CAMS · Question #999
A financial institution's transaction monitoring system flags an unusually high volume of international wire transfers originating from a small business account. The transfers are being sent to…
The correct answer is A. Review the transaction history of the account to identify patterns, including the frequency. A: The first step in any suspicious activity investigation is to review the transaction history and other relevant account information to establish context, identify patterns, and determine if the behavior is consistent with known typologies of money laundering. "The initial…
Question
A financial institution's transaction monitoring system flags an unusually high volume of international wire transfers originating from a small business account. The transfers are being sent to multiple jurisdictions known for limited regulatory oversight. Additionally, an employee reports suspicious behavior from the account holder during an in-person visit, where they requested a large cash withdrawal without providing a clear business justification. As part of the investigation, the compliance team must assess whether this activity is suspicious and determine the appropriate next steps. Which of the following steps should be taken first in the investigation process to properly gather information and assess whether the transactions are suspicious?
Options
- AReview the transaction history of the account to identify patterns, including the frequency,
- BNotify senior management and suggest account closure due to potential risks
- CImmediately file a suspicious activity report (SAR) based on the employee's report of suspicious
- DContact the customer directly to ask for clarification on the reason for the large cash withdrawal
How the community answered
(55 responses)- A73% (40)
- B4% (2)
- C16% (9)
- D7% (4)
Explanation
A: The first step in any suspicious activity investigation is to review the transaction history and other relevant account information to establish context, identify patterns, and determine if the behavior is consistent with known typologies of money laundering. "The initial phase of an AML investigation is to review relevant account information and transaction activity to assess whether a SAR filing is warranted." This approach ensures that any subsequent decisions, such as escalation, SAR filing, or customer outreach, are based on a comprehensive understanding of the facts.
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