Advanced CAMS-Financial Crimes Investigations (CAMS-FCI) Certification Set One

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Topics Covered

Financial Crime Investigation (FCI) Program Management and Risk Assessment

  1. Knowledge of FCI Program Setup

    • 1.1 Understanding how the FCI program is structured involves:
      • Governance Structure: Knowing the roles and responsibilities within the program, including oversight bodies and committees.
      • Program Elements: Understanding how monitoring, investigation, reporting, quality control, filing, and escalations interact and support the program’s objectives.
  2. Determining and Categorizing Financial Crime Risk

    • 1.2 Institutions categorize financial crime risks by:
      • Types of Risk: Identifying specific risks such as money laundering, fraud, or terrorist financing.
      • Risk Assessment: Assessing risks based on national priorities, risk appetite, products, channels, customers, and geographical locations.
  3. Differences in Investigation Risks and Processes

    • 1.3 Recognizing differences in investigation types:
      • Client vs. Internal Personnel: Different processes for investigating external clients versus internal employees.
      • Insider vs. Law Enforcement: Understanding the roles of internal investigators versus law enforcement agencies in the investigation process.
  4. Making Risk-Based Decisions

    • 1.4 Making informed decisions involves:
      • Tuning Impact: Understanding how adjusting system parameters affects risk detection.
      • Resource Allocation: Effectively allocating resources and time based on risk assessment and program needs.
  5. Assessing Relationship Actions

    • 1.5 Evaluating actions to manage client relationships includes:
      • Actions: Decisions such as keeping or exiting clients, holding transactions, freezing accounts, or updating risk ratings.
      • Argumentation: Presenting a case to the Board or risk committee to support decisions based on assessed risk.
  6. Customer Profiling and Transaction Monitoring

    • 1.6 Knowledge in profiling and monitoring includes:
      • Processes: Setting thresholds, risk scoring, and integrating systems.
      • Tools: Utilizing transaction monitoring systems, customer screening tools, and adverse media tools.
  7. Metrics for Measuring Risks and Controls

    • 1.7 Evaluating metrics involves:
      • Effectiveness: Determining what metrics are necessary to measure the effectiveness of investigations and program performance.
      • Communication: Reporting these metrics to the Board or Senior Management.
  8. Identifying Gaps in Monitoring Controls

    • 1.8 Ability to identify and address gaps:
      • Monitoring Controls: Recognizing new patterns of suspicious activity that are not detected by existing systems.
      • New Controls: Suggesting and implementing new controls to address identified gaps.
  9. Providing Expert Recommendations

    • 1.9 Offering expert advice includes:
      • Recommendations: Advising on how to manage specific clients, products, services, or geographies to mitigate money laundering risks.
      • Trend Analysis: Identifying and reporting trends in SARs to address gaps in controls.
  10. Building and Evaluating Investigative Procedures

    • 1.10 Developing and assessing procedures involves:
      • Investigative Procedures: Creating procedures and reviewing their quality in light of policies and guidelines.
      • Quality Control: Assessing the effectiveness of existing processes and reports.
  11. Knowledge of Legal Context

    • 1.11 Understanding legal requirements includes:
      • Jurisdictional Laws: Knowing laws and regulations related to transaction monitoring and financial crime across different jurisdictions.
  12. Boundaries of Obligations

    • 1.12 Knowing the roles and responsibilities:
      • FI vs. FIU vs. Law Enforcement: Understanding the responsibilities of financial institutions, financial intelligence units, and law enforcement in the investigation process.
  13. Law Enforcement Requests

    • 1.13 Knowledge of law enforcement requests:
      • Types of Requests: Understanding common requests such as information gathering, warrants, account freezes, and unexplained wealth orders.
  14. Addressing Law Enforcement Requests

    • 1.14 Handling law enforcement requests involves:
      • Coordination: Managing requests while balancing client privacy and coordinating with law enforcement during investigations.
  15. Private-Public Partnerships

    • 1.15 Understanding partnerships and information sharing:
      • Partnerships: Knowledge of formal and informal partnerships such as the 314(a) and 314(b) in the US, and other international collaborations.
  16. Adjusting Investigator Training Programs

    • 1.16 Tailoring training programs:
      • Institutional Specifics: Adjusting training to address institutional needs, new financial crime risks, and knowledge gaps.

