Conducting Investigations Flashcards
6 cards from real ACAMS practice questions. Tap to flip, then mark Knew It or Still Learning — missed cards come back until you master them.
Read the first 6 Conducting Investigations flashcards as text
What is the primary difference between an AML investigation and a standard audit?
Answer: Investigations follow a specific suspicious transaction or pattern to determine if illegal activity occurred, while audits systematically evaluate the overall effectiveness of AML controls
An AML investigation is triggered by specific suspicious activity and aims to determine whether money laundering or financial crime occurred, while an AML audit systematically evaluates the overall design and effectiveness of the institution's AML compliance program.
What information should be gathered during the initial stage of an AML investigation triggered by a transaction monitoring alert?
Answer: Customer identity information, account history, related party information, transaction patterns, and any prior SAR or alert history
A thorough AML investigation requires gathering comprehensive information from multiple sources: customer identity and KYC file, full account and transaction history, related party connections, prior alert/SAR history, and external sources such as public records and adverse media.
What does the legal term 'tipping off' mean in the AML context, and what is its consequence?
Answer: Disclosing to a subject that a SAR has been filed or is being considered about them; it is a federal crime under 31 USC 5318(g)(2)
Tipping off is the illegal act of notifying a customer or any person that they are the subject of a SAR investigation. Under 31 USC 5318(g)(2), tipping off is a federal crime that can result in imprisonment and fines.
When conducting an AML investigation, how should investigators handle 'link analysis'?
Answer: Link analysis maps the connections between accounts, individuals, entities, and transactions to identify networks of related parties and hidden relationships that may indicate coordinated money laundering
Link analysis in AML investigations involves visually mapping and analyzing connections between accounts, people, businesses, transactions, and addresses to uncover networks of related parties potentially engaged in coordinated financial crime.
What is the role of the 'BSA Officer' (BSAO) in an AML investigation?
Answer: The BSAO oversees the AML compliance program and typically makes or approves final SAR filing decisions, ensuring investigations are thorough and documented
The BSA Officer (also called the AML Compliance Officer) is responsible for overseeing the AML program, which includes ensuring investigations are properly conducted, documented, and that SAR filing decisions are sound and well-supported.
What is the standard for determining whether a SAR should be filed after completing an AML investigation?
Answer: The institution knows, suspects, or has reason to suspect that a transaction involves funds from illegal activity or is designed to evade BSA requirements, and involves at least $5,000
The SAR filing threshold is met when the institution 'knows, suspects, or has reason to suspect' that a transaction involves criminal funds or evasion of BSA requirements — proof is not required, and the threshold is $5,000 for most institutions ($2,000 for MSBs).