Which are the next steps the investigator should take?

The investigative department of a financial institution (Fl) receives an internal escalation notice from the remittance department for a SWIFT message requesting a refund due to potential fraud. The notice indicates that a total of three international incoming remittances were transferred to a corporate customer from Country A, in the amount of approximately 5 million EUR for each. The first two incoming remittances had been exchanged into currency B and transferred out to Country B a few days ago. The third incoming remittance has been held by the remittance department.

As noted from the KYC profile, the corporate customer is working in the wood industry. with the last account review completed 3 months ago. Since the account’s opening. there has been no history of a large amount of funds flowing through the account. The investigator conducts an Internet search and finds that the remitter is a food beverage company.

The same morning, the investigator receives a call from a financial intelligence unit (FIU) inquiring about the same incident. The FIU states that it will issue a warrant to freeze the account on the same day.

After further review, the decision is made that transactions appear suspicious.

Which are the next steps the investigator should take? (Select Two.)
A . Close the customer’s accounts since the FIU is issuing a warrant to freeze the funds.
B . Contact local LE and advise them of the investigation details to help speed up the investigation and prosecution.
C . Provide additional information to the LE upon receiving a formal request.
D . Close the investigation as the FIU is already on this matter, and they will inform LE if needed.
E . Gather all the information that would be useful for law enforcement (LE) and recommend filing a
SAR/STR

View Answer

Answer: C, E

Explanation:

The correct answer is C and E. The investigator should provide additional information to the LE upon receiving a formal request, and gather all the information that would be useful for LE and recommend filing a SAR/STR. These steps are consistent with the best practices of conducting financial crime investigations and reporting suspicious activity. The investigator should not close the customer’s accounts or the investigation, as this may interfere with the ongoing LE inquiry and violate the FI’s policies and procedures. The investigator should also not contact local LE directly, as this may compromise the confidentiality of the investigation and the FIU’s authority.

Reference: Advanced CAMS-FCI Study Guide, Chapter 4: Reporting Suspicious Activity, pages 40-411 Advanced CAMS-FCI Study Guide, Chapter 5: Governance of an AFC Investigations Unit, pages 48-491 Advanced CAMS-FCI Certification | ACAMS