CAMS-FCI Exam Dumps : Advanced CAMS-Financial Crimes Investigations

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

Adverse Media Screening - Using AI to Mitigate Risk

Legal requirements for adverse media screening - Thomson Reuters

Electronic client due diligence | Ethics helpsheets | ICAEW

6AMLD & FATF: Where Adverse Media Screening Fits In

Free Adverse Media Check | NameScan

The investigator should determine that a nephew of the general (Bank A’s customer) should be flagged as a senior PEP ©. This is because the nephew is related to a senior military official who is a customer of Bank A, which is a high-risk jurisdiction with strict capital controls. According to the ACAMS Advanced Financial Crimes Investigations Certification Study Guide1, “the FI should identify and flag any customers who are PEPs or have close associations with PEPs, such as family members or business partners” (p. 24). The FI should also conduct enhanced due diligence on these customers and monitor their transactions for any suspicious or unusual activity.

The other options are not correct. The investigator should not determine that a nephew of the general should be treated well to avoid reputational damage to the bank (A), as this could compromise the integrity and objectivity of the investigation, as well as expose the bank to legal or regulatory risks. The investigator should not determine that a nephew of the general is a high-net-worth individual (B), as this is not relevant or material to the investigation, as the nephew’s wealth does not affect his potential PEP status or risk level. The investigator should not determine that a nephew of the general is a trustworthy source (D), as this could be biased or inaccurate, as the nephew’s trustworthiness does not depend on his relation to the general or his involvement in the transaction.

References: 1: ACAMS Advanced Financial Crimes Investigations Certification Study Guide, available at ACAMS

The correct answer is B because the FATF recommendations state that financial institutions should provide feedback to the FIU as quickly as possible, especially in cases involving the financing of terrorism that could imply an imminent threat to the country. Option A is incorrect because requesting an official court subpoena would delay the response and might not be necessary for the FIU to access the information. Option C is incorrect because establishing a committee would also delay the response and might not be in compliance with the FIU’s request. Option D is incorrect because informing the public relations department is irrelevant to the question and might compromise the confidentiality of the investigation.

References: FATF Recommendations, Recommendation 29; Leading Complex Investigations Certificate, Module 4.