CAMS-FCI Dumps 2024 – New ACAMS CAMS-FCI Exam Questions [Q21-Q39]

NO.21 SAR/STR NARRATIVE
A SAR/STR has been submitted on five transactions conducted on the correspondent banking relationship with ABC Bank.
Client Information:
Remitter information: DEF Oil Resource Ltd. is the oldest member of the DEF Group. It was founded in 1977 as a general trading business with a primary focus on exports from Africa and North America. The group has business activities that span the entire energy value chain. Their core field of endeavor is centered within the oil and gas industry and its associated sub-sectors.
Beneficiary Information:
As per the response received from ABC Bank, it was determined that the beneficiaries are related to DEF Oil Resource Ltd. These were created by DEF Oil Resource Ltd. to purchase property in a foreign country on behalf of their senior management as part of a bonus scheme. The purpose behind this payment was for purchase of property in another country.
Payment Reference:
ABCXXXXX31PZFG2H
ABCXXXXXX51PQGEH
ABCXXXXXX214QWVG
ABCXXXXXX41PSXA2
ABCXXXXXX815QWS3
Concerns:
* We are unsure about the country of incorporation of the beneficiaries.
* We are concerned about the transactional activity since the payment made towards entities (conducted on behalf of individuals) appears to be possible tax evasion.
* There appears to be an attempt to conceal the identity of individuals (senior management), which again raises concerns about the source of funds.
* Referring to the response received from ABC Bank, we are unclear about the ultimate beneficiary of funds.
* The remitter is involved in a high-risk business, (i.e., oil and crude products trading), and the beneficiary is involved in a real estate business which again poses a higher risk.
The monitoring system of the correspondent institution flags the transaction as suspicious activity. The correspondent bank needs to send a request for information to the respondent bank. Which elements should be included in the request? (Select Three.)

Details of DEF Oil Resource Ltd parent company and the name(s) of the beneficial owner(s)

Full transaction history of the correspondent bank’s customer

The account profile of the customer and their KYC data

The respondent bank’s customer’s senior management bonus plan

The contract pertaining to the purchase of property in another country

The last 6 months of transactional history

NO.22 An investigator at a corporate bank is conducting transaction monitoring alerts clearance.
KYC profile background: An entity customer, doing business offshore in Hong Kong, established a banking business relationship with the bank in 2017 for deposit and loan purposes. It acts as an offshore investment holding company. The customer declared that the ongoing source of funds to this account comes from group-related companies.
* X is the UBO. and owns 97% shares of this entity customer;
* Y is the authorized signatory of this entity customer. This entity customer was previously the subject of a SAR/STR.
KYC PROFILE
Customer Name: AAA International Company. Ltd
Customer ID: 123456
Account Opened: June 2017
Last KYC review date: 15 Nov 2020
Country and Year of Incorporation: The British Virgin Islands, May 2017 AML risk level: High Account opening and purpose: Deposits, Loans, and Trade Finance Anticipated account activities: 1 to 5 transactions per year and around 1 million per transaction amount During the investigation, the investigator reviewed remittance transactions activities for the period from Jul
2019 to Sep 2021 and noted the following transactions pattern:
TRANSACTION JOURNAL
Review dates: from July 2019 to Sept 2021
For Hong Kong Dollars (HKD) currency:
Incoming transactions: 2 inward remittances of around 1.88 million HKD in total from different third parties Outgoing transactions: 24 outward remittances of around 9 4 million HKD in total to different third parties For United States Dollars (USD) currency:
Incoming transactions: 13 inward remittances of around 3.3 million USD in total from different third parties Outgoing transactions: 10 outward remittances of around 9.4 million USD in total to different third parties.
RFI Information and Supporting documents:
According to the RFI reply received on 26 May 2021, the customer provided the bank with the information below:
1J All incoming funds received in HKD & USD currencies were monies lent from non-customers of the bank.
Copies of loan agreements had been provided as supporting documents. All of the loan agreements were in the same format and all the lenders are engaged in trading business.
2) Some loan agreements were signed among four parties, including among lenders. borrower (the bank’s customer), guarantor, and guardian with supplemental agreements, which stated that the customer, as a borrower, who failed to repay the loan Which additional information would support escalating this account for closure?

