Under which two circumstances may law enforcement be given access to a financial institution customer's financial records? (Choose two.)
Correct Answer: B,D
Q Law enforcement may be given access to a financial institution customer's financial records if they serve a legal summons or subpoena, or if they have circumstantial evidence to suspect money laundering. These are two of the exceptions to the general rule that financial institutions must protect the privacy of their customers' financial information under the Right to Financial Privacy Act (RFPA) of 19781. The RFPA alsoallows access to customer records in other situations, such as with the customer's consent, in response to judicial orders, or for certain intelligence or counterintelligence purposes1. Option A is incorrect because a suspicious transaction report (STR) does not automatically grant law enforcement access to the customer's financial records. The STR is a confidential document that is filed by the financial institution to the Financial Intelligence Unit (FIU) of the country, and the FIU may decide to share the information with law enforcement if it deems appropriate2. However, law enforcement still needs to follow the RFPA procedures to obtain the customer's records from the financial institution. Option C is incorrect because the investigation of a customer being made public in the media does not give law enforcement the right to access the customer's financial records. The media exposure may raise the public interest or the urgency of the investigation, but it does not override the RFPA requirements. Law enforcement still needs to obtain a legal summons, subpoena, or other valid authorization to access the customer's records from the financial institution. References: 1: Right to Financial Privacy Act of 1978, 12 U.S.C. §§ 3401-3422 2: ACAMS Study Guide for the CAMS Certification Examination, 6th Edition, Chapter 3: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), p. 47
CAMS Exam Question 92
A financial institution's transaction monitoring system flags an unusually high volume of international wire transfers originating from a small business account. The transfers are being sent to multiple jurisdictions known for limited regulatory oversight. Additionally, an employee reports suspicious behavior from the account holder during an in-person visit, where they requested a large cash withdrawal without providing a clear business justification. As part of the investigation, the compliance team must assess whether this activity is suspicious and determine the appropriate next steps. Which of the following steps should be taken first in the investigation process to properly gather information and assess whether the transactions are suspicious?
Correct Answer: A
* A: The first step in any suspicious activity investigation is to review the transaction history and other relevant account information to establish context, identify patterns, and determine if the behavior is consistent with known typologies of money laundering. * "The initial phase of an AML investigation is to review relevant account information and transaction activity to assess whether a SAR filing is warranted." * This approach ensures that any subsequent decisions, such as escalation, SAR filing, or customer outreach, are based on a comprehensive understanding of the facts. References: CAMS 6th Edition, Suspicious Activity Monitoring and Investigation FFIEC BSA/AML Manual, Suspicious Activity Reporting
CAMS Exam Question 93
What types of things should an institution incorporate in it AML policies and procedures? Choose 3 answers
Correct Answer: A,B,C
An institution should incorporate on-going training, periodic audits, and ability to incorporate relevant legislative and regulatory AML changes in its AML policies and procedures. These are essential elements of an effective AML program, as they ensure that the staff are aware of their roles and responsibilities, the institution is compliant with the applicable laws and regulations, and the AML program is updated and adapted to the changing risks and environment. = CAMS Certification Package - 6th Edition | ACAMS1 CAMS Certifications: How to Get CAMS Certified | ACAMS2 ACAMS CAMS Certification Video Training Course - Exam-Labs3 Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)4
CAMS Exam Question 94
A local law enforcement officer, who is conducting a criminal investigation, requests information about a customer. Which two actions should the bank take? (Choose two.)
Correct Answer: B,C
According to the Anti-Money Laundering Specialist (the 6th edition) study guide, when a financial institution receives a law enforcement inquiry, it should cooperate as much as possible and respond to all formal requests for information, unless there is a valid objection that can and should be made1. The institution should also file a suspicious transaction report (STR) if the inquiry or the customer's activity triggers any red flags or indicators of money laundering or other financial crimes2. Additionally, the institution should monitor the account for suspicious activity and review the money laundering risk posed by the account, as these are part of the ongoing due diligence and risk assessment processes3. Closing the account immediately is not a recommended action, as it may alert the customer or interfere with the investigation4. 1: ACAMS, CAMS Certification Package - 6th Edition, Chapter 4, page 121 2: ACAMS, CAMS Certification Package - 6th Edition, Chapter 4, page 122 3: ACAMS, CAMS Certification Package - 6th Edition, Chapter 4, page 123 4: ACAMS, CAMS Certification Package - 6th Edition, Chapter 4, page 124
CAMS Exam Question 95
An auction house dealing in fine art and antiques sells a well-known painting at a price of $12 million to an agent bidding for a group of local investors. The same painting sold ten years prior at auction for $5 million. The auction house receives payment for the painting via wire transfer from an account maintained in an offshore jurisdiction by the investor group. No beneficial ownership information is available for the account. What are the two money laundering red flags? (Choose two.)
Correct Answer: D,E
The payment received from an account in an offshore jurisdiction and the lack of beneficial ownership details for the originating account are two money laundering red flags.Offshore jurisdictions are often used by money launderers to hide the source and destination of their funds, as they typically have low transparency and weak regulatory oversight. The absence of beneficial ownership information makes it difficult to identify the true owners and controllers of the funds, and to assess the legitimacy and risk of the transaction. These factors increase the possibility that the payment is related to money laundering, tax evasion, or other illicit activities. ACAMS CAMS Certification Study Guide, 6th Edition, page 33 ACAMS CAMS Certification Exam Outline, 6th Edition, Domain 1, Task 1.2 ACAMS CAMS Certification Video Training Course, Module 1, Lesson 1.2 Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition), Question 315
