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CAMS · Question #936

An employee at a financial institution (Fl) suspects that one of their co-workers is involved in a financial investment scam syndicate. Which step should be taken next by the employee who has the…

The correct answer is B. Use the Fl's whistle blowing channel to report the suspected employee. An employee suspecting a colleague of financial crime should report through the FI's official whistleblowing channel rather than investigating independently, confronting the individual, or making informal disclosures.

Conducting and Responding to Investigations

Question

An employee at a financial institution (Fl) suspects that one of their co-workers is involved in a financial investment scam syndicate. Which step should be taken next by the employee who has the suspicion?

Options

  • AQuestion their co-worker to determine If their suspicions are correct before reporting to the Fl's
  • BUse the Fl's whistle blowing channel to report the suspected employee
  • CWarn colleagues and customers of the F1 that the employee's suspicious financial investment
  • DConduct an open-source intelligence investigation using artificial intelligence tools to gain more
  • EReport the suspected employee to the line manager of the F1 to take the required action

How the community answered

(29 responses)
  • A
    3% (1)
  • B
    72% (21)
  • C
    3% (1)
  • D
    7% (2)
  • E
    14% (4)

Why each option

An employee suspecting a colleague of financial crime should report through the FI's official whistleblowing channel rather than investigating independently, confronting the individual, or making informal disclosures.

AQuestion their co-worker to determine If their suspicions are correct before reporting to the Fl's

Directly questioning the suspected co-worker risks tipping them off, compromising evidence, and may itself constitute a tipping-off offense under applicable AML laws.

BUse the Fl's whistle blowing channel to report the suspected employeeCorrect

Whistleblowing channels are specifically designed to route allegations of internal misconduct to qualified compliance, legal, or audit personnel who have the authority and training to handle them appropriately. Using this channel protects the reporting employee from retaliation and preserves the integrity of any subsequent formal investigation. It also ensures the FI can meet its regulatory obligation to investigate and, if warranted, file a suspicious activity report.

CWarn colleagues and customers of the F1 that the employee's suspicious financial investment

Warning colleagues and customers publicly would likely constitute tipping off, could harm an innocent person's reputation, and would undermine any formal investigation.

DConduct an open-source intelligence investigation using artificial intelligence tools to gain more

Conducting an independent OSINT investigation exceeds the employee's authorized role, could contaminate or taint evidence, and introduces legal, privacy, and data protection risks.

EReport the suspected employee to the line manager of the F1 to take the required action

Reporting to a line manager is not the designated channel because the manager may lack the independence, authority, or specialized training to handle financial crime allegations appropriately, and using the whistleblowing channel ensures proper escalation and confidentiality.

Concept tested: Internal whistleblowing procedures for suspected financial crime

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

Topics

#whistleblowing#internal reporting#insider threat#suspicious activity

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