Upon a routine account review a money laundering investigator identified a number of large round dollar wire transfer deposits into a business account owned by a local auto repair shop. The wire transfers all originated from a country that is a known financial secrecy haven with poor anti-money laundering controls. The investigator concludes there appears to be no legitimate business purpose for the wire transfers and files a suspicious transaction report. The owner of the auto repair shop is popular in the community and is a well-known philanthropist.
To whom should the investigator escalate these concerns?
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A. B. C. D.D
The investigator has identified a suspicious activity related to wire transfer deposits into a business account owned by a local auto repair shop. The wire transfers originate from a country that is known for its poor anti-money laundering controls, which raises concerns about the legitimacy of the funds. The investigator concludes that there is no legitimate business purpose for the wire transfers and files a suspicious transaction report.
Given the suspicious activity identified, the investigator should escalate these concerns to the bank's anti-money laundering officer. The bank's AML officer is responsible for ensuring that the bank complies with all applicable AML laws and regulations, and they are in the best position to assess the potential risks associated with the suspicious activity.
Escalating the concerns to the bank's AML officer is critical to ensure that the bank can assess the risks and take any necessary action. The bank's AML officer is responsible for investigating suspicious activity and making a determination as to whether the activity is indicative of money laundering or other illicit activity.
Furthermore, the bank's AML officer will have a thorough understanding of the bank's policies and procedures relating to suspicious activity reporting and will be able to determine if additional action is required, such as filing a report with the appropriate regulatory authorities. Failure to report suspicious activity can result in severe consequences for the bank, including significant fines and reputational damage.
Therefore, the correct answer is D. The bank's AML officer is the appropriate person to whom the investigator should escalate their concerns.