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CAMS > Module 4 (Part 1 > Flashcards

Module 4 (Part 1 Flashcards

1
Q

What does module 4 cover

A

conducting and responding to investigations

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2
Q

what are 6 common aml/cft investigation initiators

A
  1. Regulatory recommendations or official findings
  2. transaction monitoring
  3. referrals from customer-facing employees
  4. internal hotlines
  5. negative media information
  6. receipt of a governmental subpoena or search warrant
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3
Q

what is the deal with transaction monitoring rules

A

should be reviewed at a regular cadence and tuned accordingly to ensure they operate as designed (think SOAR)

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4
Q

what may tuning practices include

A

evaluating the output of monitoring rules, examining specific thresholds and conducting above and below-the-line testing to determine whether rule adjustments are necessary

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5
Q

what is difference between subpoena and search warrant

A

subpoenas are usually issued by grand juries

warrants are submitted to a court by a LEO via an affidavit stating there is PC that evidence of a crime will be located.

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6
Q

what are the two obligations of a financial institution if they receive a subpoena or a warrant

A
  1. legally fulfill the requirements of the subpoena or warrant
  2. determine whether the activity of its customer identified in the subpoena or warrant requires the filing of a STR
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7
Q

What are the 4 steps into conducting an effective financial investigation

A
  1. Reviewing internal transactions, info from the customer and other relevant internal documentation
  2. Identifying and review external information to understand the customer, related entities, and relevant media
  3. contacting business line employees responsible for the account relationship
  4. generating a written report documenting relevant findings
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8
Q

What does STR stand for

A

Suspicious Transaction Report

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9
Q

What should be drafted regarding STRs

A

procedures that document the factors to consider when determining whether to file an STR

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10
Q

What should a financial institution do once it has decided on filing an STR

A

ensure that the STR filing includes not only

  1. the details f the suspicious activity and the related demographics
  2. why the institution finds the activity suspicious
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11
Q

Based on the internal investigation, the financial institution should do what

A

make an INDEPENDENT DETERMINATION

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12
Q

as to what

A

whether to close the account in issue

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13
Q

what are 5 factors the institution should consider

A
  1. The legal basis for closing an account
  2. the reputational risk to the institution posed by maintaining the account
  3. the institution’s stated policies and procedures for closing an account.
  4. correspondence with law enforcement and requests from law enforcement to either cancel or maintain the account.
  5. the seriousness of the underlying conduct
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14
Q

what are the 8 factors to consider in decision making when considering whether to bring a case against an institution

A
  1. The institution has a criminal history
  2. The institution has had a comprehensive and effective AML/CFT program
  3. Deterring wrongdoing by others is needed and will be served by a prosecution
  4. The institution has cooperated with the investigation
  5. The institution has taken timely and effective remedial action
  6. Advice and recommendations from regulatory agencies and or the fiu for the jurisdiction are available
  7. the institution discovered and self reported the money laundering related issues
  8. there are civil remedies available that can serve as punishment
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15
Q

What should happen when responding to law enforcement investigations

A

the financial institution should designate some one to

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16
Q

to what

A
  1. respond to all law enforcement requests
  2. monitor the progress of the investigation
  3. keep senior management informed of the nature and progress of the investigation
17
Q

what if evidence is required from another jurisdiction

A

a request can be made for MUTUAL LEGAL ASSISTANCE

18
Q

what provides a legal basis for transmitting evidence that can be used for prosecution and judicial proceedings

A

Mutual Legal Assistance Treaties

19
Q

What are financial intelligence units

A

mandatory national agencies that handle financial intelligence

20
Q

what are the 3 ways the FIU contributes towards combatting money laundering

A
  1. Receiving report of suspicious transactions from financial institutions and other persons and entities
  2. Analyzing the reported suspicious transactions
  3. Disseminating the resulting intelligence to local law enforcement agencies and foreign FIUs
21
Q

What do the “Principles of Information Exchange” describe

A

practices that maximize cooperation between FIUs and can be useful to government authorities when considering AML legislation

22
Q

What is the deal with reciprocity and spontaneous exchange

A

The Egmont Principle of free exchange of information at the FIU level should be possible on the basis of reciprocity, including spontaneous exchange

23
Q

What should not be an obstacle to free exchange of information at the FIU level

A

Differences in the definition of offenses

24
Q

What is the deal with informal and rapid info exchange

A

the exchange of information should take place as informally and as rapidly as possible and with no excessive formal prerequisites

25
Q

while guaranteeing what

A

protection of privacy and confidentiality of the shared data

26
Q

What if an FIU still needs a memorandum of understanding (MOU)

A

it should be negotiated and signed by the FIU without undue delay

27
Q

so what does this mean

A

the FIU should have the authority to sign MOUs independently

28
Q

are intermediaries necessary?

A

no, it should be possible for communication between FIUs to take place directly and without intermediaries

29
Q

what about providing consent

A

providing FIU’s consent to disseminate the information for law enforcement or judicial purposes should be granted promptly and to the greatest extent possible

CAMS (19 decks)

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