CAMS · Question #811
Which payment type presents the highest financial crime risk?
The correct answer is B. A payment made to a mixer platform. This question tests the ability to identify the highest-risk payment type based on known money laundering typologies. Mixer platforms are a well-documented red flag in virtual asset financial crime.
Question
Which payment type presents the highest financial crime risk?
Options
- AA check returning a mortgage overpayment made in error
- BA payment made to a mixer platform
- CA regular standing order to a high-interest savings account
- DA bill payment made to a friend after splitting a dinner bill
How the community answered
(28 responses)- A11% (3)
- B79% (22)
- C7% (2)
- D4% (1)
Why each option
This question tests the ability to identify the highest-risk payment type based on known money laundering typologies. Mixer platforms are a well-documented red flag in virtual asset financial crime.
A check returning a mortgage overpayment has a clear, documented business purpose and an identifiable counterparty, presenting negligible financial crime risk.
Mixer (or tumbler) platforms are specifically designed to obfuscate the origin and ownership of cryptocurrency by pooling and redistributing funds, making them a primary tool for layering in money laundering. FATF and FinCEN have both identified payments to mixers as a high-risk typology requiring enhanced scrutiny and suspicious activity reporting.
A regular standing order to a named savings account is a routine, low-value, repetitive transaction consistent with normal retail banking behavior and exhibits no typology indicators.
A small peer-to-peer payment for a shared dining expense is a common, explainable, low-value transaction that poses no meaningful financial crime risk.
Concept tested: Virtual asset mixer platforms as money laundering red flags
Source: https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-RBA-virtual-assets-2021.html
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