Most Recent Acams CAMS-FCI Exam Questions & Answers

The sources of funds that Bank A should conduct additional scrutiny on are the third-party transfer and the transfer from Bank B. This is because these sources may pose higher risks of money laundering, terrorist financing, fraud, or other illicit activities. Some of the reasons why these sources require more scrutiny are23:

Third-party transfers may involve unknown or unrelated parties that may have ulterior motives or hidden agendas. They may also be used to obscure the origin or destination of funds, or to circumvent sanctions or other regulatory restrictions.

Transfers from Bank B may involve jurisdictions that have weak anti-money laundering and counter-terrorist financing (AML/CFT) regimes, high levels of corruption, or significant criminal activity. They may also involve banks that have poor reputation, compliance, or transparency standards.

Third Party Payments - Wolfsberg Group

Guidance on Correspondent Banking Services - FATF

According to the Financial Action Task Force (FATF), the use of large amounts of cash is a common method for money launderers to move illicit funds [1]. Purchasing luxury items with cash can indicate an attempt to convert illegal funds into tangible assets that can be easily resold or moved across borders. As a result, businesses that deal with luxury items are required to implement enhanced due diligence measures, including monitoring transactions involving large amounts of cash [1].

The next best course of action for the investigator is to file a SAR/STR on the account activity in relation to a potential funnel account. This is because a funnel account is a type of money laundering scheme that involves depositing funds from multiple sources into a single account, and then transferring them to another account, often in a different jurisdiction. A funnel account can be used to conceal the origin, ownership, and destination of illicit funds, and to evade currency transaction reporting requirements. The investigator should report the suspicious activity to the relevant authorities and document the findings and actions taken. The other options are incorrect because:

A . Completing the monthly review and noting the activity for next month's review is not sufficient, as it delays the reporting of a possible money laundering scheme and exposes the financial institution to regulatory and reputational risks.

C . Recommending the account for exit due to frequent global transactions is not appropriate, as it does not address the underlying issue of potential money laundering and may alert the customer of the investigation.

D . No further action is required as the customer is already rated at high-risk and the monthly spending is within expectations is not acceptable, as it ignores the red flags of a funnel account and fails to comply with the anti-money laundering obligations of the financial institution.

Advanced CAMS-FCI Certification | ACAMS, Section 2: Investigating Financial Crimes, page 9

Leading Complex Investigations Certificate | ACAMS, Module 2: Identifying Red Flags, page 5

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.

The correct answer is A because this scenario describes a possible case of human trafficking, which is a crime where people are exploited for labor or sexual services against their will. Human traffickers may use bank accounts to launder their proceeds and pay their victims, and they may use fake or stolen identities to avoid detection. The other options are not likely because they do not explain why multiple deposits from the same employer under different employees' names would occur, nor why cash withdrawals would follow each deposit.