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Acams CAMS-FCI Exam - Topic 4 Question 19 Discussion

Actual exam question for Acams's CAMS-FCI exam
Question #: 19
Topic #: 4
[All CAMS-FCI Questions]

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?

Show Suggested Answer Hide 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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Britt
3 months ago
Why are they buying property for senior management? Seems fishy!
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James
3 months ago
Totally agree, the high-risk nature of the businesses raises red flags.
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Ruthann
3 months ago
Wait, are we sure about the identity of those beneficiaries?
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Theresia
3 months ago
DEF Oil Resource Ltd. has been around since 1977.
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Trina
4 months ago
Sounds like a classic case of potential tax evasion.
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Judy
4 months ago
I recall that the narrative should clearly outline the investigator's concerns, but I wonder if we should also emphasize the high-risk nature of the businesses involved.
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Lai
4 months ago
I'm a bit confused about whether personal tax records would be necessary here. It feels like it could strengthen the case for tax evasion, but I'm not entirely sure.
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Diane
4 months ago
I think we practiced a similar question where we had to identify relevant supporting documentation. It seems crucial to include that in the narrative as well.
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Lilli
4 months ago
I remember we discussed the importance of including suspicious accounts and transactions in the narrative, but I'm not sure if we should focus on subjective opinions too.
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Cassi
5 months ago
I feel pretty confident about this one. The question is giving me a good sense of what the investigator is looking for - the suspicious accounts and transactions, as well as the rationale behind the concerns. I'll make sure to cover all of that thoroughly in the narrative.
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Reena
5 months ago
This seems straightforward enough. The investigator has already identified the key concerns, so I'll make sure to clearly outline those in the narrative. I'll also be sure to include the specific payment references to provide a clear trail of the suspicious transactions.
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Tracey
5 months ago
I'm a bit confused by all the details in this question. There's a lot of information to sift through. I'll need to take my time and really analyze each aspect carefully to make sure I don't miss anything important. The payment references will definitely be crucial to include.
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Juliann
5 months ago
Okay, I think I've got a good handle on this. The key is to focus on the investigator's concerns - the unclear country of incorporation for the beneficiaries, the potential tax evasion, the attempt to conceal identities, and the high-risk nature of the businesses involved. I'll make sure to thoroughly document all of those points in the narrative.
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Malcom
5 months ago
Hmm, this question seems tricky. I'll need to carefully review all the details about the transactions, the client information, and the concerns raised. I'll make sure to include the specific payment references and any other relevant details that could support the suspicious activity.
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Dortha
6 months ago
Haha, yeah, maybe they can get the beneficiaries to do a little dance while they're at it. Just to really drive the point home, you know?
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Leila
6 months ago
They'd probably expose themselves more doing that!
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Gabriele
6 months ago
Right? Just complicates things further.
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Carmela
6 months ago
A dance? That would be interesting.
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Levi
6 months ago
Can you imagine that? Totally absurd.
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Terrilyn
6 months ago
I agree, the remitter and beneficiary information raises red flags.
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Rosalyn
7 months ago
Good point. The investigator should keep it professional and not get too personal. Although, if they could get their hands on some juicy tax evasion details, that would make for a pretty spicy SAR/STR narrative!
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Jame
6 months ago
A: The investigator should focus on the suspicious accounts and transactions identified.
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Ernestine
7 months ago
I think the SAR/STR on the transactions with ABC Bank is concerning.
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Lyndia
7 months ago
Hmm, I'm not sure about including personal tax records. That might be overstepping a bit. Stick to the facts and the concerns based on the information provided.
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Carissa
6 months ago
Including the suspicious accounts and transactions identified is crucial for the SAR/STR narrative.
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Na
6 months ago
I agree, sticking to the facts is important in the narrative.
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Elena
7 months 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
7 months 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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Natalie
6 months ago
B) The suspicious accounts and transactions identified
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Vonda
6 months ago
A) The investigator's concerns based on their subjective opinion
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