What documentation should be referenced in the SAR/STR filing?

A financial institution (Fl) banks a money transmitter business (MTB) located in Miami. The MTB regularly initiates wire transfers with the ultimate beneficiary in Cuba and legally sells travel packages to Cuba. The wire transfers for money remittances comply with the country’s economic sanctions policies. A Fl investigator on the sanctions team reviews each wire transfer to ensure compliance with sanctions and to monitor transfer details.

An airline located in Cuba, unrelated to the business, legally sells airline tickets in Cuba to Cuban citizens wanting to travel outside of Cuba. The airline tickets are purchased using Cuban currency (CUC).

The MTB wants 100,000 USD worth of CUC. Purchasing CUC from a Cuban bank includes a 4% fee. The MTB contacts the airline to ask if the airline will trade its CUC for USD at a lower exchange fee than the Cuban bank. The airline agrees to a 1% fee. The MTB initiates a wire transfer to the airline which appears as normal activity in the monitoring system because of the business’ travel package sales.

The investigator recommends that a SAR/STR be filed.

What documentation should be referenced in the SAR/STR filing? (Select Three.)
A . All documents related to the agreement between the airline and the MTB
B . Cumulative dollar amount of the wire transfer activity
C . Airline’s ticket sales and passenger list
D . Cumulative dollar amount for transactions listing for all the MTB account’s wire activity regarding travel packages
E . Licensing information regarding the travel agency providing tourist sales to Cuba
F . Account documentation on all related accounts maintained by the MTB

View Answer

Answer: B

Explanation:

The most likely reason for conducting a reverse transaction is to conceal or launder illicit funds. A reverse transaction is a transaction that reverses a previous transaction, such as a refund, a chargeback, or a cancellation. Reverse transactions can be used by money launderers to obscure the source, ownership, or destination of funds, or to create false records or invoices. For example, a money launderer may initiate a wire transfer from a high-risk jurisdiction to a low-risk jurisdiction, and then reverse the transaction after receiving confirmation of the funds. This way, the money launderer can create a paper trail that shows legitimate funds coming from a low-risk jurisdiction, while hiding the true origin of the funds.

Reference: Advanced CAMS-FCI Study Guide, page 40-41.