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CAMS · Question #950

The compliance officer at a casino in Taiwan discovers that the casino received multiple cash deposits from a customer just below the Large-Amount Transaction Report (LTR) limit on consecutive days…

The correct answer is B. Follow internal reporting procedures to escalate the activity as suspicious and report to. Multiple cash deposits just below the reporting threshold across different accounts on consecutive days is a textbook structuring pattern requiring internal suspicious activity escalation.

Conducting and Responding to Investigations

Question

The compliance officer at a casino in Taiwan discovers that the casino received multiple cash deposits from a customer just below the Large-Amount Transaction Report (LTR) limit on consecutive days. The customer used three different betting accounts. What is the appropriate next step?

Options

  • AMake a note in the customer's account that the customer's gambling activities are frequently
  • BFollow internal reporting procedures to escalate the activity as suspicious and report to
  • CInform the customer their activity Is suspicious and request an explanation
  • DContact law enforcement to launch an Investigation into the customer's financial activities

How the community answered

(70 responses)
  • A
    6% (4)
  • B
    81% (57)
  • C
    3% (2)
  • D
    10% (7)

Why each option

Multiple cash deposits just below the reporting threshold across different accounts on consecutive days is a textbook structuring pattern requiring internal suspicious activity escalation.

AMake a note in the customer's account that the customer's gambling activities are frequently

Simply noting the activity in the account does not fulfill the casino's legal AML obligations, as structuring behavior requires formal escalation and potential regulatory reporting, not passive documentation.

BFollow internal reporting procedures to escalate the activity as suspicious and report toCorrect

The pattern described - multiple sub-threshold deposits across multiple accounts on consecutive days - constitutes structuring, which triggers the obligation to file a Suspicious Transaction Report (STR) through internal escalation procedures; bypassing internal compliance channels or taking unilateral external action is not proper protocol.

CInform the customer their activity Is suspicious and request an explanation

Informing the customer that their activity is suspicious constitutes 'tipping off,' which is prohibited under AML laws in most jurisdictions including Taiwan, as it can allow the subject to evade investigation.

DContact law enforcement to launch an Investigation into the customer's financial activities

Directly contacting law enforcement bypasses mandatory internal compliance and regulatory reporting procedures; the correct process is to file an STR with the relevant financial intelligence unit, not to independently initiate a law enforcement investigation.

Concept tested: Structuring detection and suspicious transaction reporting in casinos

Source: https://www.fatf-gafi.org/content/dam/fatf-gafi/guidance/RBA-casinos.pdf

Topics

#structuring#casino AML#suspicious activity reporting#tipping off prohibition

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