ACAMS - Association of Certified Anti-Money Laundering Specialists Conducting Investigations Questions and Answers

Question 1

An AML investigator is reviewing a corporate account for a company that imports electronics.
The account shows several large, round-figure wire transfers to a new supplier in a high-risk jurisdiction, which is inconsistent with the company's established payment patterns.
The investigator has already reviewed all internal customer due diligence (CDD) information.
What is the most appropriate next step to gather more context?

Accepted Answer

Conduct open-source intelligence (OSINT) research on the new supplier and review public records.

Answer

Immediately file a Suspicious Activity Report (SAR) based on the red flags.

Answer

Contact the customer directly to inquire about the purpose of the new payments.

Answer

Close the account immediately to mitigate the financial institution's risk.

Question 2

During an AML investigation, a relationship manager receives an inquiry from a customer asking why a recent transaction is being delayed. Which of the following responses by the relationship manager would most likely be considered illegal 'tipping off'?

Accepted Answer

"Your transaction has been flagged by our AML system, and we must investigate it before deciding whether to report it to the authorities."

Answer

"We are conducting a routine compliance review as required for certain transactions."

Answer

"There appears to be a standard processing delay in the payment system; we will notify you when it is complete."

Answer

"To complete our processing, could you please provide the invoice related to this transaction?"

Question 3

When an AML investigator concludes an investigation and decides *not* to file a Suspicious Activity Report (SAR), what is a critical component that must be included in the investigation file?

Accepted Answer

A detailed justification for the decision, including the specific factors and evidence reviewed.

Answer

A copy of the customer's most recent government-issued photo identification.

Answer

The exact date the account is scheduled for its next periodic CDD review.

Answer

An attestation signed by the relationship manager confirming the customer's good standing.

Question 4

A financial institution receives a grand jury subpoena for the financial records of one of its customers. What is the most critical action the institution must take upon receipt?

Accepted Answer

Comply with the subpoena's request for information while maintaining strict confidentiality about its existence.

Answer

Immediately notify the customer that law enforcement has requested their records.

Answer

Conduct an internal investigation and file a SAR on the customer before responding.

Answer

Freeze all transactions on the account until the subpoena has been fulfilled.

Question 5

At the conclusion of a complex money laundering investigation, the compliance officer has determined that a SAR must be filed. The investigation revealed a sophisticated network of shell companies moving funds. Which of the following is the most important element to include in the SAR narrative?

Accepted Answer

A chronological and detailed description of the suspicious activity, covering the 'who, what, where, when, and why'.

Answer

The personal opinion of the investigator on the customer's character.

Answer

A recommendation to law enforcement on which specific statutes may have been violated.

Answer

An exhaustive list of every non-suspicious transaction in the account during the review period.

Question 6

An investigator is analyzing an alert on a customer's account involving structured cash deposits followed by an outgoing wire transfer. The investigator has reviewed account opening documents, transaction history, and notes from the relationship manager. Which of the following represents the next logical step of gathering *external* information?

Accepted Answer

Performing a public internet search on the beneficiary of the wire transfer.

Answer

Reviewing security camera footage of the deposits being made.

Answer

Checking the institution's central database for other accounts linked to the customer.

Answer

Interviewing the teller who accepted the cash deposits.