What should the financial crime investigator do next?

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.

View Answer

Answer: C

Explanation:

The correct answer is C. Escalate to the compliance officer/money laundering reporting officer to file a SAR/STR. This is because the financial crime investigator has found evidence of fraudulent documents and false information, which indicate a high risk of money laundering or other financial crimes. The investigator should not contact the client directly, as this may tip them off or compromise the investigation. The investigator should also not report collusion between the cryptocurrency exchange and internal staff, as this is an assumption that has not been verified. The investigator should not request a CDD refresh, as this is not sufficient to address the serious issues identified.

Reference: Advanced CAMS-FCI Study Guide, page 291

Advanced CAMS-FCI Study Guide, page 311

Advanced CAMS-FCI Study Guide, page 331

1: https://www.acams.org/en/certifications/advanced-cams/advanced-financial-crimes-investigations