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CAMS · Question #65

The compliance officer for a bank is reviewing on-boarding documents for a new business account for a domestic corporation. The officer is unable to verify the identity of the beneficial owners of…

The correct answer is B. The nature and purpose of the business include international remittance transfers. According to the ACAMS Study Guide 6th Edition, Chapter 2, page 37, one of the red flags of money laundering or terrorist financing is the use of nominees, trusts, or third parties to hide the identity, ownership, or control of the funds or assets involved in the transaction…

AML/CFT Compliance Programs

Question

The compliance officer for a bank is reviewing on-boarding documents for a new business account for a domestic corporation. The officer is unable to verify the identity of the beneficial owners of the company. Only information on the nominee owners was provided, and none of the listed addresses are local. The purpose of the business and future expected activity were disclosed to include cash letters, money orders and international remittance transfers. Which red flag identifies a heightened money laundering risk?

Options

  • AExpected activity was advised to include cash letter and money orders
  • BThe nature and purpose of the business include international remittance transfers
  • CThe names provided at account opening are identified as the corporation's representative
  • DAccount signer's government issued identification lists addresses outside of where the branch

How the community answered

(53 responses)
  • A
    2% (1)
  • B
    83% (44)
  • C
    11% (6)
  • D
    4% (2)

Explanation

According to the ACAMS Study Guide 6th Edition, Chapter 2, page 37, one of the red flags of money laundering or terrorist financing is the use of nominees, trusts, or third parties to hide the identity, ownership, or control of the funds or assets involved in the transaction. Nominees are individuals or entities that act on behalf of the actual or beneficial owners of a company, trust, or account, and may be used to conceal the source, destination, or purpose of the funds or assets. Nominees may also be used to evade taxes, sanctions, or regulatory requirements. In this case, the compliance officer is unable to verify the identity of the beneficial owners of the company, and only information on the nominee owners was provided. This raises the suspicion that the company may be involved in money laundering or terrorist financing activities, and that the nominee owners may be acting as fronts or intermediaries for the actual or beneficial owners. The compliance officer should conduct further due diligence on the company, the nominee owners, and the beneficial owners, and report any suspicious or unusual activity to the relevant

Topics

#beneficial ownership#nominee owners#CDD#high-risk activity

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