Advanced CAMS-Financial Crimes Investigations: CAMS-FCI Exam Premium File as PDF & Test Engine

A financial regulator is evaluating the effectiveness of a financial institution's (Fl) anti-financial crime program. Which condition should be met to satisfy the regulator?

• A. In the past 3 years, internal auditing results show no high-severity issues and a maximum of three medium-seventy and four low-severity issues.
• B. The program is drafted using a risk-based approach to avoid the Fl being used as a conduit for criminal activities.
• C. The program meets the minimum requirements of anti-financial crime standards, which are published by a financial industry association.
• D. The program is aligned with the financial industry's anti-financial crime priorities.

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In which case should an investigator avoid escalating a suspicious event to the chief compliance officer and pursue other channels?

• A. A close family member of the chief compliance officer is the beneficiary of a cross-border transfer.
• B. An individual involved in a large sum transaction is a foreign PEP.
• C. A trade entity engages in complex trade deals involving numerous third-party intermediaries in incongruent lines of business.
• D. The transaction chain is likely connected to a known member of a terrorist organization.

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A compliance officer of a financial institution is reviewing a payment for sanctions compliance between two parties in Europe and Asia. The payment is in Euros and involves the provision of services to a company located in a jurisdiction subject to Office of Foreign Assets Control secondary sanctions. Which factor is most important in determining the compliance officer's response?

• A. Asset freezes only prohibit US companies from engaging in certain activities with counterparts from a sanctioned jurisdiction.
• B. Secondary sanctions only target specific sectors of the economy such as the banking and finance sectors.
• C. A one-off commercial transaction conducted between parties in Europe and Asia is not subject to secondary sanctions.
• D. The threat of US sanctions against foreign individuals and entities continues to exist despite the absence of a US nexus.

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A financial institution (Fl) banks a money transmitter business (MTB) located in Miami. The MTB regularly initiates wire transfers with the ultimate beneficiary in Cuba and legally sells travel packages to Cuba. The wire transfers for money remittances comply with the country's economic sanctions policies. A Fl investigator on the sanctions team reviews each wire transfer to ensure compliance with sanctions and to monitor transfer details.
An airline located in Cuba, unrelated to the business, legally sells airline tickets in Cuba to Cuban citizens wanting to travel outside of Cuba. The airline tickets are purchased using Cuban currency (CUC).
The MTB wants 100,000 USD worth of CUC. Purchasing CUC from a Cuban bank includes a 4% fee. The MTB contacts the airline to ask if the airline will trade its CUC for USD at a lower exchange fee than the Cuban bank. The airline agrees to a 1% fee. The MTB initiates a wire transfer to the airline which appears as normal activity in the monitoring system because of the business' travel package sales.
The investigator recommends that a SAR/STR be filed. What documentation should be referenced in the SAR/STR filing? (Select Three.)

• A. Airline's ticket sales and passenger list
• B. Cumulative dollar amount for transactions listing for all the MTB account's wire activity regarding travel packages
• C. Licensing information regarding the travel agency providing tourist sales to Cuba
• D. Account documentation on all related accounts maintained by the MTB
• E. Cumulative dollar amount of the wire transfer activity
• F. All documents related to the agreement between the airline and the MTB

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CLIENT INFORMATION FORM Client Name: ABC Tech Corp Client I.D. Number: 08125 Name: ABC Tech Corp Registered Address: Mumbai, India Work Address: Mumbai. India Cell Phone: ***"- Alt Phone:
Email: ********
Client Profile Information:
Sector: Financial
Engaged in business from (date): 02 Jan 2020
Sub-sector: Software-Cryptocurrency Exchange
Expected Annual Transaction Amount: 125.000 USD
Payment Nature: Transfer received from client's fund
Received from: Clients
Received for: Sale of digital assets
The client identified themselves as "Cryptocurrency Exchange" Client has submitted the limited liability partnership deed. However, the bank's auditing team is unable to identify the client's exact business profile as the cryptocurrency exchange specified by the client as their major business awaits clearance from the country's regulator. The client has submitted documents/communications exchanged with the regulator and has cited the lack of governing laws in the country of their operation as the reason for the delay.
Investigators determine the ultimate beneficial owner of ABC Tech Corp is a high-net-worth client. The client owns a real estate agency left to her when her spouse died. The spouse provided seed capital for ABC Tech Corp through a direct 1,000.000 Great British Pound (GBP) deposit.
What additional information would trigger filing a SAR/STR?

• A. The client's spouse's source of wealth was a salary of 250,000 GBP per annum for the past 4 years and rental of properties of 150,000 GBP per annum for the past 6 years.
• B. The client's current net asset value is 8 million GBP, of which 7.5 million GBP was derived from the inheritance.
• C. An open-source search revealed that the client's spouse was a PEP.
• D. The funds for the seed capital were in the form of 50 cashier's checks of 10,000 GBP each and 50 money orders of 10,000 GBP.

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