An investigator is reviewing an alert for unusual activity. System scanning detected a text string
within a company customer's account transactions that indicates the account may have been used
for a drug or drug paraphernalia purchase Based on the KYC profile, the investigator determines the
customer's company name and business type are marketed as a gardening supplies company. The
investigator reviews the account activity and notes an online purchase transaction that leads the
investigator to a website that sells various strains of marijuan
a. Additional account review detects cash deposits into the account at the branch teller lines, so the
investigator reaches out to the teller staff regarding the transactions. The teller staff member reports
that the business customers have frequently deposited cash in lower amounts. The teller, without
prompting, adds that one of the transactors would occasionally smell of a distinctscent of marijuana
smoke.
Which are the best next steps for the investigator to take? (Select Three.)
Correct Answer: A, C, E
Explanation:
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 opensource 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.
Reference:
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 help sheets | ICAEW
6AMLD &FATF: Where Adverse Media Screening Fits In
Free Adverse Media Check | NameScan
Question 2
During transaction monitoring. Bank A learns that one of their customers. Med Supplies 123, is attempting to make a payment via wire totaling 382,500 USD to PPE Business LLC located in Mexico to purchase a large order of personal protective equipment. specifically surgical masks and face shields. Upon further verification. Bank A decides to escalate and refers the case to investigators. Bank A notes that, days prior to the above transaction, the same customer went to a Bank A location to wire 1,215,280 USD to Breath Well LTD located in Singapore. Breath Well was acting as an intermediary to purchase both 3-ply surgical masks and face shields from China. Bank A decided not to complete the transaction due to concerns with the involved supplier in China. Moreover, the customer is attempting to send a third wire in the amount of 350,000 USD for the purchase of these items, this time using a different vendor in China. The investigator must determine next steps in the investigation and what actions, if any. should be taken against relevant parties. Upon further investigation. Bank As investigator learns that both the Mexico- and Singapore-based companies are linked to the alleged suppliers in China. Which additional indicators would the investigator need to identify to determine if this fits a fentanyl (drug) trafficking typology? (Select Two.)
Correct Answer: A, C
Question 3
A criminal is engaged in chain hopping while trying to launder ransomware payments. The criminal will likely:
Correct Answer: B
Explanation:
Chain hopping is a technique used by criminals to obscure the traceability of cryptocurrency transactions by converting the funds to a different type of cryptocurrency, often using multiple exchanges or platforms. The other options are not related to chain hopping. References: Advanced CAMS-FCI Study Guide, page 38.
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