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CAMS · Question #635

The AML investigator is reviewing the transaction monitoring alerts and the customer's historical profile for the past two years. A review of the negative news search from a blog indicates that the…

The correct answer is D. The account received a large cash deposit followed by systematic automated teller machine E. The customer conducts multiple cash transactions on a regular basis which do not match the. Given the customer's prior association with a terrorist group, large structured cash deposits followed by ATM withdrawals and cash transactions inconsistent with the customer's profile are the highest-priority escalation triggers.

Conducting and Responding to Investigations

Question

The AML investigator is reviewing the transaction monitoring alerts and the customer's historical profile for the past two years. A review of the negative news search from a blog indicates that the customer was previously part of a terrorist group. Which activities warrant further escalation? (Select Two.)

Options

  • AThe customer remitted monies in several transactions to the account of a recognized charity non-
  • BThe customer has bought and sold several real estate properties over the last year.
  • CThe credit transactions in the account relate mostly to salary and rental income from property.
  • DThe account received a large cash deposit followed by systematic automated teller machine
  • EThe customer conducts multiple cash transactions on a regular basis which do not match the

How the community answered

(37 responses)
  • A
    5% (2)
  • B
    16% (6)
  • C
    8% (3)
  • D
    70% (26)

Why each option

Given the customer's prior association with a terrorist group, large structured cash deposits followed by ATM withdrawals and cash transactions inconsistent with the customer's profile are the highest-priority escalation triggers.

AThe customer remitted monies in several transactions to the account of a recognized charity non-

While terrorist financing through charities is a known typology, remittances to a recognized and legitimate charity are not inherently suspicious on their own and do not rise to the same escalation priority as unexplained cash activity.

BThe customer has bought and sold several real estate properties over the last year.

Buying and selling real estate over the prior year is not inherently suspicious without additional indicators such as unexplained funding sources or rapid price manipulation, and is less alarming in isolation than the cash-related activity present in this account.

CThe credit transactions in the account relate mostly to salary and rental income from property.

Credit transactions consisting of salary and rental income represent documented and explainable sources of funds consistent with a legitimate financial profile, making them the lowest-risk activity in the account for escalation purposes.

DThe account received a large cash deposit followed by systematic automated teller machineCorrect

A large cash deposit followed by systematic ATM withdrawals is a structuring and layering pattern that, combined with a terrorism nexus identified in the negative news search, strongly indicates the account may be used to move funds for illicit purposes and warrants immediate escalation.

EThe customer conducts multiple cash transactions on a regular basis which do not match theCorrect

Multiple cash transactions that do not match the customer's known financial profile are a direct indicator of suspicious activity; for a customer linked to a terrorist group, unexplained cash activity is a high-risk indicator that requires further investigation and escalation.

Concept tested: Terrorist financing indicators in transaction monitoring alerts

Source: https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-on-terrorist-financing-risk-assessment.html

Topics

#terrorist financing#transaction monitoring#cash structuring#alert escalation

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