CAMS · Question #247
A money transmitter's nation-wide agent network remits funds to a country in Africa on behalf of an immigrant community based in the United States. A terrorist group is known to operate openly in…
The correct answer is D. The dollar amount of each transaction is just below the record keeping threshold. According to the ACAMS CAMS Study Guide, one of the common methods of money laundering and terrorist financing is to structure transactions to avoid reporting or record keeping requirements. Structuring involves breaking down a large amount of cash into smaller transactions…
Question
A money transmitter's nation-wide agent network remits funds to a country in Africa on behalf of an immigrant community based in the United States. A terrorist group is known to operate openly in this African country. In reviewing transaction records, the compliance officer detects a pattern where two customers together visit the same agent each week and remit the same amount of funds, $2,500, to the same recipient in the country in Africa. What should alert the compliance officer to possible money laundering or terrorist financing activity by the two customers?
Options
- AThe customers always visit together.
- BThe customers always visit the same agent.
- CThe funds are being sent to the same recipient each week.
- DThe dollar amount of each transaction is just below the record keeping threshold.
How the community answered
(53 responses)- A4% (2)
- B8% (4)
- C11% (6)
- D77% (41)
Explanation
According to the ACAMS CAMS Study Guide, one of the common methods of money laundering and terrorist financing is to structure transactions to avoid reporting or record keeping requirements. Structuring involves breaking down a large amount of cash into smaller transactions that fall below a specified threshold, or using different accounts, agents, locations, or days to conduct the transactions. Therefore, the fact that the two customers remit the same amount of funds, $2,500, each week to the same recipient in a high-risk country is a red flag for possible money laundering or terrorist financing activity, as it suggests that they are trying to evade the record keeping threshold of $3,000 for money transmitters in the United States.
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