CAMS · Question #949
Which of the following scenarios describe common risk indicators of money laundering faced by operators of legitimate money services businesses (MSBs)? (Select Three.)
The correct answer is A. A customer changes multiple high-denomination notes to low-denomination notes. B. A customer conducts cash transactions using multiple branches of the MSB on the same day. D. A customer sends and receives money transfers in equal amounts at or about the same time. MSBs face specific money laundering risk indicators tied to structuring behavior, use of multiple branches to avoid reporting thresholds, and equal-value send-and-receive patterns that suggest layering.
Question
Which of the following scenarios describe common risk indicators of money laundering faced by operators of legitimate money services businesses (MSBs)? (Select Three.)
Options
- AA customer changes multiple high-denomination notes to low-denomination notes.
- BA customer conducts cash transactions using multiple branches of the MSB on the same day.
- CA customer has a family link to the destination of a money transfer
- DA customer sends and receives money transfers in equal amounts at or about the same time.
- EA customer only wants to deal with a particular employee in the MSB.
How the community answered
(54 responses)- A76% (41)
- C15% (8)
- E9% (5)
Why each option
MSBs face specific money laundering risk indicators tied to structuring behavior, use of multiple branches to avoid reporting thresholds, and equal-value send-and-receive patterns that suggest layering.
Exchanging high-denomination notes for low-denomination notes is a classic placement-stage indicator, as it obscures the origin and denomination of funds and is a recognized typology in FATF guidance on MSBs.
Using multiple branches of the same MSB on the same day is a structuring indicator designed to stay below reporting thresholds at each location, a well-documented red flag in MSB AML guidance.
Having a family link to the destination of a money transfer is a normal, legitimate reason for international remittances and is not itself a risk indicator of money laundering.
Sending and receiving money transfers in equal amounts at approximately the same time suggests the MSB is being used as a pass-through layering mechanism, where funds are cycled to obscure their origin.
Preferring a specific employee alone is not a standard AML risk indicator for MSBs; while it could be a factor in a broader pattern, it does not independently signal money laundering activity.
Concept tested: MSB money laundering red flags and structuring indicators
Source: https://www.fatf-gafi.org/content/dam/fatf-gafi/guidance/RBA-money-value-transfer-services.pdf
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