CAMS-FCI practice question 7 of 25

An investigator receives an alert documenting a series of transactions. A limited liability corporation (LLC) wired 59.000.000 USD to an overseas…

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 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 money for a fee before returning it to investors. What is the total suspicious transaction amount that the investigator should report?

Answer options

A: 600,000,000 USD

B: 59,000,000 USD

C: 541.000,000 USD

D: 659,000,000 USD Correct answer

Correct Answer:

D. 659,000,000 USD

Explanation

When filing a SAR/STR that involves a series of related transactions, the investigator should report the aggregate amount of all transactions that are part of the suspicious activity. This provides law enforcement with a complete picture of the total value of funds involved in the potential money laundering scheme. In this scenario, both the incoming wire of 600,000,000 USD and the outgoing wire of 59,000,000 USD are integral parts of the suspicious, circular-looking activity. Therefore, the total suspicious amount is the sum of these transactions. Total Amount = 600,000,000 USD + 59,000,000 USD = 659,000,000 USD.

Why Incorrect

A. Reporting only the 600,000,000 USD inflow would ignore the suspicious outflow that is part of the same pattern of activity.
B. Reporting only the 59,000,000 USD outflow would understate the scale of the suspicious activity by omitting the much larger inflow.
C. Reporting the net difference (541,000,000 USD) is incorrect as it does not reflect the total volume of funds that passed through the account as part of the scheme.

References

1. ACAMS CAMS6-EN Study Guide, (2020). Chapter 4, Section: "Completing the SAR/STR Form," p. 270. The guide explains that the amount reported should reflect the total value of the suspicious activity, which often involves aggregating multiple transactions.

2. Financial Crimes Enforcement Network (FinCEN). FinCEN SAR Electronic Filing Instructions. Section 4 (Filing a FinCEN SAR), Item 24 (Amount). The instructions specify to "enter the total dollar amount of the suspicious activity" and that for multiple, related transactions, the filer should "enter the aggregated amount."

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