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CAMS · Question #934

News published in Country A reports that a politically exposed person (PEP) had received a bribe from a transnational company headquartered in a developing country of approximately USS1.5 million…

The correct answer is A. provide the information available to them because the exchange is between two FlUs that are. Egmont Group member FIUs may exchange financial intelligence with each other based solely on mutual membership, without requiring a pre-existing bilateral MoU.

Conducting and Responding to Investigations

Question

News published in Country A reports that a politically exposed person (PEP) had received a bribe from a transnational company headquartered in a developing country of approximately USS1.5 million deposited into on account at a financial institution (Fl> located in Country B Both countries are members of the Egmont Group The account where the money was deposited belongs to the PEP's immediate family member. To corroborate the facts, the PIU of Country A sent a formal request via secure communication channels for further information from its counterpart FIU in Country B. According to Egmont principles, the FIU of Country B can:

Options

  • Aprovide the information available to them because the exchange is between two FlUs that are
  • Bprovide the requested information only if a memorandum of understanding (MoU) is signed
  • Cdirect the FIU of Country A to the Fl where the account was opened for further information.
  • Ddeny the request if the FIU of Country B has not received a suspicious activity report (SAR) from

How the community answered

(44 responses)
  • A
    70% (31)
  • B
    9% (4)
  • C
    16% (7)
  • D
    5% (2)

Why each option

Egmont Group member FIUs may exchange financial intelligence with each other based solely on mutual membership, without requiring a pre-existing bilateral MoU.

Aprovide the information available to them because the exchange is between two FlUs that areCorrect

The Egmont Principles establish that membership in the Egmont Group is itself the basis for spontaneous and requested information exchange between FIUs, removing the need for bilateral treaties or MoUs. Country B's FIU can provide the requested information because both FIUs are Egmont members and the request arrived through secure, official channels. This reflects the Egmont principle that cooperation among members should be as broad as possible to combat transnational financial crime.

Bprovide the requested information only if a memorandum of understanding (MoU) is signed

An MoU is not a prerequisite for information exchange between Egmont member FIUs - the membership framework itself supplies the legal and operational basis for cooperation.

Cdirect the FIU of Country A to the Fl where the account was opened for further information.

Redirecting the requesting FIU directly to the financial institution bypasses the FIU-to-FIU exchange mechanism central to the Egmont framework and is not a sanctioned response.

Ddeny the request if the FIU of Country B has not received a suspicious activity report (SAR) from

The absence of a domestic SAR does not bar an FIU from responding to a foreign counterpart's request, as FIUs may hold or access information from sources beyond filed SARs.

Concept tested: Egmont Group FIU-to-FIU information sharing principles

Source: https://egmontgroup.org/resources/egmont-principles-for-information-exchange/

Topics

#Egmont Group#FIU information sharing#PEP bribery#cross-border cooperation

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