ACAMS CAMS-FCI Advanced CAMS-Financial Crimes Investigations Online Training
ACAMS CAMS-FCI Online Training
The questions for CAMS-FCI were last updated at Mar 31,2025.
- Exam Code: CAMS-FCI
- Exam Name: Advanced CAMS-Financial Crimes Investigations
- Certification Provider: ACAMS
- Latest update: Mar 31,2025
An investigator at a corporate bank is conducting transaction monitoring alerts clearance.
KYC profile background: An entity customer, doing business offshore in Hong Kong, established a banking business relationship with the bank in 2017 for deposit and loan purposes. It acts as an offshore investment holding company.
The customer declared that the ongoing source of funds to this account comes from group-related companies.
• X is the UBO. and owns 97% shares of this entity customer;
• Y is the authorized signatory of this entity customer.
This entity customer was previously the subject of a SAR/STR.
KYC PROFILE
Customer Name: AAA International Company. Ltd
Customer ID: 123456
Account Opened: June 2017
Last KYC review date: 15 Nov 2020
Country and Year of Incorporation: The British Virgin Islands, May 2017
AML risk level: High
Account opening and purpose: Deposits, Loans, and Trade Finance
Anticipated account activities: 1 to 5 transactions per year and around 1 million per transaction amount
During the investigation, the investigator reviewed remittance transactions activities for the period from Jul 2019 to Sep 2021 and noted the following transactions pattern:
TRANSACTION JOURNAL
Review dates: from July 2019 to Sept 2021 For Hong Kong Dollars (HKD) currency:
Incoming transactions: 2 inward remittances of around 1.88 million HKD in total from different third parties
Outgoing transactions: 24 outward remittances of around 9 4 million HKD in total to different third parties
For United States Dollars (USD) currency:
Incoming transactions: 13 inward remittances of around 3.3 million USD in total from different third parties
Outgoing transactions: 10 outward remittances of around 9.4 million USD in total to different third parties.
RFI Information and Supporting documents:
According to the RFI reply received on 26 May 2021, the customer provided the bank with the information below:
1) All incoming funds received in HKD & USD currencies were monies lent from non-customers of the bank. Copies of loan agreements had been provided as supporting documents. All of the loan agreements were in the same format and all the lenders are engaged in trading business.
2) Some loan agreements were signed among four parties, including among lenders. borrower (the bank’s customer), guarantor, and guardian with supplemental agreements, which stated that the customer, as a borrower, who failed to repay the loan
Which additional information would support escalating this account for closure?
- A . The bank files SARs/STRs indicating that Y opened accounts for small companies located in close proximity to the bank.
- B . A follow-up request reveals that the account receives funds from loans, collects payments from group-related companies, and sends the payments to the lenders.
- C . A review of outward remittances reveals the same pattern of several simple steps for each transaction,
- D . A review of X’s personal bank account shows that X received wire transfers that aggregate the amounts transferred to the group-related companies.
An investigator at a corporate bank is conducting transaction monitoring alerts clearance.
KYC profile background: An entity customer, doing business offshore in Hong Kong, established a banking business relationship with the bank since 2017 for deposit and loan purposes. It acts as an offshore investment holding company. The customer declared that the ongoing source of funds to this account comes from group-related companies.
• X is the UBO. and owns 97% shares of this entity customer;
• Y is is the authorized signatory of this entity customer.
This entity customer was previously the subject of a SAR/STR.
KYC PROFILE
Customer Name: AAA International Company. Ltd
Customer ID: 123456
Account Opened: June 2017
Last KYC review date: 15 Nov 2020
Country and Year of Incorporation: The British Virgin Islands, May 2017
AML risk level: High
Account opening and purpose: Deposits, Loans and Trade Finance
Anticipated account activities: 1 to 5 transactions per year and around 1 million per transaction amount
During the investigation, the investigator reviewed remittance transactions activities for the period from Jul 2019 to Sep 2021 and noted the following transactions pattern:
TRANSACTION JOURNAL
Review dates: from July 2019 to Sept 2021 For Hong Kong Dollars (HKD) currency:
Incoming transactions: 2 inward remittances of around 1.88 million HKD in total from different third parties
Outgoing transactions: 24 outward remittances of around 9 4 million HKD in total to different third parties
For United States Dollars (USD) currency:
Incoming transactions: 13 inward remittances of around 3.3 million USD in total from different third parties
Outgoing transactions: 10 outward remittances of around 9.4 million USD in total to different third parties.
RFI Information and Supporting documents:
According to the RFI reply received on 26 May 2021, the customer provided the bank with the information below:
1) All incoming funds received in HKD & USD currencies were monies lent from non-customers of the bank. Copies of loan agreements had been provided as supporting documents. All of the loan agreements were in the same format and all the lenders are engaged in trading business.
2) Some loan agreements were signed among four parties, including among lenders. borrower (the bank’s customer), guarantor, and guardian with supplemental agreements, which stated that the customer, as a borrower, who failed to repay the loan
After reviewing the transaction journal, request for information response, and supporting documentation, the investigator determines that additional information is needed.
