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ACAMS

CAMS · Question #612

Before providing suspicious activity report documentation to an authorized requestor, the institution should first:

The correct answer is D. independently verify the requestor. According to the guidance issued by FinCEN and the Federal banking agencies, when a financial institution receives a request for SAR supporting documentation from FinCEN or an appropriate law enforcement or supervisory agency, it must first verify that the requestor is, in…

Conducting and Responding to Investigations

Question

Before providing suspicious activity report documentation to an authorized requestor, the institution should first:

Options

  • Acontact a local financial intelligence unit for authorization.
  • Bnotify outside counsel.
  • Cde request a subpoena.
  • Dindependently verify the requestor.

How the community answered

(47 responses)
  • A
    4% (2)
  • B
    2% (1)
  • C
    11% (5)
  • D
    83% (39)

Explanation

According to the guidance issued by FinCEN and the Federal banking agencies, when a financial institution receives a request for SAR supporting documentation from FinCEN or an appropriate law enforcement or supervisory agency, it must first verify that the requestor is, in fact, a representative of such an agency. This is to ensure the confidentiality and security of the SAR information and to prevent unauthorized disclosures. A financial institution should have procedures for such verification in its BSA/AML compliance program, which may include, for example, independent employment verification with the requestor's field office or face-to-face review of the requestor's credentials.

Topics

#SAR confidentiality#requestor verification#SAR documentation#disclosure controls

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