Step 1: Analyzing Debits, Credits, and International Transactions
Question
A client opens a bank account for a multi-level marketing company. The debits and credits of the account are numerous and very involved. Further, there are a lot of international transactions. Also, funds are being funneled from the company to the client's personal account in another jurisdiction.
Which two steps should law enforcement take in investigating this matter? (Choose two.)
Answers
Explanations
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A. B. C. D.AC
In investigating the matter described, law enforcement should take the following two steps:
Determine who are the signatories on the account: It is crucial for law enforcement to identify the individuals authorized to operate the bank account. By determining the signatories on the account, investigators can gain insight into who has control over the funds and who is responsible for the account's transactions. This information helps establish the chain of responsibility and allows investigators to focus their efforts on these individuals. Additionally, identifying the signatories can provide clues about their background, connections, and potential involvement in money laundering activities.
Examine possible Suspicious Activity Report (SAR) information received from the local Financial Intelligence Units (FIUs): FIUs play a vital role in combating money laundering and financial crimes. They receive and analyze SARs submitted by banks and other financial institutions, highlighting potentially suspicious activities. By examining possible SAR information related to the multi-level marketing company, law enforcement can uncover important details about the transactions, patterns, and behavior of the account. SARs often contain valuable information, including transactional data, customer profiles, and reasons for suspicion, which can assist investigators in understanding the potential illicit activities involved.
While all the answer choices provided contain relevant aspects, these two steps are the most essential for the initial investigation:
A. Determining the signatories helps identify the key individuals involved in the account and potentially responsible for any illicit activities.
D. Examining possible SAR information received from local FIUs provides a valuable source of intelligence that can shed light on suspicious activities associated with the account.
Answer B, asking the bank for the history of the multi-level marketing company, can be a helpful step as well, but it is more focused on obtaining additional background information about the company itself rather than the specific transactions and potential money laundering activities. It may be useful in building a broader understanding of the company's operations and any red flags associated with it.
Answer C, examining the flow of money from the company to the individual in an effort to determine if it is legitimate, is a valid consideration but is somewhat encompassed by the other steps. Determining the signatories and analyzing possible SAR information would naturally involve examining the flow of funds and investigating the legitimacy of the transactions.
Therefore, the most appropriate steps for law enforcement in this scenario would be to determine the signatories on the account (A) and examine possible Suspicious Activity Report information received from the local Financial Intelligence Units (D).
