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A financial institution's transaction monitoring system flags an unusually high volume of international wire transfers...

A financial institution's transaction monitoring system flags an unusually high volume of international wire transfers originating from a small business account. The transfers are being sent to multiple jurisdictions known for limited regulatory oversight. Additionally, an employee reports suspicious behavior from the account holder during an in-person visit, where they requested a large cash withdrawal without providing a clear business justification. As part of the investigation, the compliance team must assess whether this activity is suspicious and determine the appropriate next steps.

Which of the following steps should be taken first in the investigation process to properly gather information and assess whether the transactions are suspicious?

A.

Review the transaction history of the account to identify patterns, including the frequency, destination, and purpose of the wire transfers

B.

Notify senior management and suggest account closure due to potential risks

C.

Immediately file a suspicious activity report (SAR) based on the employee's report of suspicious behavior

D.

Contact the customer directly to ask for clarification on the reason for the large cash withdrawal

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