CAMS · Question #636
A customer puts high-denomination cash notes into a poker machine at a casino. Without placing any bets, the customer collected winnings in the form of a check from the casino. Which money…
The correct answer is B. Legitimizing illicit funds. Converting illicit cash into a casino-issued check without gambling creates a facade of legitimate winnings, which is the defining characteristic of legitimizing illicit funds through placement and layering.
Question
A customer puts high-denomination cash notes into a poker machine at a casino. Without placing any bets, the customer collected winnings in the form of a check from the casino. Which money laundering threats could result from the customer's activities?
Options
- AMicro-structuring cash
- BLegitimizing illicit funds
- CMisuse of money service business
- DObscured beneficial ownership
How the community answered
(61 responses)- A2% (1)
- B85% (52)
- C8% (5)
- D5% (3)
Why each option
Converting illicit cash into a casino-issued check without gambling creates a facade of legitimate winnings, which is the defining characteristic of legitimizing illicit funds through placement and layering.
Micro-structuring involves deliberately breaking large cash amounts into multiple smaller transactions to stay below regulatory reporting thresholds, which is not occurring in this single large-denomination cash transaction.
The customer exploits the casino environment to convert criminal cash proceeds into a check that carries the appearance of lawful gambling winnings, completing the placement and initial layering stages of money laundering. This technique is effective because casinos are a plausible source of large cash winnings, providing a seemingly legal origin for illicit funds. The conversion from cash to a negotiable instrument also facilitates integration of those funds into the broader financial system.
Misuse of a money service business describes exploiting licensed MSBs such as currency exchangers or check cashers to move or convert funds, which does not specifically capture the act of converting cash into seemingly legitimate gambling proceeds via a casino.
Obscured beneficial ownership involves concealing the true owner of funds or legal entities through nominees or layered corporate structures, a technique unrelated to this individual's direct cash-to-check conversion at the casino.
Concept tested: Casino placement and layering in money laundering
Source: https://www.fatf-gafi.org/en/publications/Methodsandtrends/Vulnerabilitiesofcasinosandgamingsector.html
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