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The threat of US sanctions against foreign individuals and entities continues to exist despite the absence of a US nexus. This is stated in the Certified Anti-Money Laundering Specialist (the 6th edition) manual on page 591, which states: “It is important to note that the threat of US sanctions against foreign individuals and entities continues to exist even when there is no direct US nexus (i.e., no US persons or assets involved).”

Section 314(b) of the USA PATRIOT Act allows financial institutions to share information with each other, under a safe harbor that offers protection from liability, in order to better identify and report potential money laundering or terrorist financing activities. The intended benefits of this information sharing include:

Participating financial institutions sharing information about suspicious activity by customers that may have otherwise gone unnoticed. For example, if a customer is conducting transactions with multiple financial institutions that individually do not appear suspicious, but collectively indicate a pattern of money laundering or terrorist financing, the financial institutions can share this information and report it to the authorities.

Detecting money laundering and terrorist financing approaches and schemes across multiple financial institutions. For example, if a financial institution identifies a new typology or modus operandi of money laundering or terrorist financing, it can share this information with other financial institutions to help them prevent or detect similar activities by their customers.

Obtaining additional information on customers or transactions regarding potential money laundering or terrorist financing. For example, if a financial institution has incomplete or insufficient information on a customer or a transaction that raises suspicion, it can request more information from another financial institution that may have dealt with the same customer or transaction.

References:

• Section 314(b) | FinCEN.gov
• Section 314(b) Fact Sheet - FinCEN.gov

The best next steps for the investigator to take are:

A. Review the customer’s transaction history. This can help the investigator identify any patterns or anomalies in the customer’s account activity, such as changes in transaction volume, frequency, amount, source, destination, purpose, etc. The investigator can also compare the customer’s transaction history with their KYC profile and risk rating to assess if there are any discrepancies or inconsistencies.

C. Check internal KYC information. This can help the investigator verify the customer’s identity, business nature, ownership structure, expected activity, source of funds, etc. The investigator can also update or enhance the customer’s KYC information based on any new or relevant information obtained from other sources.

E Conduct adverse media and open-source searches on the customer’s background. This can help the investigator find out if there is any negative or adverse information about the customer in public data sources, such as news articles, social media posts, blogs, forums, etc. Adverse media and open-source searches can also provide additional context and insight into the customer’s reputation, behavior, associations, etc. The other options are incorrect because:

B. Request information from the internet service provider who hosts the website is not feasible, as it may require a legal process or a court order to obtain such information. Moreover, the internet service provider may not have or disclose any useful information about the website or its owner.

D. Research other customer accounts for transactions to the same website is not relevant, as it may not provide any meaningful information about the customer under investigation. Furthermore, it may violate the privacy and confidentiality of other customers who are not related to the investigation.

F. Identify if the customer has opened accounts in an urban city area is not helpful, as it may not have any bearing on the customer’s involvement in a drug or drug paraphernalia purchase. Additionally, it may not be possible to access or verify such information without the customer’s consent or authorization.

References:

Advanced CAMS-FCI Certification | ACAMS, Section 2: Investigating Financial Crimes, page 11

Leading Complex Investigations Certificate | ACAMS, Module 3: Conducting Research and Analysis, page 6

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