Acams Exam CAMS-FCI Topic 4 Question 19 Discussion

Actual exam question for Acams's CAMS-FCI exam

Question #: 19
Topic #: 4

SAR/STR NARRATIVE

A SAR/STR has been submitted on five transactions conducted on the correspondent banking relationship with ABC Bank.

Client Information:

Remitter information: DEF Oil Resource Ltd. is the oldest member of the DEF Group. It was founded in 1977 as a general trading business with a primary focus on exports from Africa and North Americ

a. The group has business activities that span the entire energy value chain. Their core field of endeavor is centered within the oil and gas industry and its associated sub-sectors.

Beneficiary Information:

As per the response received from ABC Bank, it was determined that the beneficiaries are related to DEF Oil Resource Ltd. These were created by DEF Oil Resource Ltd. to purchase property in a foreign country on behalf of their senior management as part of a bonus scheme. The purpose behind this payment was for the purchase of property in another country.

Payment Reference:

ABCXXXXX31PZFG2H

ABCXXXXXX51PQGEH

ABCXXXXXX214QWVG

ABCXXXXXX41PSXA2

ABCXXXXXX815QWS3

Concerns:

* We are unsure about the country of incorporation of the beneficiaries.

* We are concerned about the transactional activity since the payment made towards entities (conducted on behalf of individuals) appears to be possible tax evasion.

* There appears to be an attempt to conceal the identity of individuals (senior management), which again raises concerns about the source of funds.

* Referring to the response received from ABC Bank, we are unclear about the ultimate beneficiary of funds.

* The remitter is involved in a high-risk business, (i.e., oil and crude products trading), and the beneficiary is involved in real estate business which again poses a higher risk.

When drafting the SAR/STR narrative, the investigator notes several payment references. What additional information should the investigator include in the narrative?

AThe investigator's concerns based on their subjective opinion

BThe suspicious accounts and transactions identified

CAll relevant tables, spreadsheets, and other supporting documentation

DPersonal tax records pertinent to the owners to indicate tax evasion

Show Suggested Answer

Suggested Answer: B

The SAR/STR narrative should include the suspicious accounts and transactions identified, as well as the reasons why they are considered suspicious. The narrative should provide a clear and concise description of the activity, the parties involved, the dates, amounts, and frequencies of the transactions, and any other relevant information that would assist law enforcement in understanding the nature and purpose of the activity. The narrative should not include the investigator's subjective opinion, personal tax records, or supporting documentation that is not essential to explain the suspicious activity. Supporting documentation can be attached separately to the SAR/STR form or provided upon request by law enforcement.

by Zita at Aug 02, 2025, 07:01 PM

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Elena

1 days ago

I agree, the payment references are key. But the investigator should also highlight the concerns about the beneficiaries' identities and the potential tax evasion. That could be a major clue.

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Arlie

5 days ago

The suspicious payment references are definitely crucial information to include in the narrative. We need to dig deeper into those transactions to uncover any potential red flags.

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