The Egmont Group is an international network of Financial Intelligence Units (FIUs) that enhances cooperation and information sharing to combat financial crime.
Option A (Correct): The Egmont Group improves global cooperation by enabling FIUs to exchange financial intelligence securely.
Option C (Correct): The group facilitates secure communication channels for sharing money laundering and terrorist financing intelligence.
Option E (Correct): The Egmont Group fosters trust between FIUs, allowing them to work collaboratively on cross-border investigations.
Why Other Options Are Incorrect:
Option B (Incorrect): The Egmont Group does not negotiate case-by-case memoranda of understanding (MoUs) for individual cases.
Option D (Incorrect): The Egmont Group does not draft AML legislation; it provides guidance but does not have regulatory authority.
Key Functions of the Egmont Group:
Facilitating cross-border cooperation among FIUs.
Providing a secure network (Egmont Secure Web) for intelligence sharing.
Developing best practices for AML/CFT investigations.
Reference:
FATF Recommendation 29 (Role of FIUs in AML/CFT)
Egmont Group Charter and Principles for FIU Collaboration
Wolfsberg Group AML Guidance on FIU Information Exchange

A financial institution should consult with its legal counsel before responding to a grand jury subpoena regarding a customer, as such subpoenas may involve complex legal issues and potential conflicts of interest.
A grand jury subpoena is a legal order issued by a federal or state grand jury that compels a person or entity to produce documents, testify, or both, in connection with a criminal investigation. A financial institution that receives a grand jury subpoena should not disclose its existence or contents to the customer or any third party, unless authorized by law or the court, as doing so may constitute obstruction of justice or violate the secrecy rules of the grand jury. A financial institution should also assess and review all relevant information it has about the customer that is the subject of the subpoena, in accordance with its risk-based AML program, and consider filing a SAR if it identifies any suspicious activity.
References:
1: This article provides an overview of the legal and practical considerations for financial institutions when responding to subpoenas, including the types of subpoenas, the rules that apply, the confidentiality and privilege issues, and the procedural steps to follow.
2: This document provides answers to frequently asked questions regarding SARs and other AML considerations, including the question of how to handle grand jury subpoenas and other law enforcement inquiries.

The Patriot Act, enacted in 2001, introduced several provisions to enhance the anti-money laundering and counter-terrorist financing (AML/CFT) measures for U.S. banks and their foreign correspondent relationships.
Some of the potential issues for foreign financial institutions (FFIs) maintaining correspondent accounts with
U.S. banks under the Patriot Act are:
* Cancellation of correspondent banking relationships: The Patriot Act requires U.S. banks to conduct due diligence and enhanced due diligence on their foreign correspondent accounts, and to terminate any account that poses a significant risk of money laundering or terrorist financing. This may result in the cancellation of correspondent banking relationships with FFIs that do not meet the U.S. standards or cooperate with the U.S. authorities. The loss of correspondent banking relationships may affect the FFIs' ability to access the U.S. financial system and provide services to their customers.
* Forfeiture of funds in a U.S. interbank account: The Patriot Act authorizes the U.S. government to seize and forfeit any funds in a U.S. interbank account that are involved in or traceable to money laundering or terrorist financing activities. This means that FFIs may face the riskof losing their funds in a U.S.
interbank account if they or their customers are suspected or accused of engaging in illicit activities.
The forfeiture of funds may have significant financial and reputational consequences for the FFIs and their customers.
* Prohibition of correspondent accounts for shell banks: The Patriot Act prohibits U.S. banks from establishing or maintaining correspondent accounts for shell banks, which are banks that have no physical presence in any country and are not affiliated with a regulated financial group. This means that FFIs that are shell banks or have relationships with shell banks cannot access the U.S. financial system through correspondent accounts. The prohibition of correspondent accounts for shell banks aims to prevent the use of shell banks as vehicles for money laundering and terrorist financing.
CAMS Study Guide, 6th Edition, Chapter 4: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), pp. 81-841 USA PATRIOT Act, Title III: International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001, Sections 312, 319, and 3132 Wolfsberg Anti-Money Laundering Principles for Correspondent Banking, October 2014, pp. 3-43 Reference:http://www.ffiec.gov/bsa_aml_infobase/pages_manual/olm_027.htm

The bank's existing anti-money laundering training is not adequate to be delivered to the employees of the newly acquired credit card business, because anti-money laundering training needs to be tailored and focused on the risks specific to the business. Credit card businesses face different types of money laundering risks than retail banks, suchas card-not-present fraud, identity theft, card skimming, and prepaid card abuse. Therefore, the anti-money laundering training for credit card businesses should cover the specific red flags, indicators, typologies, and mitigation measures related to these risks, as well as the relevant laws and regulations that apply to credit card businesses.
CAMS Study Guide, 6th Edition, Chapter 4, Section 4.31
CAMS Study Guide, 6th Edition, Chapter 5, Section 5.21
Certification Candidate Handbook, Section 3.22
Latest CAMS Exam Questions, Question 433

When investigating unusual transactions, financial institutions must focus on data-driven risk assessment and internal review first.
* Option A (Correct):Assessing business ownership and control structureshelps determine ifmultiple businesses are connected through hidden links(e.g., shell companies or common ownership).
* Option C (Correct):The account managermay provide valuable insight on whether the customer's activity aligns with their expected profile.
* Option B (Incorrect):Law enforcement should only be contacted after internal review confirms suspicious activity.
* Option D (Incorrect):Declining transactions without thorough investigationcould lead tomissed SAR filingsor improper risk assessment.
* Option E (Incorrect):Social media is not a reliable investigative toolfor AML casework.
Key Red Flags in Business AML Investigations:
* Frequent transactions between businesses with no clear commercial relationship.
* Ownership structures that obscure beneficial owners.
* Rapid movement of funds through multiple accounts without economic justification.
Best Practices for Investigating Complex Cases:
* Verify ownership and control through official company registries.
* Conduct negative news screening and PEP/sanctions screening.
* Request supporting documentation from the customer.
Reference:
FATF Recommendation 10 (Customer Due Diligence)
Wolfsberg Group Guidance on Transaction Monitoring and Investigations
FinCEN Red Flags for Business Money Laundering Investigations