Which investigative actions should the investigator take concerning the 100.000 USD wire transfer?

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.

Which investigative actions should the investigator take concerning the 100.000 USD wire transfer? (Select Three.)
A . Review the wire transfer protocols for this customer.
B . Gather all account activity for Fl clients that purchased packages from the airline.
C . Review a sampling of wire transfers initiated by travel companies with Cuba travel packages.
D . Recommend a plan for the Fl’s management to restrict the account relationship.
E . Review regulations applicable to foreign currency trading transactions.
F . Locate and review licenses, registrations, and account operating agreements associated with the MTB account.

View Answer

Answer: A, E, F

Explanation:

The investigator should take the following investigative actions concerning the 100,000 USD wire transfer:

Review the wire transfer protocols for this customer. This will help the investigator to determine if the wire transfer is consistent with the customer’s normal business activity and risk profile, or if it deviates from the established patterns or thresholds.

Review regulations applicable to foreign currency trading transactions. This will help the investigator to assess if the wire transfer violates any laws or regulations related to currency exchange, such as reporting requirements, licensing requirements, or sanctions compliance.

Locate and review licenses, registrations, and account operating agreements associated with the MTB account. This will help the investigator to verify if the MTB has the necessary authorization and documentation to conduct currency exchange transactions and if it has disclosed this activity to the FI.

Reference: Advanced CAMS-FCI Study Guide, pages 32-33.