An investigator receives an alert documenting a series of transactions.

ACAMS CAMS-FCI Question Answer

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?

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

The bank is out of compliance with beneficial ownership regulations.

The bank is out of compliance with CIP regulations.

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