The investigator should determine that a nephew of the general (Bank A’s customer) should be flagged as a senior PEP ©. This is because the nephew is related to a senior military official who is 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 determine that a nephew of the general should be treated well to avoid reputational damage to the bank (A), as this could compromise the integrity and objectivity of the investigation, as well as expose the bank to legal or regulatory risks. The investigator should not determine that a nephew of the general is a high-net- worth individual (B), as this is not relevant or material to the investigation, as the nephew’s wealth does not affect his potential PEP status or risk level. The investigator should not determine that a nephew of the general is a trustworthy source (D), as this could be biased or inaccurate, as the nephew’s trustworthiness does not depend on his relation to the general or his involvement in the transaction. Reference: 1: ACAMS Advanced Financial Crimes Investigations Certification Study Guide, available at ACAMS

One of the actions that is part of the enhanced due diligence process is collecting beneficial

ownership details regarding the client’s account. This is important to identify the natural persons

who ultimately own or control the client, and to assess the potential risks associated with them.

According to the Financial Action Task Force (FATF), beneficial ownership information should

include1:

The name, nationality, and country of residence of each beneficial owner.

The date of birth or incorporation of each beneficial owner.

The nature and extent of the beneficial interest held by each beneficial owner.

The means by which the beneficial ownership or control is exercised.

Reference:

FATF Guidance on Transparency and Beneficial Ownership

The correct answer is C. Escalate to the compliance officer/money laundering reporting officer to file

a SAR/STR. This is because the financial crime investigator has found evidence of fraudulent

documents and false information, which indicate a high risk of money laundering or other financial

crimes. The investigator should not contact the client directly, as this may tip them off or

compromise the investigation. The investigator should also not report collusion between the

cryptocurrency exchange and internal staff, as this is an assumption that has not been verified. The

investigator should not request a CDD refresh, as this is not sufficient to address the serious issues

identified.

Reference:

Advanced CAMS-FCI Study Guide, page 291

Advanced CAMS-FCI Study Guide, page 311

Advanced CAMS-FCI Study Guide, page 331

1: https://www.acams.org/en/certifications/advanced-cams/advanced-financial-crimesinvestigations

An investigator should avoid escalating a suspicious event to the chief compliance officer if there is a

potential conflict of interest, such as when a close family member of the officer is involved in the

transaction. In such a case, the investigator should pursue other channels, such as reporting to a

higher authority or an independent committee. The other options do not present a conflict of

interest and should be escalated to the chief compliance officer as part of the normal procedure.

Reference: Advanced CAMS-FCI Certification Handbook, page 18.

The activity type that the FI should target for creating an automated alert for human trafficking

money laundering is multiple deposits between midnight and 4:00 AM (B). This is because this

pattern is consistent with the indicators of human trafficking identified by the Financial Action Task

Force (FATF) and the Egmont Group1, which include:

Frequent cash deposits, often in round amounts, outside of normal business hours

Deposits made at different branches or ATMs in various locations

Lack of information about the nature and purpose of the business

Involvement in online platforms that advertise sexual services

Expenses related to travel and accommodation

The other options are not as relevant or specific as option B. Payments made to multiple hotels in the

same city (A) could be a legitimate business expense or a sign of other types of money laundering,

such as tax evasion or fraud. Deposits made within days of major sporting events © could also be

explained by other factors, such as increased tourism or gambling. Payments made for virtual

currency (D) are not directly related to human trafficking, although they could be used to facilitate

money laundering in general.

Reference: 1: FATF and Egmont Group, Financial Flows from Human Trafficking, July 2018, available at

FATF

Here is the exact information from the Financial Action Task Force (FATF) Guidance for a Risk-Based

Approach for Trust and Company Service Providers:

"Understanding the management and ownership structure of a trust is crucial in assessing the ML/TF

risk it poses. This includes the identity of all settlors, trustees and beneficiaries, and their respective

roles and responsibilities, as well as the nature and purpose of the trust."

"TCSPs should obtain and maintain up-to-date information on the purpose and intended nature of

the business relationship, the source of funds and wealth, and where relevant, the source of funds or

wealth of the settlor and beneficiaries."

Based on this information, the correct answers are A and D. Trust and Company Service Providers

must understand the responsibility and authority in the structure, as well as the general purpose

behind the structure in order to assess the overall risk of the trust and ensure that any transactions

with the trust are legitimate.

:

Verified Answer: D The recommendation that the AMLO should make is to conduct an in-depth

Explanation:investigation into accumulated remittance information in the past year to find the trend

of such transactions. This is because the regular and increasing remittances from a country with high

piracy activity may indicate a possible link to illicit funds derived from piracy or other criminal

activities. According to the World Bank, remittances are often used as a channel for money

laundering and terrorist financing, especially when they originate from or are destined to high-risk

jurisdictions1. Therefore, the AMLO should analyze the remittance data to identify the sources,

destinations, amounts, frequencies, and purposes of the transactions, and compare them with the

customer profiles, expected activities, and risk ratings. The AMLO should also review any relevant

information from external sources, such as media reports, sanctions lists, or law enforcement alerts,

to determine if there are any red flags or indicators of suspicious activity. If the investigation reveals

any evidence or suspicion of money laundering or terrorist financing, the AMLO should file a SAR/STR

to the appropriate AML authority.

Reference:

Remittances data - Migration data portal

Chain hopping is a technique used by criminals to obscure the traceability of cryptocurrency

transactions by converting the funds to a different type of cryptocurrency, often using multiple

exchanges or platforms. The other options are not related to chain hopping. Reference: Advanced

CAMS-FCI Study Guide, page 38.

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.

Reference: Reporting Suspicious Activity Certificate, Module 4, page 7.