The fact that should not be included in the SAR/STR narrative is the request by law enforcement (D).

This is because the request by law enforcement is confidential and should not be disclosed to the

customer or anyone else who is not authorized to know it. According to the ACAMS Advanced

Financial Crimes Investigations Certification Study Guide1, “the FI should not include any reference

to the LE request in the SAR/STR narrative, as this could compromise the LE investigation or alert the

customer of the suspicion” (p. 35). The FI should also not inform the customer of the LE request or

delay filing the SAR/STR because of it.

The other facts should be included in the SAR/STR narrative, as they are relevant and indicative of

human trafficking money laundering. The air travel and hotel expenses (A) show that the customer is

involved in moving people across different locations, which could be a sign of human smuggling or

trafficking. The time of the cash deposits (B) shows that the customer is receiving cash payments

during unusual hours, which could be a sign of illicit activities or services. The sporting event ©

shows that the customer is exploiting a high-demand situation for their business, which could be a

sign of opportunistic or organized crime.