The bank files SARs/STRs indicating that Y opened accounts for small companies located in close proximity to the bank.

A follow-up request reveals that the account receives funds from loans, collects payments from group-related companies, and sends the payments to the lenders.

A review of outward remittances reveals the same pattern of several simple steps for each transaction,

A review of X’s personal bank account shows that X received wire transfers that aggregate the amounts transferred to the group-related companies.

NO.23 A client with many personal and business deposits with the financial institution (Fl) seeks a business loan. The client wants to guarantee the loan with a trust for which they are the beneficiary.
An investigator examines the trust. The trust has many layers, including shell companies in known tax havens.
The client’s ultimate beneficial ownership claim cannot be validated, and the loan is denied.
Two months later, the Fl receives a law enforcement (LE) request on one of the client’s business accounts.
While reviewing the business account, the Fl receives another LE request on the same account from another agency. The requested information is shared.
Three months later, a branch manager receives a request to open a business deposit account related to a complex trust. The manager forwarded the request because of the complexity. The trust was the same as the previously examined trust, but the request came from a different client. The second client also has many accounts with the Fl. Further inspection finds links between the second client and the Paradise Papers. The Papers state the client led illegal activities and committed tax evasion.
What steps should the investigator perform in reference to the first client’s existing accounts? (Select Three.)

Review all client-signed documents relating to all accounts.

File SARs/STRs for all accounts at the beginning of the discovery phase and amend later as necessary.

Inform Fl management of all processes used to investigate the client due to LE inquiry.

Perform secondary scans of the client’s other owners/authorized signers

Review Fl approved policies regarding the existing accounts to ensure regulatory requirements were followed.

Prepare a relationship flow chart of all existing accounts to better understand the client’s activities.

NO.24 Online payments from a customer’s account to three foreign entities trigger an investigation. The investigator knows the funds originated from family real estate after an investment company approached the customer online. Funds were remitted for pre-lPO shares. Which should now occur in the investigation?

Seek evidence for the customer’s source of wealth.

Have the relationship manager contact the customer to understand the nature of the transaction.

Review the structure of the transactions to the three entities.

Inspect electronic banking login records.

NO.25 The training department is conducting awareness training for unusual customer identification scenarios. Which two indicators should be included? (Select Two.)

The customer opens the account in the name of a family member who begins making large deposits.

The customer’s name and home address cannot be verified

The customer’s internet protocol address does not match the identifying information provided during online registration.

The customer requests payment of proceeds to an unrelated third party.

The customer frequently exchanges small bills for large bills.

NO.26 Which information is it best practice to share at the very beginning of a well-written SAR/STR narrative?

A specific description of the involved accounts and transactions, including the origination and application of funds

The purpose of the SAR/STR narrative and a general description of the known or alleged violation

Information about any follow-up actions conducted by the financial institution on the account

Any and all relevant facts about the parties who facilitated the suspicious activity or transactions

NO.27 Due to an ever-diversifying business model and multi-jurisdictional footprint, a casino has decided to outsource the source of funds and wealth checks to a third-party provider. Why is it important for the casino to maintain control of the output from the provider?

Clients of the casino prefer to know that the casino is keeping their information secure when being held by a third-party.

As with all third-party relationships, proper control must be maintained to ensure profitability.

The casino maintains ultimate responsibility for this activity and should maintain control to avoid non-compliance.

Other casinos are frequently looking to reduce costs and share ideas, so if this relationship is successful, the model can be used by other businesses.

NO.28 Which most likely indicates that a business email compromise attack has occurred?

A company sends a recurring payment to a new account number.

A company sends a larger-than-normal check to an existing supplier.

A company adds a new employee as an authorized signer.

A company has a new beneficial owner.

