QUEAccording to the ACAMS Study Guide, one of the skills of an effective AML investigator is to conduct investigative interviews using appropriate techniques and methods1. One of the techniques is to use open-ended questions that elicit detailed responses from the interviewee, and to avoid leading or suggestive questions that may reveal the investigator’s assumptions or suspicions1. Therefore, the best option is to ask question of a material nature about the suspected false statements without revealing the suspected deception, as this would allow the investigator to gather more information and evidence, and to test the consistency and credibility of the interviewee’s answers.
The other options are not advisable or effective, because:
A. Informing the suspect that deception is obvious and continuing the interview is not a good strategy, because it may antagonize the suspect and make them less cooperative or more defensive. It may also alert the suspect to the investigator’s knowledge and sources, and give them an opportunity to change or modify their story2.
B. Advising the suspect that the interview will be terminated if there is suspicion of deception is not a good strategy, because it may create a negative impression of the investigator and the investigation, and it may discourage the suspect from providing any useful information. It may also imply that the investigator has insufficient evidence or authority to pursue the case2.
C. Directing the interview in another direction until there is better rapport before returning back to the troubling question is not a good strategy, because it may waste time and resources, and it may lose the focus and momentum of the investigation. It may also signal to thesuspect that the investigator is not confident or competent, and it may give the suspect a chance to prepare or rehearse their answers2.
1: ACAMS Study Guide, 6th Edition, Chapter 4: Conducting and Supporting the Investigation, page 105. 2: 46 AML Investigator Interview Questions (And Sample Answers)
STION NO: 96
A bank employee recently opened an account for a new restaurant. Daily cash deposits over a three-month
period are close to $9,500.
What are two red flags that indicate possible money laundering or terrorist financing? (Choose two.)
A. The restaurant is located in a different city
B. The daily cash deposits are so close in amount
C. It is a new account that has daily cash deposits
D. The new account demonstrates a steady flow of income
Answer:BD
These two options are potential red flags for money laundering or terrorist financing because they could indicate an attempt to avoid the reporting threshold of $10,000 for cash transactions, or to conceal the source or origin of the funds. According to the ACAMS Study Guide, some common indicators of money laundering are:
Transactions structured to avoid recordkeeping or reporting requirements
Transactions inconsistent with the customer’s profile or business activity
Transactions involving the use of multiple accounts or locations
Transactions involving high-risk jurisdictions or entities
Transactions involving cash or complex crypto assets
The other two options are not necessarily red flags by themselves, as they could have legitimate explanations. For example, the restaurant could be located in a different city because of market demand, or the new account could demonstrate a steady flow of income because of the success of the business.
[References:, ACAMS Study Guide for the CAMS Certification Examination - 6th Edition, Chapter 2, page 41-42, FFIEC BSA/AML Appendices - Appendix F – Money Laundering and Terrorist Financing Red Flags, page 1-2, 4 Red Flags of Money Laundering or Terrorist Financing, page 1, Money Laundering Red Flags | Key Behaviours and Indicators, page 1, , , , ]
