Acams Advanced CAMS-Financial Crimes Investigations CAMS-FCI Exam Questions

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Total 101 questions
Question 1

An investigator is reviewing a case generated from the transaction monitoring system, with two large amounts of incoming remittance (IR) to an individual customer. Based on the KYC profile, the customer is a plant manager of a famous multi-national electronics manufacturing firm. As the customer has no similarly large transaction patterns for the past 2 years, the investigator sends an inquiry to the relationship manager (RM) about the nature of the transaction. The RM replies that the transaction is a consultancy fee provided from two different electronics companies with a debit note provided However, there is no detail of service provided on the debit note, and the remitters are two individuals.

Which actions should the investigator recommend to mitigate risk? (Select Two.)



Answer : D, E

The actions that the investigator should recommend to mitigate risk are conducting enhanced due diligence (D) and re-evaluating the customer risk profile (E). These actions are appropriate and prudent, as they allow the investigator to obtain more information and evidence about the nature and purpose of the transactions, the source and destination of the funds, and the identity and legitimacy of the parties involved. According to the ACAMS Advanced Financial Crimes Investigations Certification Study Guide1, ''the FI should conduct enhanced due diligence on all parties involved in the investigation, including checking various sources of information, such as watch lists, sanctions lists, negative news, and official registries'' (p. 24). The FI should also ''re-assess the customer risk profile based on any new information obtained during the investigation, and adjust the customer due diligence and monitoring requirements accordingly'' (p. 25).

The other options are not as appropriate or effective as options D and E. The investigator should not recommend exiting the relationship with the customer (A), as this could be premature or disproportionate, as well as potentially discriminatory or illegal. The investigator should not recommend documenting and maintaining a file with the investigative findings (B), as this is not an action to mitigate risk, but rather a standard procedure for any investigation. The investigator should not recommend discussing the investigation findings with the customer , as this could compromise the integrity and objectivity of the investigation, as well as expose the FI to legal or regulatory risks.


Question 2

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?



Answer : B

The activity type that the FI should target for creating an automated alert for human trafficking money laundering is multiple deposits between midnight and 4:00 AM (B). This is because this pattern is consistent with the indicators of human trafficking identified by the Financial Action Task Force (FATF) and the Egmont Group1, which include:

Frequent cash deposits, often in round amounts, outside of normal business hours

Deposits made at different branches or ATMs in various locations

Lack of information about the nature and purpose of the business

Involvement in online platforms that advertise sexual services

Expenses related to travel and accommodation

The other options are not as relevant or specific as option B. Payments made to multiple hotels in the same city (A) could be a legitimate business expense or a sign of other types of money laundering, such as tax evasion or fraud. Deposits made within days of major sporting events could also be explained by other factors, such as increased tourism or gambling. Payments made for virtual currency (D) are not directly related to human trafficking, although they could be used to facilitate money laundering in general.


Question 3

A client at a financial institution deposits large amounts of money into an account, and almost immediately, the funds are then distributed to numerous individuals' accounts. The transaction activity described in the scenario is a pattern of:



Answer : B

Deposit trading is a pattern of suspicious activity where a client deposits large amounts of money into an account, and then transfers the funds to other accounts, often in different jurisdictions or countries. This could be an attempt to disguise the source or destination of the funds, or to avoid reporting requirements. Deposit trading is also known as layering, which is the second stage of money laundering.


Question 4

Law enforcement agents arrive at a broker-dealer's premises with a search warrant. In addition to cooperation with the warrant, which instructions should the person in charge of the broker-dealer provide to their employees?



Answer : A

The instruction that the person in charge of the broker-dealer should provide to their employees is to take notes on the questions and comments made by the agents (A). This is because taking notes can help the employees to recall and document what happened during the search warrant execution, which can be useful for legal or regulatory purposes. According to ACAMS3, ''the FI should instruct its staff to cooperate with LE agents during a search warrant execution, but also to take notes of what is being searched, seized, or asked by the agents'' (p. 35). The FI should also ''keep copies of any documents or records that are taken by LE agents'' (p. 35).

The other instructions are not correct. The person in charge of the broker-dealer should not instruct their employees to sign consent forms permitting the agents to search employees' offices (B), as this is unnecessary and potentially risky, as the agents already have a valid search warrant that authorizes them to search the premises. The person in charge of the broker-dealer should not instruct their employees to provide agents with unlimited access to customers' personal data , as this could violate privacy or data protection laws, as well as compromise customer trust and confidentiality. The person in charge of the broker-dealer should not instruct their employees to volunteer information not requested by the agents that they think may be useful (D), as this could interfere with the LE investigation or expose them to legal or regulatory risks.


Introduction to Transnational Organized Crime

ACAMS Law Enforcement and Financial Crimes Investigations eLearning Course Module

Law Enforcement Requests and Actions

Question 5

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 Chin

a. 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.)



Answer : A, D

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.


Question 6

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 Cub

a. 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.)



Answer : A, E, F

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.


Question 7

Which most likely indicates that a business email compromise attack has occurred?



Answer : A

When writing or reviewing a SAR/STR, it is important to ensure that the narrative is kept to the point; easy to read; and addresses the who, what, when, where, why, and how. This is because the narrative is the most crucial part of the SAR/STR, as it provides a clear and concise summary of the suspicious activity or transaction that triggered the report. The narrative should include all the relevant information that would help law enforcement or regulators to understand the nature and context of the activity or transaction, such as123:

The who: The names, addresses, account numbers, and other identifying information of the parties involved in the activity or transaction, such as customers, beneficiaries, intermediaries, or third parties.

The what: The type, amount, frequency, and purpose of the activity or transaction, such as cash deposits, wire transfers, check payments, or purchases of goods or services.

The when: The date, time, and duration of the activity or transaction, and whether it was a one-time occurrence or part of a pattern or trend.

The where: The location or channel of the activity or transaction, such as branches, ATMs, online platforms, or mobile applications.

The why: The reason or rationale for the activity or transaction, and why it was considered suspicious or unusual based on the customer's profile, behavior, or expected activity.

The how: The method or mechanism of the activity or transaction, such as cash, check, debit card, credit card, cryptocurrency, or prepaid card.


How to write the perfect ''Suspicious Activity Reports'' (SAR)? | i-AML

Writing for Prosecution: Best Practices For Composing SAR Narratives That Assist Prosecutors | ACAMS

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Total 101 questions