NO.29 Each month the automated transaction monitoring system generates alerts based on predetermined scenarios.
An alert was generated in relation to the account activity of ABC Foundation. Below is the transaction history for ABC Foundation (dates are in DD/MM/YYYY format).

The relationship manager for ABC Foundation contacts the client to request more information on the beneficiary of the transfer in Turkey. ABC Foundation advises that this is a not-for-profit charity group called
‘Forever Free.” Which is the best next step in the investigation?

Contact the financial institution in Turkey that has a relationship with Forever Free and advise them of the investigation.

Update the customer profile to include Forever Free as the recipient of the funds.

Check the junsdiction’s list of known chanties with connections to terrorist activity.

File a SAR/STR with the new information learned about the beneficiary.

NO.30 In a SAR/STR narrative concerning Individual A. which statement indicates a product of analysis rather than a fact or judgement?

Individual A was the originator of nine wires totaling 225.000 USD between January and March 2020.

Individual A made structured cash deposits possibly to circumvent regulatory reporting requirements

Individual A made structured cash deposits on almost consecutive days.

Individual A is a college student and employed part-time at a car wash.

NO.31 A financial institution (Fl) receives an urgent request for information from the financial intelligence unit (Fl country. According to FATF recommendations, which is the best action for the FI to take?

Request an official court subpoena with details of the investigation.

Provide as much information as possible to the FIU immediately.

Establish a committee from different areas of the Fl to determine if the request should be answered.

Inform the public relations department to prepare for negative news.

ling the financing of terrorism that could imply an imminenl threat in the

NO.32 Why is a more robust supervisory approach needed by regulators when overseeing small- and medium-sized money service businesses (MSBs) compared to larger MSBs for combatting terrorist financing (TF)?

Small- and medium-sized MSBs need to be targeted to ensure that competition in the industry remains constant and uniform.

Small- and medium-sized MSBs need to be robustly supervised so the regulator can maintain visibility in combatting TF.

Small- and medium-sized MSBs are more likely to falsify records to appear less risky in order to keep the banking relationship.

Small- and medium-sized MSBs are more at risk of allowing transactions linked to TF due to the lack of skilled compliance resources.

NO.33 A KYC specialist from the first line of defense at a bank initiates an internal escalation based on a letter of credit received by the bank.
MEMO
To: Jane Doe. Compliance Manager, Bank B From: Jack Brown, KYC Specialist, Bank B RE: Concerning letter of credit A letter of credit (LC) was received from a correspondent bank.
Bank A. in Country A. in Asia with strict capital controls, providing guarantee of payment to Bank B’s client for the export of 10 luxury cars located in Country B. located in Europe. Bank A’s customer is a general in the army where Bank A is headquartered.
The information contained in the LC is as follows:
* Advising amount per unit 30.000.00 EU *10 units of BMW
* Model IX3
* Year of registration: 2020
Upon checks on Bank B’s client, the exporter mentioned that the transactions were particularly important, and a fast process would be much appreciated in order to avoid reputational damage to the firm and the banks involved in the trade finance process. The exporter has a longstanding relationship with Bank B and was clearly a good income generator. The exporter indicated that, as a general, the importer was trustworthy.
The relationship manager <RM) was contacted to conduct a full review of the exporter and to conduct a site visit.
Feedback from the RM:
The RM contacted the exporter for a client courtesy visit, but it was rearranged four times as the exporter kept cancelling the appointments. When the exporter was finally pinned down for an interview, employees were reluctant to provide clear answers about the basis of the transaction. The employees were evasive when asked about the wider business and trade activity in the country.
Findings from the investigation from various internal and external sources of information:
* There were no negative news or sanctions hits on the exporter company, directors, and shareholders.
* The registered address of the exporting business was a residential address.
* The price of the cats was checked and confirmed to be significantly below the market price of approximately 70,000 EU, based on manufacturer’s new price guide.
* The key controllers behind the exporting company, that is the directors and During the investigation, the investigator determines that a nephew of the general (Bank A’s customer) is a customer at Bank B.
Which step should the investigator take next?

