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Acams CAMS Exam - Topic 3 Question 114 Discussion
Topic #: 3
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?
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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