Which additional information should the investigator request?
- A . Previously filed SARVSTR unrelated to the customer, but similar in content
- B . Formation document/description of the group-related companies
- C . Source of the incoming funds to the group-related companies
- D . Adverse news screening on all names listed in the formation documents
CLIENT INFORMATION FORM Client Name: ABC Tech Corp Client ID. Number: 08125 Name: ABC Tech Corp Registered Address: Mumbai, India Work Address: Mumbai, India Cell Phone: "*•"’" Alt Phone: "*""* Email: …….."
Client Profile Information:
Sector: Financial
Engaged in business from (date): 02 Jan 2020 Sub-sector: Software-Cryptocurrency Exchange Expected Annual Transaction Amount: 125,000 USD Payment Nature: Transfer received from clients’ fund
Received from: Clients
Received for: Sale of digital assets
The client identified itself as Xryptocurrency Exchange." The client has submitted the limited liability partnership deed. However, the bank’s auditing team is unable to identify the client’s exact business profile as the cryptocurrency exchange specified by the client as their major business awaits clearance from the country’s regulator. The client has submitted documents/communications exchanged with the regulator and has cited the lack of governing laws in the country of their operation as the reason for the delay.
During the financial crime investigation, the investigator discovers that some of the customer due diligence (CDD) documents submitted by the client were fraudulent. The investigator also finds that some of the information in the financial institution’s information depository is false.
What should the financial crime investigator do next?
- A . Report collusion between the cryptocurrency exchange and internal staff in the internal hotline or whistle-blowing channel.
- B . Request that the relationship manager conduct a CDD refresh as it is a material trigger.
- C . Escalate to the compliance officer/money laundering reporting officer to file a SAR/STR.
- D . Contact the client directly and obtain the relevant notarized documents and information.
CLIENT INFORMATION FORM Client Name: ABC Tech Corp Client I.D. Number: 08125 Name: ABC
Tech Corp Registered Address: Mumbai, India Work Address: Mumbai. India Cell Phone: *■*•"― Alt
Phone: Email: *•*•*«•*•
Client Profile Information:
Sector: Financial
Engaged in business from (date): 02 Jan 2020
Sub-sector: Software-Cryptocurrency Exchange
Expected Annual Transaction Amount: 125.000 USD
Payment Nature: Transfer received from client’s fund
Received from: Clients
Received for: Sale of digital assets
The client identified themselves as "Cryptocurrency Exchange" Client has submitted the limited liability partnership deed. However, the bank’s auditing team is unable to identify the client’s exact business profile as the cryptocurrency exchange specified by the client as their major business awaits clearance from the country’s regulator. The client has submitted documents/communications exchanged with the regulator and has cited the lack of governing laws in the country of their operation as the reason for the delay.
Investigators determine the ultimate beneficial owner of ABC Tech Corp is a high-net-worth client. The client owns a real estate agency left to her when her spouse died. The spouse provided seed capital for ABC Tech Corp through a direct 1,000.000 Great British Pound (GBP) deposit.
What additional information would trigger filing a SAR/STR?
- A . The client’s spouse’s source of wealth was a salary of 250,000 GBP per annum for the past 4 years and rental of properties of 150,000 GBP per annum for the past 6 years.
- B . The client’s current net asset value is 8 million GBP, of which 7.5 million GBP was derived from the inheritance.
- C . An open-source search revealed that the client’s spouse was a PEP.
- D . The funds for the seed capital were in the form of 50 cashier’s checks of 10,000 GBP each and 50 money orders of 10,000 GBP.
During transaction monitoring. Bank A learns that one of their customers. Med Supplies 123. is attempting to make a payment via wire totaling 382,500 USD to PPE Business LLC located in Mexico to purchase a large order of personal protective equipment. specifically surgical masks and face shields. Upon further verification. Bank A decides to escalate and refers the case to investigators. Bank A notes that, days prior to the above transaction, the same customer went to a Bank A location to wire 1,215,280 USD to Breath Well LTD located in Singapore. Breath Well was acting as an intermediary to purchase both 3-ply surgical masks and face shields from China. Bank A decided not to complete the transaction due to concerns with the involved supplier in China. Moreover, the customer is attempting to send a third wire in the amount of 350,000 USD for the purchase of these items, this time using a different vendor in China. The investigator must determine next steps in the investigation and what actions, if any. should be taken against relevant parties.
During the investigation, Bank A receives a USA PATRIOT Act Section 314(a) request related to Med Supplies 123.
Which steps should the investigator take when fulfilling the request? (Select Three.)
- A . Exit the relationship with the business since it appears that customer is under investigation.
- B . Do not respond to Financial Crimes Enforcement Network (FinCEN) if the requested information is not present in the financial institution’s system of records.
- C . Review the account(s) activity and proactively file a SAR/STR using the 314(a) request as the basis for the filing.
- D . Report to Financial Crimes Enforcement Network (FinCEN) that a match was found without revealing any other details.
