CAMS-FCI practice question 2 of 25

In which case should an investigator avoid escalating a suspicious event to the chief compliance officer and pursue other channels?

Full set: 101 questions
Answer options
A: The transaction chain is likely connected to a known member of a terrorist organization.
B: A close family member of the chief compliance officer is the beneficiary of a cross-border transfer. Correct answer
C: A trade entity engages in complex trade deals involving numerous third-party intermediaries in incongruent lines of business.
D: An individual involved in a large sum transaction is a foreign PEP.
Correct Answer:
B. A close family member of the chief compliance officer is the beneficiary of a cross-border transfer.
Explanation

When a suspicious event directly involves a close family member of the chief compliance officer (CCO), there exists an inherent conflict of interest that compromises the CCO's ability to make objective decisions. This situation requires the investigator to bypass the normal reporting chain and escalate through alternative channels such as the board of directors, audit committee, or an independent compliance function to ensure unbiased investigation and maintain the integrity of the compliance program.

Why Incorrect

A. Terrorist financing requires immediate escalation to the CCO as part of standard AML protocols.

C. Complex trade deals with multiple intermediaries warrant CCO notification for risk assessment and monitoring.

D. Foreign PEP involvement necessitates enhanced due diligence and CCO awareness per standard procedures.

References

1. FATF Recommendation 15 - Internal Controls and Foreign Branches and Subsidiaries (2012-2023), Paragraph 15.4 on independence of compliance function

2. Basel Committee on Banking Supervision, "Sound management of risks related to money laundering and financing of terrorism" (2020), Section III.2 on governance arrangements, pages 12-14

3. Wolfsberg Group, "Wolfsberg AML Principles on Private Banking" (2023), Section 2.3 on conflicts of interest management

4. ACAMS Study Guide for CAMS Certification (6th Edition), Chapter 4: Compliance Programs, pages 187-189 on reporting structures and independence

5. IIF Report, "Financial Crime Compliance: Managing Conflicts of Interest" (2022), Section 3.2 on alternative reporting channels, pages 23-25

Scroll to Top