CAMS-FCI practice question 19 of 25

While each is potentially important, which allows an investigations analyst to better write a SAR/STR narrative that is useful to law enforcement? (Select Two.)

Full set: 101 questions
Answer options
A: Including an explanation of the internal process that brought the transaction to the attention of the analyst
B: Including information about the general activity trends in the area where the suspicious transactions were conducted
C: Including contact information for individuals at other institutions with whom correspondence has occurred
D: Including a detailed description of the known or suspected criminal violation or suspicious activity Correct answer
E: Ensuring all information in the SAR/STR is complete and accurate based on what the institution knows Correct answer
Correct Answer:
D. Including a detailed description of the known or suspected criminal violation or suspicious activity; E. Ensuring all information in the SAR/STR is complete and accurate based on what the institution knows
Explanation

For a Suspicious Activity Report (SAR) or Suspicious Transaction Report (STR) to be useful to law enforcement, it must provide clear, actionable intelligence. A detailed description of the suspected violation (D) provides the essential "who, what, when, where, why, and how" of the activity, forming the core of the investigation. Ensuring all information is complete and accurate (E) is fundamental; without this, the report can be misleading, waste investigative resources, or be entirely unusable. These two elements directly determine the report's value and ability to initiate or support an investigation.

Why Incorrect

A. Law enforcement is focused on the suspicious activity itself, not the institution's internal discovery process.
B. Law enforcement typically has its own, more comprehensive data on area trends; the SAR should be specific to the subject.
C. Including third-party contact information is improper and can raise tipping-off and privacy concerns.

References

1. Financial Crimes Enforcement Network (FinCEN). (2023). SAR Quality Pamphlet. (This guidance repeatedly emphasizes the need for narratives to be "concise, complete, and logical" and to clearly answer the "who, what, when, where, why, and how" questions about the suspicious activity).

2. Financial Action Task Force (FATF). (2012, updated 2023). International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation – The FATF Recommendations. (See Recommendation 20 and its Interpretive Note, which require STRs to contain a description of the suspicion and be as complete as possible to be useful to the FIU).

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