- E . Report back to the Financial Crimes Enforcement Network (FinCEN) within 15 days of receipt of the request via a secure internet website.
- F . Search its records expeditiously to determine whether it maintains(ed) any accounts for the subject(s) listed in the request.
During transaction monitoring. Bank A learns that one of their customers. Med Supplies 123, is attempting to make a payment via wire totaling 382,500 USD to PPE Business LLC located in Mexico to purchase a large order of personal protective equipment. specifically surgical masks and face shields. Upon further verification. Bank A decides to escalate and refers the case to investigators. Bank A notes that, days prior to the above transaction, the same customer went to a Bank A location to wire 1,215,280 USD to Breath Well LTD located in Singapore. Breath Well was acting as an intermediary to purchase both 3-ply surgical masks and face shields from China. Bank A decided not to complete the transaction due to concerns with the involved supplier in China. Moreover, the customer is attempting to send a third wire in the amount of 350,000 USD for the purchase of these items, this time using a different vendor in China. The investigator must determine next steps in the investigation and what actions, if any. should be taken against relevant parties.
Upon further investigation. Bank As investigator learns that both the Mexico- and Singapore-based companies are linked to the alleged suppliers in China.
Which additional indicators would the investigator need to identify to determine if this fits a fentanyl (drug) trafficking typology? (Select Two.)
- A . Review of the invoices and transportation documents, provided by the customer, reveal significant discrepancies between the description of goods.
Internet research reveals that suppliers are newly established companies with no history of sales of medical equipment. - B . Review of the account activity reveals that wires were mainly funded by multiple cash deposits, conducted in amounts of 10.000 USD or below.
- C . Review of the Food and Drug Administration (FDA) product certifications provided by the customer reveals that documents were falsified.
- D . Review of the account activity reveals that account is inconsistent with the expected business activity as it shows multiple charges at various hotels, transportation tickets for unrelated 3rd parties, etc.
During transaction monitoring. Bank A learns that one of its customers. Med Supplies 123, is attempting to make a payment via wire totaling 382.500 USD to PPE Business LLC located in Mexico to purchase a large order of personal protective equipment. specifically surgical masks and face shields. Upon further verification. Bank A decides to escalate and refers the case to investigators. Bank A notes that days prior to the above transaction, the same customer went to a Bank A location to wire 1,215,280 USD to Breath Well LTD located in Singapore. Breath Well was acting as an intermediary to purchase both 3-ply surgical masks and face shields from China. Bank A decided not to complete the transaction due to concerns with the involved supplier in China. Moreover, the customer is attempting to send a third wire in the amount of 350,000 USD for the purchase of these items, this time using a different vendor in China. The investigator must determine the next steps in the investigation and what actions, if any. should be taken against relevant parties.
The investigator is gathering more information to determine if a SAR/STR filing is needed.
Which steps are the correct ways of collecting the additional information? (Select Two.)
- A . Reach out to the relationship manager asking if more up-to-date customer due diligence information can be collected on the customer.
- B . Use available documentation received from law enforcement (e.g.. grand jury subpoena) as red flags in SAR/STR filing.
- C . Reach out to the customer and ask for supporting documentation for the conducted wires to avoid SAR/STR filing.
- D . Conduct open-source research to determine if the customer and involved counterparties are in the same business field.
- E . Issue a USA PATRIOT ACT Section 314(b) request to participating financial institutions advising that information is needed to decide if the activity is suspicious.
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 take to review the accounts held by the second client who is listed in the Paradise Papers? (Select Two.)
- A . Recommend a SAR/STR be filed regarding the second client’s use of a questionable trust to open an account.
- B . Review all accounts being reviewed by AML investigators over the past year that have opened trust accounts.
- C . Inform Fl management of deficiencies in their AML program because the second client’s activities were not detected.
- D . Monitor all accounts and entities related to the second client
- E . Inform Fl management of the start of a serious risk-based investigation that could result in losses and reputation risk.
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.
Law enforcement (LE) suspects human trafficking to occur during a major sporting event LE officers asked several financial institutions (FIs) to monitor financial transactions occurring before, during, and after the event.
An investigator identified a pattern linked to a business. The business’ account received multiple even dollar deposits between midnight and 4:00 AM. They occurred each day for several days prior to the date of the sporting event. Also, large cash deposits, typically between 2,000 USD and 3,000 USD. made by a person to the business’ account occurred in many branches in the days after the sports event.
There was little information about the company. The company did not have any history of employee payroll expenses or paying taxes. Expenses from the business account included air travel and hotel expenses. Searches about the person making cash deposits showed little. An online social media platform webpage with the individual’s name showed ads for dates1′ and "companionship."
The Fl wants to create an automated alert for human trafficking money laundering after this investigation.
Which activity type should they target?
- A . Payments made to multiple hotels in the same city
- B . Multiple deposits between midnight and 4:00 AM
- C . Deposits made within days of major sporting events
- D . Payments made for virtual currency
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