A new AML Officer for a US-based money service business (MSB) is drafting procedures around types of activity that require further review. Which should be included? (Choose two.)

Question

Options

• AA customer visiting multiple branches of the MSB on the same day in order to transfer funds
• BA customer buying several money orders totaling over $10,000 USD using debit card on the
• CA customer sending funds to a family member living in a high-risk jurisdiction that is subject to
• DA customer buying multiple money orders for $250 totaling $2,000 USD.
• EA customer attempting to buy money orders under $3,000 USD in cash multiple times a day.

• A
  85% (28)
• B
  3% (1)
• C
  3% (1)
• D
  9% (3)

Explanation

A customer visiting multiple branches of the MSB on the same day in order to transfer funds internationally is a potential indicator of structuring, which is a technique used by money launderers to avoid reporting thresholds or detection by authorities. A customer attempting to buy money orders under $3,000 USD in cash multiple times a day is also a possible sign of structuring, as well as an attempt to evade the identification and recordkeeping requirements for MSBs. Both scenarios should be included in the procedures for further review by the AML Officer.

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