Which steps are the correct ways of collecting the additional information?

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.

View Answer

Answer: A, D

Explanation:

The correct answer is A and C because these indicators suggest that the customer is using fraudulent documents and misrepresenting the goods to conceal the illicit nature of the transactions. Fentanyl traffickers often use front companies and falsified invoices to disguise their shipments as legitimate products, such as medical supplies or chemicals. Reviewing the invoices and transportation documents, as well as the FDA product certifications, can help to identify discrepancies or anomalies that indicate fraud or deception.

Reference: Fentanyl and Fentanyl Analogues: Federal Trends and Trafficking Patterns, page 18; Fentanyl Trafficking Offenses, page 2.