What steps should the investigator perform in reference to the first client’s existing accounts?

A client with many personal and business deposits with the financial institution (Fl) seeks a business loan. The client wants to guarantee the loan with a trust for which they are the beneficiary.

An investigator examines the trust. The trust has many layers, including shell companies in known tax havens. The client’s ultimate beneficial ownership claim cannot be validated, and the loan is denied. Two months later, the Fl receives a law enforcement (LE) request on one of the client’s business accounts. While reviewing the business account, the Fl receives another LE request on the same account from another agency. The requested information is shared.

Three months later, a branch manager receives a request to open a business deposit account related to a complex trust. The manager forwarded the request because of the complexity. The trust was the same as the previously examined trust, but the request came from a different client. The second client also has many accounts with the Fl. Further inspection finds links between the second client and the Paradise Papers. The Papers state the client led illegal activities and committed tax evasion.

What steps should the investigator perform in reference to the first client’s existing accounts? (Select

Three.)
A . Review all client-signed documents relating to all accounts.
B . File SARs/STRs for all accounts at the beginning of the discovery phase and amend later as necessary.
C . Inform Fl management of all processes used to investigate the client due to LE inquiry.
D . Perform secondary scans of the client’s other owners/authorized signers
E . Review Fl approved policies regarding the existing accounts to ensure regulatory requirements were followed.
F . Prepare a relationship flow chart of all existing accounts to better understand the client’s activities.

View Answer

Answer: A, D, F

Explanation:

The investigator should review all client-signed documents relating to all accounts (A) to check for any discrepancies or red flags. The investigator should also perform secondary scans of the client’s other owners/authorized signers (D) to identify any possible connections or associations with the second client or the Paradise Papers. Additionally, the investigator should prepare a relationship flow chart of all existing accounts (F) to better understand the client’s activities and patterns. These steps are consistent with the ACAMS Advanced Financial Crimes Investigations Certification Study Guide1, which states that investigators should “review all relevant documentation, including account opening documents, transaction records, and customer correspondence” (p. 23), “conduct enhanced due diligence on all parties involved in the investigation” (p. 24), and “use data visualization tools to map out complex relationships and transactions” (p. 25).

Reference: 1: ACAMS Advanced Financial Crimes Investigations Certification Study Guide, available at ACAMS