Investigative Processes and Techniques for Financial Crime

  1. Escalation of Criminal Investigations

    • 2.1 Escalation Triggers: Recognize when an investigation should be escalated due to:
      • Sensitivity: Investigations involving internal staff or politically exposed persons (PEPs).
      • Complexity: Cases requiring more advanced or specialized handling.
  2. Information-Gathering Strategies

    • 2.2 Crafting Strategies: Develop effective strategies to gather information:
      • Approach: Creating questions and methods for relationship managers and other sources.
      • Discretion: Conducting probes without alerting the subject.
      • Requests: Submitting and managing requests for information (RFI).
  3. Privacy Rules and Regulations

    • 2.3 Understanding Privacy Regulations: Knowledge of privacy laws and regulations related to:
      • Information Sharing: Internal and external sharing with legal entities, customers, and law enforcement.
  4. Documentation of Investigation Files

    • 2.4 Retaining Files: Maintain comprehensive files to support investigative decisions:
      • Documentation: Notes on unusual activity, KYC updates, decision-making processes, supporting evidence, and any deviations from the process.
  5. Identification of Available Data and Resources

    • 2.5 Data and Resource Identification: Identify and utilize various data sources:
      • Internal: KYC files, transaction history, business records.
      • External: UBO registers, source of wealth, public records, PEP lists, and more.
  6. Cross-Function and Cross-Culture Communication

    • 2.6 Effective Communication: Communicate effectively in cross-border investigations:
      • Jurisdictional Knowledge: Understanding different jurisdictional risks, information reliability, data gathering protocols, and local regulatory environments.
      • Specialist Knowledge: Knowing when to involve specialists and handling complexities in various jurisdictions.
  7. Evaluation and Scoping of Investigation Plans

    • 2.7 Scoping Plans: Evaluate and scope investigation plans based on:
      • Initial Data: Assessing data gaps and their relevance to the investigation.
  8. Assessment of Information

    • 2.8 Differentiating Behavior: Evaluate information to distinguish between:
      • Unusual, Suspicious, and Unknown Behavior: Identifying and determining the significance of various types of behavior.
  9. Utilization of Large Databases

    • 2.9 Database Analysis: Using large databases to:
      • Pattern Recognition: Distill complex patterns into clear conclusions.
  10. Analytical Software for Investigations

    • 2.10 Software Tools: Leverage analytical software to:
      • Data Visualization: Create visualizations and conduct analyses such as network analysis and transaction monitoring.
  11. Assessing Information Reliability

    • 2.11 Information Evaluation: Assess the reliability of various information sources:
      • Internal and External Sources: Evaluate KYC files, transaction histories, UBO registers, and other sources.
  12. Searching for Additional Information

    • 2.12 Beyond Standard Sources: Seek additional information beyond typical sources:
      • Research: Conduct open-source research and utilize internal data across different departments.
  13. Evaluating Investigation Continuation

    • 2.13 Decision Making: Decide whether to continue or conclude an investigation based on:
      • Risk and Constraints: Assessing risks, constraints, and the overall conclusion of the investigation.
  14. Recognizing Complex Financial Crime Schemes

    • 2.14 Pattern Recognition: Identify potential complex or sophisticated financial crime schemes from transaction patterns.
  15. Differentiating Investigation Types

    • 2.15 Investigation Types: Understand differences between:
      • Client-related Investigations: Focused on client behavior.
      • Internal Investigations: Concerning insiders of the institution.
      • Law Enforcement Investigations: Conducted by law enforcement with different evidence thresholds and focuses.

Knowledge of Financial Crime Risks and Typologies

  1. High-Risk Products and Services

    • 3.1 Complex Financial Products: Understanding how high-risk and complex products/services can be used for illicit activities:
      • Examples: Correspondent banking, trusts, private banking, wealth management.
      • Exploitation: Methods by which these products may facilitate money laundering or financial crime.
  2. High-Risk Customers and Businesses

    • 3.2 Misuse by High-Risk Entities: Knowledge of how high-risk customers or businesses misuse legal entities for illicit purposes:
      • Examples: Gatekeepers, complex corporate structures, Designated Non-Financial Businesses and Professions (DNFBPs), Money Service Businesses (MSBs), Trust Company Service Providers, cash-intensive businesses.
      • Misuse: Methods to launder money or evade taxes.
  3. Bribery and Corruption Typologies

    • 3.3 Corruption Mechanisms: Recognize various typologies of bribery and corruption:
      • Examples: Complex shell companies, politically exposed persons (PEPs), offshore accounts.
      • Indicators: Typical patterns and structures used in corruption schemes.
  4. Predicate Crimes for Money Laundering

    • 3.4 Crime Sources: Understanding the predicate crimes that commonly lead to money laundering:
      • Examples: Terrorism, fraud, cyber-crime, human trafficking, tax evasion, narcotics trafficking, corruption.
      • Linkages: How these crimes produce illicit proceeds that are laundered.
  5. Financing for Proliferation and Weapons of Mass Destruction (WMD)

