A bank's transaction surveillance system triggers an alert for a deposit of 250,000 USD into a client's account. According to the bank's KYC information, the client works for a financial advisory firm, and earns approximately 100,000 USD per year. Which actions should be taken? (Choose three.)
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A. B. C. D. E. F.ABF
The situation described in this question is a common example of a potential suspicious transaction that could be indicative of money laundering or other financial crimes. In order to ensure compliance with anti-money laundering regulations and mitigate risks to the bank, several actions should be taken:
A. File the suspicious transaction immediately to the financial intelligence unit: If a transaction is considered suspicious, the bank must file a suspicious activity report (SAR) with the relevant financial intelligence unit (FIU) as soon as possible. This is a regulatory requirement, and failing to file SARs in a timely and accurate manner can result in significant penalties and reputational damage for the bank. Therefore, the first action that should be taken in response to the alert is to escalate it to the bank's compliance team, who can determine whether it meets the threshold for filing a SAR and proceed accordingly.
B. Review the transaction background in the bank's transaction platform: Once the alert has been escalated to the compliance team, they should review the transaction details and any available background information in the bank's transaction monitoring platform. This can help to provide additional context for the transaction, such as whether it was a one-time occurrence or part of a pattern of unusual activity, and whether there are any other red flags that would indicate the need for further investigation.
C. Review the alert if the deposit is made in cash: If the deposit was made in cash, this could be an additional red flag, as cash deposits are often associated with money laundering and other illicit activities. In this case, the compliance team should pay particular attention to the source of the funds and any other indicators of suspicious activity.
D. Discard the alert as a false positive hit: Discarding the alert without further investigation is not an appropriate response, as it could lead to missed opportunities to detect and prevent financial crimes. Even if the transaction ultimately proves to be legitimate, it is important to err on the side of caution and conduct a thorough investigation before ruling out any potential risks.
E. Contact the client advisor to learn if he has any insight on the transaction background: As the client works for a financial advisory firm, it may be useful to contact their advisor to learn more about the nature of the transaction and whether it is consistent with their client's known financial activities. This can help to provide additional context for the transaction and inform the bank's decision-making process.
F. Request information and documentation from the client on the background of the transaction: If the compliance team determines that the transaction is suspicious, they may need to request additional information and documentation from the client to better understand the nature of the transaction and any associated risks. This could include information about the source of the funds, the purpose of the transaction, and any other relevant details. The bank should have procedures in place for requesting information from clients in a manner that is consistent with KYC and privacy regulations.