The best next step in the investigation is to check the jurisdiction’s list of known charities with

connections to terrorist activity ©. This is because the FI has a responsibility to verify the legitimacy

and reputation of the beneficiary of the funds, especially if it is a charity or non-profit organization

that operates in a high-risk jurisdiction or sector. 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 check if the

beneficiary is consistent with the customer’s profile and expected activity.

The other options are not as appropriate or effective as option C. Contacting the financial institution

in Turkey that has a relationship with Forever Free and advising them of the investigation (A) could

violate confidentiality or data protection laws, as well as compromise the investigation or alert the

customer or beneficiary of the suspicion. Updating the customer profile to include Forever Free as

the recipient of the funds (B) could be premature or inaccurate, as it does not verify the nature and

purpose of the transfer or the identity and legitimacy of the beneficiary. Filing a SAR/STR with the

new information learned about the beneficiary (D) could also be premature or incomplete, as it does

not confirm if there is any suspicious or criminal activity involved in the transfer or if there are any

other red flags or indicators.