ACAMS Advanced CAMS-Financial Crimes Investigations CAMS-FCI Question # 19 Topic 2 Discussion

ACAMS Advanced CAMS-Financial Crimes Investigations CAMS-FCI Question # 19 Topic 2 Discussion

CAMS-FCI Exam Topic 2 Question 19 Discussion:
Question #: 19
Topic #: 2

An analyst reviews an alert for high volume Automated Clearing House (ACH) activity in an account. The analyst's initial research finds the account is for a commercial daycare account that receives high volumes of large government-funded ACH transactions to support the programs. The account activity consists of checks (cheques) made payable to individual names in varying dollar amounts. One check indicates rent to another business.

An Internet search finds that the daycare company owner has previous government-issued violations for safety and classroom size needs, such as not having enough chairs and tables per enrollee. These violations were issued to a different daycare name.

Simultaneous to this investigation, another analyst sends an email about negative news articles referencing local child/adult daycare companies misusing governmental grants. This prompts the financial institution (Fl) to search all businesses for names containing daycare' or "care*. Text searches return a number of facilities as customers at the Fl and detects that three of these businesses have a similar transaction flow of high volume government ACH funding with little to no daycare expenses.

During the investigation, new suspicious patterns and trends related to check cashing are observed. The Fl decides to conduct a training to ensure that 1) the AML program is robust and 2) the training program is relevant and appropriate. Which parties should be trained on emerging trends and red flags? (Select Two.)


A.

Financial crimes investigation unit


B.

Loan department


C.

Branch personnel


D.

Senior management


E.

The board of directors


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