Discuss Acams CAMS Exam Topic 3 Question 114

A compliance officer at a U.S. financial institution receives a grand jury subpoena requesting customer records related to an ongoing money laundering investigation involving a politically exposed person (PEP).

What should the compliance officer do first?

ANotify the customer and seek consent

BConsult with the institution's legal counsel to assess validity and determine the appropriate response

CImmediately provide records to the grand jury

DFile a Suspicious Activity Report (SAR) describing receipt of the subpoena

Suggested Answer: B

When a financial institution receives a grand jury subpoena, it is legally compelled to respond, but must do so in a controlled, lawful, and coordinated manner.

The first step is to consult with legal counsel to verify the subpoena's validity, scope, deadlines, and confidentiality requirements. Legal counsel ensures the institution responds accurately, protects privileged information, and complies with applicable laws.

Notifying the customer would constitute tipping off, which is prohibited. Immediate disclosure without legal review may result in over-disclosure or violation of customer privacy laws. Filing a SAR may be appropriate depending on the facts, but it is not the first step and must not reference the subpoena.

This approach aligns with U.S. AML, BSA, and law enforcement cooperation requirements.

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17 comments · newest first

Elli 1 month ago

I feel like option B is the safest route.

Carman 2 months ago

Filing a SAR is important, but not the first step here.

Shad 2 months ago

Immediate action is risky; option C is not wise.

Jody 2 months ago

Option A could lead to issues, better to get legal advice first.

Carolynn 2 months ago

Notifying the customer could complicate things.

Sophia 2 months ago

Definitely, they need to assess the validity of the subpoena.

Chauncey 2 months ago

Agreed, option B makes the most sense.

Suzi 3 months ago

I think the compliance officer should consult legal counsel first.

Carin 3 months ago

B is the safest route, but what if the PEP is a big client?

Valentine 3 months ago

I think D might be necessary too, right?

Stephen 3 months ago

Surprised this is even a question, isn't it obvious?

Cathrine 3 months ago

A is a bad idea, you can't just notify the customer.

Malcom 4 months ago

Definitely B, always consult legal first!

Sharan 4 months ago

I feel like immediately providing records could lead to serious issues, especially with a PEP involved. Consulting legal seems like the right move to start with.

Galen 4 months ago

I practiced a similar question, and I believe that filing a SAR might be necessary, but it feels like it should come after consulting legal first.

Cherelle 4 months ago

I'm not entirely sure, but I remember something about not notifying the customer in these cases. Maybe that's why option A isn't the best choice?

Daryl 4 months ago

I think the first step should be to consult with legal counsel. It seems like the safest option to assess the situation properly.

Acams CAMS Exam - Topic 3 Question 114 Discussion