Acams CAMS-FCI Exam - Topic 4 Question 6 Discussion

Actual exam question for Acams's CAMS-FCI exam

Question #: 6
Topic #: 4

An investigator receives an alert documenting a series of transactions. A limited liability corporation (LLC) wired 59.000,000 USD to an overseas account associated with a state-run oil company. A second account associated with the state-run oil company wired 600,000,000 USD to the LLC. The LLC then wired money to other accounts, a money brokerage firm, and real estate purchases.

The investigator initiated an enhanced KYC investigation on the LLC. The financial institution opened the LLC account a couple of weeks prior to the series of transactions. The names associated with the LLC had changed multiple times since the account opened. A search of those names revealed relations with multiple LLCs. Public records about the LLCs did not show any identifiable business activities.

Open-source research identified mixed reports about the brokerage firm. The firm indicated it purchased mutual funds for its clients and dispensed returns to clients.

Media reports claimed the firm laundered money by holding for a fee before returning it to investors.

The investigator discovers that the bank has no records pertaining to ownership of the LLC. What would this mean for the bank and/or investigator?

AThe bank may not be able to file a SAR/STR without the ownership data.

BThe bank is out of compliance with beneficial ownership regulations.

CThe bank is out of compliance with CIP regulations.

DThe bank cannot respond to law enforcement requests without the ownership data.

Show Suggested Answer

Suggested Answer: C

The bank is out of compliance with CIP regulations because it did not obtain the minimum identifying information from the customer prior to opening the account, as required by 31 CFR 1020.220(a)(2)(i)(A). The bank should have obtained the name, date of birth, address, and identification number of the customer, as well as verified the identity of the customer to the extent reasonable and practicable. The lack of ownership data may also indicate a violation of beneficial ownership regulations, but that is not the primary issue in this case.

by Bethanie at Oct 20, 2024, 07:29 AM

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Michael

4 months ago

This is why KYC is so important!

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Elliot

4 months ago

I agree, they must be out of compliance with beneficial ownership regulations.

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Dorsey

4 months ago

Wait, how can they not have ownership records? That seems off.

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Rikki

4 months ago

Definitely sounds like a compliance issue for the bank.

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Deeanna

4 months ago

That's a huge amount of money being wired around!

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Bok

5 months ago

I recall a case study where lack of ownership data hindered law enforcement responses, so option D sounds plausible as well.

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Daniela

5 months ago

This situation seems to touch on CIP regulations too, but I feel like the focus is more on beneficial ownership. Could option C be relevant?

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Dino

5 months ago

I'm not entirely sure, but I think not having ownership data could impact the bank's ability to file a SAR. Maybe option A?

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Ruthann

5 months ago

I remember discussing the importance of beneficial ownership regulations in class, so I think option B might be the right choice.

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Vashti

5 months ago

This seems straightforward to me. The bank's lack of ownership data for the LLC means they can't file a proper SAR/STR, so that's the obvious answer.

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Chara

5 months ago

I'm a bit confused by all the different entities and transactions involved. I'll need to carefully review the details and make sure I understand the full scope of the issue before deciding on the best answer.

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Yen

5 months ago

Okay, I think I've got a handle on this. The key is figuring out whether the bank is out of compliance with beneficial ownership or CIP regulations. That will guide my response.

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Mendy

5 months ago

Hmm, the lack of ownership data for the LLC is definitely concerning. I'll need to think through the implications for the bank's compliance and ability to respond to the investigation.

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Meaghan

5 months ago

This seems like a tricky one. I'll need to carefully review the details about the LLC and the brokerage firm to try to determine the best approach.

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Darell

1 year ago

This bank needs to hire a team of bloodhounds to sniff out the missing ownership data. Option B is the clear choice, but I'd also suggest they invest in a few extra coffee makers for the compliance team.

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Mike

1 year ago

D) The bank cannot respond to law enforcement requests without the ownership data.

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Quentin

1 year ago

C) The bank is out of compliance with CIP regulations.

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Farrah

1 year ago

B) The bank is out of compliance with beneficial ownership regulations.

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Tess

1 year ago

A) The bank may not be able to file a SAR/STR without the ownership data.

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Kayleigh

1 year ago

That could be a problem for the investigator. They need that information to track down the money laundering.

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Halina

1 year ago

Ah, the old 'I forgot where I put the ownership data' excuse. Classic bank move. Option B is the only option that won't land them in even deeper trouble.

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Macy

1 year ago

They better get their act together before things escalate.

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Clarence

1 year ago

Agreed, option B is the safest bet for the bank.

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Carlene

1 year ago

Definitely, they need to have their ducks in a row.

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Remona

1 year ago

Yeah, that excuse won't fly with regulators.

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Shantell

1 year ago

Hmm, this is a tricky one. I bet the bank wishes they had a magic wand to make this problem disappear. Option B is the way to go, but I'm feeling a bit of a headache coming on just thinking about it.

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Tula

1 year ago

Whoa, this is a messy situation. The bank definitely needs to get their act together and comply with the beneficial ownership rules. Option B is the clear choice.

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