The bank's internal financial intelligence unit (FIU) has reviewed activity related to a politically exposed person (PEP); the activity in the account contains a large, round number, one time wire to an obscure organization. Which would not be a sufficient reason to file a SAR/STR?
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A. B. C. D.D
In the context of the Certified Anti-Money Laundering Specialist (CAMS) exam, the question pertains to the decision of whether to file a Suspicious Activity Report (SAR) or Suspicious Transaction Report (STR) based on the activity of a politically exposed person (PEP) within a bank's account. The question asks you to identify the option that would not be a sufficient reason to file a SAR/STR.
Let's analyze each answer choice and determine whether it would provide a sufficient reason to file a SAR/STR:
A. Beneficiary is largely unknown: If the beneficiary of a large, round-number wire transfer is largely unknown, it could raise suspicions regarding the legitimacy of the transaction. The lack of information about the recipient could indicate potential money laundering or illicit activities. Therefore, this would generally be considered a valid reason to file a SAR/STR.
B. Maintain the bank's reputation: Maintaining the bank's reputation is an important consideration for financial institutions. However, it is not a sufficient reason on its own to decide against filing a SAR/STR. The primary objective of anti-money laundering (AML) efforts is to detect and report suspicious activities, regardless of their potential impact on the bank's reputation. Therefore, this would not be a valid reason to refrain from filing a SAR/STR.
C. Wire is a large amount: A large, round-number wire transfer can be indicative of potential money laundering or other illicit activities. Such transactions may be attempts to move funds quickly and covertly. Consequently, a large amount alone can be a valid reason to file a SAR/STR.
D. Customer activity is unreasonable: If the customer's activity is deemed unreasonable, it suggests behavior that deviates from normal or expected patterns. Unreasonable activity may include frequent large transactions, unusual transactional patterns, or inconsistencies in the customer's financial behavior. Such irregularities could indicate potential money laundering or other illicit activities. Therefore, this would typically be considered a valid reason to file a SAR/STR.
Considering the explanations provided above, the option that would not be a sufficient reason to file a SAR/STR is:
B. Maintain the bank's reputation
While maintaining the bank's reputation is important, it is not an adequate reason on its own to forgo filing a SAR/STR. The primary focus should be on identifying and reporting suspicious activities to combat money laundering and protect the integrity of the financial system.