CAMS-FCI: Suspicious Activity Reporting, Escalation and Remediation Outcomes

Suspicious Activity Reporting, Escalation and Remediation Outcomes

This domain tests the filing decision, narrative quality, handling of continuing activity, and what should happen after a report is filed: restriction, exit decisions and control remediation.

Core rules

File when suspicion is reasonable. You do not need proof, and you do not need to name the predicate offence.
The narrative answers who, what, when, where, why and how, with dates, amounts, account numbers, counterparties and the specific behaviour observed. State facts first and label inferences as inferences.
Timeliness matters. Jurisdictions set deadlines measured from detection, and late filing is itself a finding.
Continuing activity: if the activity persists after filing, submit a further or continuing report according to policy and local requirements rather than assuming the first report covers it.
No tipping off. In several jurisdictions the report is protected and should not be used as evidence in civil litigation; follow policy and legal advice.
Escalation routes include the MLRO, sanctions team, legal, human resources and law enforcement.
Post-filing outcomes include enhanced monitoring, transaction restrictions and exit. Exit decisions must weigh the risk of financial exclusion and the risk of tipping off.
Remediation covers root-cause analysis of the control that missed the activity, a lookback, scenario tuning, training and metrics fed back to the monitoring team.

Worked example

Filing on a suspected mule account: describe account opening and the declared profile, list the three inbound transfers with dates, amounts and senders, list the two outbound conversions with the exchange names, give the total and the residual balance, and note that the stated occupation does not explain the flows. Then state the suspicion - that the account appears to be used to channel third-party funds - without asserting that a crime has been proved.

Traps that cost marks

Vague narratives such as "activity inconsistent with profile" with no figures.
Filing once and never reviewing continuing activity.
Using de-risking as a substitute for analysis.
Failing to remediate the alert scenario that let the case through in the first place.

Ethics, Confidentiality and Legal Considerations in Investigations

This domain tests the judgement calls that end investigations and sometimes careers: confidentiality, conflicts of interest, privilege, data protection and the lawful handling of personal information.

Core rules

Need-to-know governs dissemination. Case detail is shared only with those who require it for their role. Discussing a case in a public place or on an unsecured channel is a confidentiality breach regardless of intent.
Tipping off: you may not disclose a report or the existence of an investigation in a way likely to prejudice an investigation.
Conflicts of interest: recuse where a personal relationship, prior role or financial interest creates bias, and document the recusal and the reassignment.
Legal privilege: legal advice privilege covers communications with counsel for the purpose of legal advice; litigation privilege covers documents created for contemplated litigation. Compliance working papers are not automatically privileged - never assume.
Data protection: lawful basis, minimisation, cross-border transfer restrictions and retention limits. Local law may prohibit a transfer even to a parent company.
Employment law: internal investigations must respect workplace rights, representation and the privacy of employee communications.
Ethical duties: escalate wrongdoing, including by senior staff, and use whistleblowing channels where protected.
Sanctions and reporting obligations are legal duties; a commercial rationale never overrides them.

Worked example

A colleague mentions that the subject of your case is their brother-in-law and asks for an update. You do not share it. You record the potential conflict, notify your manager and the MLRO, and the case is reassigned. The relationship is not misconduct in itself, but undisclosed it would compromise the credibility of the investigation and any decision that followed from it.

Traps that cost marks

Discussing case detail on personal devices or consumer messaging apps.
Assuming compliance working papers attract legal privilege.
Sending customer data across borders without checking local restrictions.
Letting a senior person's informal request override an escalation or reporting duty.