ACAMS Conducting Investigations 2

Question 1

What is the primary difference between an AML investigation and a standard audit?

Accepted 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

Answer

Audits are conducted by regulators while investigations are internal

Answer

Investigations only examine historical transactions while audits focus on future controls

Answer

Audits must be reported to FinCEN while investigations are confidential

Question 2

What information should be gathered during the initial stage of an AML investigation triggered by a transaction monitoring alert?

Accepted Answer

Customer identity information, account history, related party information, transaction patterns, and any prior SAR or alert history

Answer

Only the transaction details that triggered the alert

Answer

Only the beneficial ownership information for the account

Answer

External law enforcement reports and media searches only

Question 3

What does the legal term 'tipping off' mean in the AML context, and what is its consequence?

Accepted 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)

Answer

Informing a supervisor about a colleague's suspicious behavior; it is encouraged

Answer

Providing anonymous tips to law enforcement; it is legally protected

Answer

Sharing customer information with another financial institution; it may violate privacy laws

Question 4

When conducting an AML investigation, how should investigators handle 'link analysis'?

Accepted 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

Answer

Link analysis involves examining hyperlinks in customer-submitted documents for malware

Answer

Link analysis is a statistical technique for measuring transaction frequency

Answer

Link analysis involves checking web links to verify customer business legitimacy

Question 5

What is the role of the 'BSA Officer' (BSAO) in an AML investigation?

Accepted Answer

The BSAO oversees the AML compliance program and typically makes or approves final SAR filing decisions, ensuring investigations are thorough and documented

Answer

The BSAO only files CTRs and has no role in investigations

Answer

The BSAO only communicates with regulators and has no operational investigation role

Answer

The BSAO is responsible only for employee AML training programs

Question 6

What is the standard for determining whether a SAR should be filed after completing an AML investigation?

Accepted 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

Answer

The institution must be certain that money laundering has occurred

Answer

The institution must have a court order or law enforcement request before filing

Answer

SARs are only required for transactions involving more than $25,000