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CAMS · Question #312

An anti-money laundering specialist working at a bank just received a legal request from a law enforcement agency mandating the release of all financial transaction records relating to an account at…

The correct answer is D. Advise the bank's senior legal advisor of the situation. the specialist should inform the bank's senior legal advisor of the situation and seek guidance on how to handle the legal request and the internal memos. The specialist should not take any action that could compromise the integrity of the legal request, the bank's anti-money…

Conducting and Responding to Investigations

Question

An anti-money laundering specialist working at a bank just received a legal request from a law enforcement agency mandating the release of all financial transaction records relating to an account at the bank. The specialist immediately recognizes the account as one owned by the bank Chief Executive Officers brother. During research to gather the requested documents, the specialist finds several internal memos he had sent to the bank president with concerns regarding possible suspicious activity relating to this account. The specialist recalls the bank president verbally responded to each memo with an explanation of the activity and indicated there was no cause for concern. What should the specialist do with respect to these internal memos?

Options

  • APlace these memos in his personal files in case they are subsequently requested
  • BAsk the bank president to document his instructions to the specialist
  • CCall the law enforcement agent and suggest he modify the legal request to include these memos
  • DAdvise the bank's senior legal advisor of the situation

How the community answered

(35 responses)
  • A
    3% (1)
  • B
    3% (1)
  • C
    9% (3)
  • D
    86% (30)

Explanation

the specialist should inform the bank's senior legal advisor of the situation and seek guidance on how to handle the legal request and the internal memos. The specialist should not take any action that could compromise the integrity of the legal request, the bank's anti-money laundering program, or the specialist's own professional obligations. The specialist should not place the memos in his personal files, as this could be seen as hiding or tampering with evidence. The specialist should not ask the bank president to document his instructions, as this could create a conflict of interest or a perception of undue influence. The specialist should not call the law enforcement agent and suggest he modify the legal request, as this could be seen as interfering with the investigation or tipping off the account holder.

Topics

#internal investigation#legal request#suspicious activity memos#senior legal counsel

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