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CAMS · Question #207

Bank A is located in Country A. A wire transfer from Bank B located in Country B is processes by Bank A, where the funds are being moved to a customer at Bank C located in Country C. The wire…

The correct answer is A. The transaction in Country A. A bank must file a Suspicious Transaction Report (STR) in its own jurisdiction where it detects or processes the suspicious activity, regardless of where the originating or receiving banks are located.

Conducting and Responding to Investigations

Question

Bank A is located in Country A. A wire transfer from Bank B located in Country B is processes by Bank A, where the funds are being moved to a customer at Bank C located in Country C. The wire transfer is deemed suspicious by Bank A. Who should Bank A file a suspicious transaction report on?

Options

  • AThe transaction in Country A
  • BBank B in Country A
  • CThe transaction in Country B
  • DBank C in Country C

How the community answered

(32 responses)
  • A
    84% (27)
  • B
    3% (1)
  • C
    6% (2)
  • D
    6% (2)

Why each option

A bank must file a Suspicious Transaction Report (STR) in its own jurisdiction where it detects or processes the suspicious activity, regardless of where the originating or receiving banks are located.

AThe transaction in Country ACorrect

Bank A is the institution that detected and processed the suspicious wire transfer within Country A; it is therefore obligated to file the STR with its own domestic financial intelligence unit covering the transaction as it occurred in Country A. Each institution reports to its own regulatory authority, and the suspicion arose at Bank A during processing, making Country A the correct jurisdiction.

BBank B in Country A

Bank A cannot file an STR against Bank B in Country A because Bank B is a foreign institution domiciled in Country B and is not subject to Country A's reporting jurisdiction.

CThe transaction in Country B

Bank A has no legal authority to file an STR in Country B, as STR obligations are strictly tied to the domestic jurisdiction of the reporting institution.

DBank C in Country C

Bank A has no reporting obligation or jurisdictional authority over Bank C in Country C, as each institution independently reports suspicious activity to its own domestic authority.

Concept tested: Suspicious transaction report jurisdiction and filing obligation

Source: https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html

Topics

#suspicious transaction report#wire transfer#correspondent banking#STR jurisdiction

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