File a SAR/STR in relation to corruption involving the nephew and the general.

Determine whether there is a business relationship between the nephew and the general.

Seek senior management approval to continue the relationship with the nephew.

Flag the nephew as a PEP by association.

NO.34 Law enforcement (LE) suspects human trafficking to occur during a major sporting event LE officers asked several financial institutions (FIs) to monitor financial transactions occurring before, during, and after the event.
An investigator identified a pattern linked to a business. The business’ account received multiple even dollar deposits between midnight and 4:00 AM. They occurred each day for several days prior to the date of the sporting event. Also, large cash deposits, typically between 2,000 USD and 3,000 USD. made by a person to the business’ account occurred in many branches in the days after the sports event.
There was little information about the company. The company did not have any history of employee payroll expenses or paying taxes. Expenses from the business account included air travel and hotel expenses. Searches about the person making cash deposits showed little. An online social media platform webpage with the individual’s name showed ads for dates1′ and “companionship.” The Fl wants to create an automated alert for human trafficking money laundering after this investigation.
Which activity type should they target?

Payments made to multiple hotels in the same city

Multiple deposits between midnight and 4:00 AM

Deposits made within days of major sporting events

Payments made for virtual currency

NO.35 Which might suggest misuse of crowdfunding resources by a terrorist?

A small charge at a gas station followed by a large charge at an electronics store

A large deposit followed by multiple charges at a sporting goods store

Multiple small deposits followed by a wire transfer to a large well-known international charity

Multiple small deposits followed by the purchase of airplane tickets >

NO.36 An analyst reviews an alert for high volume Automated Clearing House (ACH) activity in an account. The analyst’s initial research finds the account is for a commercial daycare account that receives high volumes of large government-funded ACH transactions to support the programs. The account activity consists of checks (cheques) made payable to individual names in varying dollar amounts. One check indicates rent to another business.
An Internet search finds that the daycare company owner has previous government-issued violations for safety and classroom size needs, such as not having enough chairs and tables per enrollee. These violations were issued to a different daycare name.
Simultaneous to this investigation, another analyst sends an email about negative news articles referencing local child/adult daycare companies misusing governmental grants. This prompts the financial institution (Fl) to search all businesses for names containing daycare’ or “care*. Text searches return a number of facilities as customers at the Fl and detects that three of these businesses have a similar transaction flow of high volume government ACH funding with little to no daycare expenses.
During the investigation, new suspicious patterns and trends related to check cashing are observed. The Fl decides to conduct a training to ensure that 1) the AML program is robust and 2) the training program is relevant and appropriate. Which parties should be trained on emerging trends and red flags? (Select Two.)

Financial crimes investigation unit

Loan department

Branch personnel

Senior management

The board of directors

NO.37 The compliance learn is reviewing multiple data points to include in its data analytics program to detect shell or front company red flags. Which data points should the compliance team include? (Select Two.)

Entities exhibiting transactions with declared counterparties

Entities whose principal place of business is a non-residential address

Entities with high paid-up capital relative to monthly value of transactions

Entities with a large number and variety of beneficiaries not declared at the time of onboarding

Entities transacting with or having relation to tax haven or high-risk countries

NO.38 An EU bank account received 1.8 million EUR from a Swiss bank. The EU bank determines the originator was indicted by U.S. law enforcement, arrested in Switzerland, and extradited for alleged insider trading.
Which is the best reason the EU bank should file a SAR/STR?

The originator was indicted by U.S. law enforcement.

Insider trading is a predicate offense in the U.S. and Switzerland.

The events raise concerns that the payment represents proceeds from insider trading.

The Swiss bank filed a SAR/STR with the Money Laundering Reporting Office Switzerland.

NO.39 A compliance analyst is reviewing the account activity of a customer that they suspect may be indicative of money laundering activity. Which is difficult to determine solely from the customer’s account activity and KYC file?

If the activity is materially different from related businesses

If the account has multiple transfers to the same, related businesses

If there is negative media associated with counterparties

If the account is mostly dormant or has little activity