    • 3.5 Proliferation Financing: Knowledge of techniques and methods used to finance the proliferation of WMD:
      • Examples: Exploitation of business for WMD, funding methods for obtaining WMD materials, evading sanctions.
      • Banking Exploits: Types of products, services, geographies, or customer bases exploited.
  6. Terrorism Financing

    • 3.6 Terrorism Financing Methods: Understanding how terrorism is financed through financial institutions, MSBs, and virtual asset service providers:
      • Examples: Crowd funding, payment flows tied to digital assets, exploitation of non-profits and humanitarian efforts.
      • Ideologies and Techniques: Basic understanding of terrorist ideologies and methods used to finance terrorism.
  7. Cyber-Related Financial Crimes

    • 3.7 Cyber Crime Typologies: Knowledge of financial crimes related to cyber activities:
      • Examples: Red flags for cyber heists, business email compromise, ransomware payments.
      • Techniques: Identifying and tracing ransomware payments, methods to move funds quickly through cyber-controlled accounts.
  8. Transnational Criminal Organizations (TCOs) and Drug-Trafficking Organizations (TDOs)

    • 3.8 TCOs and TDOs: Understanding the operations of TCOs and TDOs and their financial activities:
      • Examples: Trade-based money laundering, payment flows from TDOs to other regions, narcotics routes.
      • Patterns: Payment flows and financing methods associated with major cartels and drug trafficking.
  9. Human Trafficking Typologies

    • 3.9 Human Trafficking: Knowledge of different typologies of human trafficking and associated financial crime methods.
  10. Environmental Crime Typologies

    • 3.10 Environmental Crime: Understanding typologies related to environmental crimes:
      • Examples: Wildlife trafficking and other forms of environmental exploitation.
  11. Online Marketplaces and Social Media

    • 3.11 Digital Platforms: Knowledge of how criminals use online platforms to launder money:
      • Examples: Online marketplaces, social media, and gaming platforms.
      • Techniques: Methods used by criminals to exploit these platforms for financial crimes.
  • Understanding the SAR/STR Process

    • 4.1 SAR/STR Process Knowledge: Understanding the process of Suspicious Activity Reports (SARs) and Suspicious Transaction Reports (STRs) for law enforcement:
      • Process Overview: Key steps in filing, reviewing, and processing SARs and STRs.
  • Crafting Effective SAR/STR Narratives

    • 4.2 Essential Narrative Content: Ability to determine what information is necessary and unnecessary to include in the SAR/STR narrative:
      • Inclusions: Key facts and details that should be highlighted.
      • Exclusions: Information that does not add value or may be redundant.
  • Communicating Financial Data to Law Enforcement

    • 4.3 Simplifying Complex Data: Ability to convey financial industry knowledge in a digestible way for law enforcement:
      • Techniques: Simplifying complex data, explaining normal versus unusual activity, and describing bank products and their uses.
  • Conveying the Investigation’s Bottom Line

    • 4.4 Summarizing Findings: Ability to clearly convey the bottom line of the financial crime investigation in the SAR:
      • Focus: Clearly articulating the institution’s concerns and identifying unknowns.
  • Differentiating Between Facts, Analysis, and Judgment

    • 4.5 Fact vs. Analysis vs. Judgment: Ability to distinguish between facts, analysis, and judgment in SARs:
      • Facts: Relevant and explicit information.
      • Analysis: Connections and patterns identified between data points.
      • Judgment: Conclusions drawn from facts and analysis.
  • Chronological Narration of the Financial Crime

    • 4.6 Relating the Narrative: Ability to chronologically relate the financial crime narrative from various perspectives:
      • Perspectives: Transactions, customer history, and shared information.
  • Interpreting Complex Data Sets

    • 4.7 Data Communication: Ability to communicate the meaning of complex data sets:
      • Methods: Techniques to make complex data understandable for law enforcement.
  • Evaluating and Improving SAR Quality

    • 4.8 SAR Quality Assessment: Ability to evaluate and improve SARs for usefulness to law enforcement:
      • Review Process: Assessing SARs for completeness and appropriateness, suggesting improvements.
  • Applying Jurisdictional Laws and Regulations

    • 4.9 Jurisdictional Compliance: Ability to apply different jurisdictional laws and regulations to the SAR-filing decision-making process:
      • Filing Requirements: Understanding of initial and repeat filing obligations, and affirmative review requirements.
  • Developing SAR Writing Standards

    • 4.10 Writing Standards: Ability to write standards and best practices for completing SARs:
      • Guidelines: Creating comprehensive guides for effective SAR writing.

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