Which actions should financial institutions perform to ensure proper data governance? (Select Three.)

• A. Periodically validate integrity and accuracy of information used for IT systems such as customer information, customer identification records, and transaction records.
• B. Review significant discrepancies between the values of the product reported on the invoice and the fair market value.
• C. For customers who are determined to be at high risk, review their risk rating and apply risk mitigation measures as appropriate.
• D. Evaluate the nature of foreign remittance under a risk-based structure of AML/CFT and take necessary measures in accordance with the risk-based approach.
• E. Establish an appropriate data management method for collecting and storing information.
• F. Ensure the accuracy of customer identification records and transaction records and appropriately manage data as a prerequisite for the effective use of IT systems.

An investigator is reviewing an alert for unusual activity. System scanning detected a text string within a company customer's account transactions that indicates the account may have been used for a drug or drug paraphernalia purchase. Based on the KYC profile, the investigator determines the customer's company name and business type are marketed as a gardening supplies company. The investigator reviews the account activity and notes an online purchase transaction that leads the investigator to a website that sells various strains of marijuana. Additional account review detects cash deposits into the account at the branch teller lines, so the investigator reaches out to the teller staff regarding the transactions. The teller staff member reports that the business customers have frequently deposited cash in lower amounts. The teller, without prompting, adds that one of the transactors would occasionally smell of a distinct scent of marijuana smoke.
Which information should be included in the SAR/STR?

• A. The fact that one of the transactors occasionally smelled of marijuana smoke
• B. Details of the transactor's social media accounts
• C. The customer information, including KYC background
• D. A transaction that is commensurate with the customer's background

An analyst reviews an alert for high volume Automated Clearing House (ACH) activity in an account. The analyst's initial research finds the account is for a commercial daycare account that receives high volumes of large government-funded ACH transactions to support the programs. The account activity consists of checks (cheques) made payable to individual names in varying dollar amounts. One check indicates rent to another business.
An Internet search finds that the daycare company owner has previous government-issued violations for safety and classroom size needs, such as not having enough chairs and tables per enrollee. These violations were issued to a different daycare name.
Simultaneous to this investigation, another analyst sends an email about negative news articles referencing local child/adult daycare companies misusing governmental grants. This prompts the financial institution (Fl) to search all businesses for names containing daycare' or care*. Text searches return a number of facilities as customers at the Fl and detects that three of these businesses have a similar transaction flow of high volume government ACH funding with little to no daycare expenses.
The analyst determines that site visits should be conducted for the three daycare businesses. Which observations at the on-site visits would justify writing a SAR/STR? (Select Three.)

• A. A full parking lot of cars with no staff at the site
• B. A site located in a commercial building
• C. Visible signage indicating the purpose of the building
• D. Visible attendance with children being dropped off by parents
• E. Signs of severe wear and poor maintenance at the site
• F. Lights turned off at the site during operational hours

In a SAR/STR narrative concerning Individual A. which statement indicates a product of analysis rather than a fact or judgement?

• A. Individual A made structured cash deposits possibly to circumvent regulatory reporting requirements
• B. Individual A made structured cash deposits on almost consecutive days.
• C. Individual A was the originator of nine wires totaling 225.000 USD between January and March 2020.
• D. Individual A is a college student and employed part-time at a car wash.