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ACAMS AML Certifications CAMS-FCI Question # 9 Topic 1 Discussion

CAMS-FCI Exam Topic 1 Question 9 Discussion:
Question #: 9
Topic #: 1

An analyst reviews an alert for high volume Automated Clearing House (ACH) activity in an account. The analyst's initial research finds the account is for a commercial daycare account that receives high volumes of large government-funded ACH transactions to support the programs. The account activity consists of checks (cheques) made payable to individual names in varying dollar amounts. One check indicates rent to another business.

An Internet search finds that the daycare company owner has previous government-issued violations for safety and classroom size needs, such as not having enough chairs and tables per enrollee. These violations were issued to a different daycare name.

Simultaneous to this investigation, another analyst sends an email about negative news articles referencing local child/adult daycare companies misusing governmental grants. This prompts the financial institution (Fl) to search all businesses for names containing daycare' or 'care1. Text searches return a number of facilities as customers at the Fl and detects that three of these businesses have a similar transaction flow of high volume government ACH funding with little to no daycare expenses.

During the investigation, it was determined that some of the checks were issued to a mother-in-law of a PEP and deposited into her account with the Fl. This customer was not found on the Fl's PEP list How should the investigator proceed in this situation"? (Select Two.)


A.

Conduct the investigation as usual, since the activity in question is not directly connected to the PEP.


B.

Reter the newly identified customers account for closure due to the high risk associated with the potential PEP.


C.

Use this case as an example to train employees to recognize potential PEPs during their investigation process.


D.

Send a referral to Sanctions/List Screening, or similar department/responsible individual, to ensure that the customer due diligence information is up to date.


E.

File a SAR/STR due to the potential involvement of a PEP.


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