conducted for the three daycare businesses. Which observations at the on-site visits would justify writing a SAR/STR? (Select Three.)

• A. Lights turned off at the site during operational hours
• B. Visible signage indicating the purpose of the building
• C. A site located in a commercial building
• D. Signs of severe wear and poor maintenance at the site
• E. A full parking lot of cars with no staff at the site
• F. Visible attendance with children being dropped off by parents

The investigative department of a financial institution (Fl) receives an internal escalation notice from the remittance department for a SWIFT message requesting a refund due to potential fraud. The notice indicates that a total of three international incoming remittances were transferred to a corporate customer from Country A, in the amount of approximately 5 million EUR for each. The first two incoming remittances had been exchanged into currency B and transferred out to Country B a few days ago. The third incoming remittance has been held by the remittance department.
As noted from the KYC profile, the corporate customer is working in the wood industry. with the last account review completed 3 months ago. Since the account's opening. there has been no history of a large amount of funds flowing through the account. The investigator conducts an Internet search and finds that the remitter is a food beverage company.
The same morning, the investigator receives a call from a financial intelligence unit (FIU) inquiring about the same incident. The FIU states that it will issue a warrant to freeze the account on the same day.
After further review, the decision is made that transactions appear suspicious. Which are the next steps the investigator should take? (Select Two.)

• A. Gather all the information that would be useful for law enforcement (LE) and recommend filing a SAR/STR
• B. Close the customer's accounts since the FIU is issuing a warrant to freeze the funds.
• C. Close the investigation as the FIU is already on this matter, and they will inform LE if needed.
• D. Contact local LE and advise them of the investigation details to help speed up the investigation and prosecution.
• E. Provide additional information to the LE upon receiving a formal request.