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CAMS · Question #42

CAMS Question #42: Real Exam Question with Answer & Explanation

The correct answer is A. The LLC's ownership is not disclosed to the bank C. The repayment in the amount of $9,000 indicates potential structuring. According to the ACAMS study guide, one of the red flags for money laundering in loan transactions is "the use of shell companies or other legal entities whose ownership is not transparent or whose beneficial owners are unknown" (p. 223). Money launderers may use such entities to

Question

A bank located in Arizona is considering a loan application for a new client. The collateral for the loan is a property in Florida. The loan will be in the name of a limited company (LLC) whose ownership is not disclosed to the bank. The LLC was established by a New York-based attorney. The loan will be repaid by the LLC in monthly wire transfers of $9,000 which is more than the required monthly payment. Which aspect indicates potential for money laundering?

Options

  • AThe LLC's ownership is not disclosed to the bank
  • BThe collateral, a property in Florida, is not located in Arizona
  • CThe repayment in the amount of $9,000 indicates potential structuring
  • DThe attorney associated with the account is outside the bank's lending area

Explanation

According to the ACAMS study guide, one of the red flags for money laundering in loan transactions is "the use of shell companies or other legal entities whose ownership is not transparent or whose beneficial owners are unknown" (p. 223). Money launderers may use such entities to hide their identity and the source of their funds, or to create complex layers of transactions to obscure the trail of money. The other options are not necessarily indicative of money laundering risk, as they could be explained by legitimate factors such as the location of the property, the repayment schedule, or the choice of attorney.

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