The 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.

The investigator should review how the wire transfers were initiated first, because this could indicate

the level of involvement and knowledge of the LLC account holders. If the wire transfers were

initiated online or by phone, it could suggest that the account holders were trying to avoid face-to-

face contact with the bank staff and reduce the chances of being questioned or identified. If the wire

transfers were initiated in person at a branch, it could indicate that the account holders were

confident or careless about their activities, or that they had some relationship with the bank staff.

The method of initiation could also affect the quality and quantity of information collected by the

bank about the wire transfers, such as the purpose, source, and destination of the funds. Reference:

ACAMS Advanced Financial Crimes Investigations Certification Study Guide, page 65.

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.

The instruction that the person in charge of the broker-dealer should provide to their employees is

to take notes on the questions and comments made by the agents (A). This is because taking notes

can help the employees to recall and document what happened during the search warrant execution,

which can be useful for legal or regulatory purposes. According to ACAMS3, “the FI should instruct its

staff to cooperate with LE agents during a search warrant execution, but also to take notes of what is

being searched, seized, or asked by the agents” (p. 35). The FI should also “keep copies of any

documents or records that are taken by LE agents” (p. 35).

The other instructions are not correct. The person in charge of the broker-dealer should not instruct

their employees to sign consent forms permitting the agents to search employees’ offices (B), as this

is unnecessary and potentially risky, as the agents already have a valid search warrant that authorizes

them to search the premises. The person in charge of the broker-dealer should not instruct their

employees to provide agents with unlimited access to customers’ personal data ©, as this could

violate privacy or data protection laws, as well as compromise customer trust and confidentiality. The

person in charge of the broker-dealer should not instruct their employees to volunteer information

not requested by the agents that they think may be useful (D), as this could interfere with the LE

investigation or expose them to legal or regulatory risks.

Reference:

Introduction to Transnational Organized Crime

ACAMS Law Enforcement and Financial Crimes Investigations eLearning Course Module

Law Enforcement Requests and Actions

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. Reference: Advanced CAMS-FCI Study Guide, pages 32-33.

The correct answer is A because a SAR/STR narrative should be concise, clear, and complete,

addressing the who, what, when, where, why, and how of the suspicious activity. Option B is

incorrect because providing too much information can make the narrative confusing and irrelevant.

Option C is incorrect because the introduction should provide a summary of the suspicious activity,

not the conclusion. Option D is incorrect because suspect names should be mentioned in the

narrative to identify the parties involved in the suspicious activity.

Reference: Advanced CAMS-FCI Certification Handbook, page 17; Leading Complex Investigations

Certificate, Module 3.

The step that the investigator should take next is to flag the nephew as a PEP by association (D). This is because the nephew is related to a general who is a senior military official and a customer of Bank A, which is a high-risk jurisdiction with strict capital controls. According to the ACAMS Advanced Financial Crimes Investigations Certification Study Guide1, “the FI should identify and flag any customers who are PEPs or have close associations with PEPs, such as family members or business partners” (p. 24). The FI should also conduct enhanced due diligence on these customers and monitor their transactions for any suspicious or unusual activity. The other options are not correct. The investigator should not file a SAR/STR in relation to corruption involving the nephew and the general (A), as this could be premature or unnecessary, as there is no evidence of corruption or criminal activity between them. The investigator should not determine whether there is a business relationship between the nephew and the general (B), as this is not relevant or material to the investigation, as the nephew and the general are customers of different banks and are not involved in the same transaction. The investigator should not seek senior management approval to continue the relationship with the nephew ©, as this could be premature or disproportionate, as there is no indication that the nephew poses a high risk or requires termination. Reference: 1: ACAMS Advanced Financial Crimes Investigations Certification Study Guide, available at ACAMS

If the investigator uncovers evidence that foreign nationals are involved in this activity, they should

also note the possible presence of human smuggling (D). This is because human smuggling is the

illegal movement of people across borders, often facilitated by criminal networks that exploit

vulnerable migrants. According to the FATF and Egmont Group report on Financial Flows from Human

Trafficking2, “human smuggling can be closely linked to human trafficking, as smuggled migrants

may become victims of trafficking along their journey or at their destination” (p. 9). The report also

states that some indicators of human smuggling are similar to those of human trafficking, such as:

Frequent cash deposits or withdrawals in different locations

Use of false or fraudulent identification documents

Expenses related to travel and accommodation

Involvement in online platforms that advertise sexual services

The other options are not as relevant or specific as option D. Tax fraud (A) is the evasion of taxes by

individuals or businesses, which may or may not be related to human trafficking or smuggling. Black

market peso exchange (B) is a money laundering scheme that involves exchanging illicit proceeds in

one currency for another currency at a discounted rate, which is more commonly associated with

drug trafficking or trade-based laundering. Trade-based laundering © is the manipulation of trade

transactions to disguise the origin and ownership of illicit funds, which is also more likely to be linked

to drug trafficking or other types of fraud.

Reference: 1: ACAMS Advanced Financial Crimes Investigations Certification Study Guide, available at

ACAMS 2: FATF and Egmont Group, Financial Flows from Human Trafficking, July 2018, available at

FATF

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.

The 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.