A money transmitter's nation-wide agent network remits funds to a country in Africa on behalf of an immigrant community based in the United States. A terrorist group is known to operate openly in this African country. In reviewing transaction records, the compliance officer detects a pattern where two customers together visit the same agent each week and remit the same amount of funds, $2,500, to the same recipient in the country in Africa. What should alert the compliance officer to possible money laundering or terrorist financing activity by the two customers?
Correct Answer: D
According to the ACAMS CAMS Study Guide, one of the common methods of money laundering and terrorist financing is to structure transactions to avoid reporting or record keeping requirements. Structuring involves breaking down a large amount of cash into smaller transactions that fall below a specified threshold, or using different accounts, agents, locations, or days to conduct the transactions. Therefore, the fact that the two customers remit the same amount of funds, $2,500, each week to the same recipient in a high-risk country is a red flag for possible money laundering or terrorist financing activity, as it suggests that they are trying to evade the record keeping threshold of $3,000 for money transmitters in the United States12. References: * ACAMS CAMS Study Guide, 6th Edition, page 27 * FFIEC BSA/AML Appendices - Appendix F - Money Laundering and Terrorist Financing Red Flags1 * AML Red Flags - What are the Top 10 Indicators? - ComplyAdvantage2
Question 438
Which of the following represents the first Financial Action Task Force initiative?
Correct Answer: A
The first Financial Action Task Force (FATF) initiative was the 40 Recommendations on Money Laundering, which were issued in April 1990, less than a year after the FATF was established by the G7 summit in Paris in 1989. The 40 Recommendations aimed to provide a comprehensive plan of action to fight money laundering by setting out the principles and measures for effective legal, regulatory, and operational frameworks at the national and international levels. The 40 Recommendations have been revised and updated several times since then, most recently in 2022, to reflect the evolving trends and techniques of money laundering and to include the issues of terrorist financing and the financing of proliferation of weapons of mass destruction. The other options are not the first FATF initiative, but they are related to the FATF's work and mandate. The Report on Non-Cooperative Countries and Territories (NCCTs) was launched in 2000 to identify and monitor the jurisdictions that did not comply with the FATF standards and posed a risk to the international financial system. The Report on Money Laundering Typologies was first published in 1996 and has been updated annually to provide an analysis of the methods, techniques, and trends of money laundering and to assist the FATF members and observers in developing effective countermeasures. The Special Recommendations on Terrorist Financing were issued in October 2001, following the September 11 attacks, to complement the 40 Recommendations and to address the specific challenges of combating the financing of terrorism and terrorist acts. References: * History of the FATF, 1 * Financial Action Task Force - Wikipedia, 2 * Financial Action Task Force (FATF): What it is, How it Works - Investopedia, 3 * The FINANCIAL ACTION TASK FORCE (FATF) - INSIGHTSIAS, 4
Question 439
What is the main role of the Egmont Group in combating money laundering and terrorist financing?
