An immigrant residing in the United States opens a bank account that includes a debit card. Several months later, the transactional monitoring system…

According to the ACAMS CAMS Certification Study Guide (6th edition), the bank should file a SAR if it

knows, suspects, or has reason to suspect that a transaction involves funds derived from illegal

activity, or is intended or conducted to hide or disguise funds or assets derived from illegal activity,

or to evade any BSA regulation or federal law, or has no business or apparent lawful purpose, or is

not the sort in which the customer would normally be expected to engage1. The scenario described

in the question meets these criteria, as the small deposits and withdrawals from a high-risk country

could indicate money laundering, terrorist financing, or other illicit activities. The bank should also

document its decision to file or not file a SAR, and retain thesupporting documentation for five

years1.

The other options are not correct because they either do not comply with the BSA requirements, or

do not adequately address the potential risk of the activity. Blocking any further activity could alert

the customer of the bank’s suspicion, and could also interfere with law enforcement investigations.

Initiating an investigation into the activity could be part of the bank’s due diligence process, but it

does not substitute the obligation to file a SAR if the activity is suspicious. Contacting the customer

could also tip off the customer, or elicit false or misleading explanations that could hinder the bank’s

assessment of the activity.

ACAMS CAMS Certification Study Guide (6th edition), page 82-83. 12345678 [9]