ACA Final Test Exam 2024\2025.
Structuring
Designing a transaction to evade triggering a reporting or record-keeping requirement.
Smurfing
Multiple individuals making multiple cash deposits and/or buying multiple monetary instruments or bank
drafts in amounts under the reporting threshold in an attempt to evade detection
Microstructuring
Structuring done at a much smaller level
Wash-trading or "offsetting" accounts
The entry of matching buys and sells in particular securities; which provides the illusion of trading. It
generates offsetting profits and losses through multiple accounts.
Free Trade Zone (FTZ)
Designated geographic areas with special regulatory and tax treatments
for certain trade-related goods and services.
Trade-Based Money Laundering
The process of disguising the proceeds of crime and moving value through
the use of trade transactions in an attempt to legitimize their illicit origins.
Over Invoicing
Invoicing goods or services at a price above the fair market price.
Under Invoicing
Invoicing goods or services at a price below the fair market price.
Over-shipping or Short-shipping
The difference in the invoiced quantity of goods and the quantity of goods that are shipped whereby the
buyer or seller gains excess value based on the payment made.
Ghost-shipping
Fictitious trades where a buyer and seller collude to prepare all the documentation indicating goods were
sold, shipped and payments were made, but no goods were actually shipped.
Shell companies
Corporate entities created with a view to to reduce the transparency of ownership in a transaction.
Multiple Invoicing
A form of trade-based money laundering whcih involved the use of numerous invoices issued for the same
shipment of goods, thus allowing the money launderer the opportunity to make numerous payments and
justify them with the invoices.
Black Market Trades
Commonly referred to as the Black Market Peso Exchange whereby a domestic transfer of funds is used
to pay for goods by a foreign importer
,ACA Final Test Exam 2024\2025.
Letters of Credit
A credit instrument issued by a bank that guarantees payments on behalf of its customer to a third party
when certain conditions are met
Funnel Accounts
an individual or business account in one geographic area that receives multiple cash deposits, often in
amounts below the cash reporting threshold, and from which the funds are withdrawn in a different
geographic area with little time elapsing between the deposits and withdrawals.
Black Market Peso Exchange
A process by which money in the United States derived from illegal activity is purchased by Colombian
peso brokers and deposited in US bank accounts that the brokers have established.
Electronic Purses
Cards that electronically store value on integrated circuit chips. Unlike pre-paid credit cards with
magnetic stripes that store account information, funds are stored on memory chips.
Virtual Currency (Digital Currency)
A medium of exchange that operates in the digital space. It can be converted into either a fiat (e.g., a
government-issued currency) or it can be a substitute for real currency.
International Business Company (IBC)
Entities formed outside of a person or businesses'
country of residence, typically in offshore jurisdictions, for confidentially or asset protection purposes.
Shelf Company
A corporation that has had no activity. It has been created and put on the shelf. This corporation is then
later sold to someone who prefers a previously registered corporation over a new one.
Shell Company
A company that at the time of incorporation has no significant assets or operations.
Asset Protection Trusts
A special form of irrevocable trust usually created offshore for the principle purpose of preserving one's
wealth from creditors.
The Hawala System
An informal value transfer system involving the international transfer of value outside the legitimate
banking system and based on a trusted network of individuals.
Numbered Account
A bank account where the identity of the account holder is not disclosed in the title of an account, and
identification to effect transactions takes place using a code word or number known only by the account
holder and a restricted number of bank employees, thus providing the account holder with a degree of
bank privacy in their financial transactions.
Comitology
, ACA Final Test Exam 2024\2025.
The EU system that oversees the implementation of acts proposed by the European Commission.
Third Country Citizen
Individuals who are in transit and/or applying for visas in countries that are not their country of origin
(i.e. country of transit)
The Wolfsberg Group
An association of 13 global banks that aims to develop financial services industry standards and guidance
related to Know Your Customer, Anti-Money Laundering and Counter-Terrorist Financing policies.
Egmont Group
An informal networking group of
financial intelligence units
CICAD
Commission within the Organization of American
States that deals with drug related issues, including money laundering
World Bank and International Monetary Fund
These organizations work together and in conjunction with FATF to encourage countries
to have adequate anti- money laundering laws and to review anti-money laundering laws and procedures
of FATF member countries.
Money Laundering Control Act of 1986
The world's first law to criminalize money laundering.
Section 311: US Patriot Act
Section of the US Patriot Act that provides the US Treasury Department with the authority to apply
graduated, proportionate measures against a foreign jurisdiction, a foreign financial institution, a type of
international transaction or a type of account that the Treasury Secretary determines to be a "primary
money laundering concern."
Section 312: US Patriot Act
Section of the US Patriot Act which requires
due diligence and, in certain situations, enhanced due diligence for foreign correspondent accounts
(which includes virtually all account relationships that institutions can have with a foreign financial
institution) and private banking for non-US persons.
Section 313: US Patriot Act
Section of the US Patriot Act which prohibits US banks and securities brokers and dealers from
maintaining correspondent accounts for foreign, unregulated shell banks that have no physical presence
anywhere.
Section 314 (A): US Patriot Act
Section of the US Patriot Act that enables US federal, state, local, and foreign (European Union) law
enforcement agencies, through FinCEN, to reach out to more than 43,000 points of contact at more than
Structuring
Designing a transaction to evade triggering a reporting or record-keeping requirement.
Smurfing
Multiple individuals making multiple cash deposits and/or buying multiple monetary instruments or bank
drafts in amounts under the reporting threshold in an attempt to evade detection
Microstructuring
Structuring done at a much smaller level
Wash-trading or "offsetting" accounts
The entry of matching buys and sells in particular securities; which provides the illusion of trading. It
generates offsetting profits and losses through multiple accounts.
Free Trade Zone (FTZ)
Designated geographic areas with special regulatory and tax treatments
for certain trade-related goods and services.
Trade-Based Money Laundering
The process of disguising the proceeds of crime and moving value through
the use of trade transactions in an attempt to legitimize their illicit origins.
Over Invoicing
Invoicing goods or services at a price above the fair market price.
Under Invoicing
Invoicing goods or services at a price below the fair market price.
Over-shipping or Short-shipping
The difference in the invoiced quantity of goods and the quantity of goods that are shipped whereby the
buyer or seller gains excess value based on the payment made.
Ghost-shipping
Fictitious trades where a buyer and seller collude to prepare all the documentation indicating goods were
sold, shipped and payments were made, but no goods were actually shipped.
Shell companies
Corporate entities created with a view to to reduce the transparency of ownership in a transaction.
Multiple Invoicing
A form of trade-based money laundering whcih involved the use of numerous invoices issued for the same
shipment of goods, thus allowing the money launderer the opportunity to make numerous payments and
justify them with the invoices.
Black Market Trades
Commonly referred to as the Black Market Peso Exchange whereby a domestic transfer of funds is used
to pay for goods by a foreign importer
,ACA Final Test Exam 2024\2025.
Letters of Credit
A credit instrument issued by a bank that guarantees payments on behalf of its customer to a third party
when certain conditions are met
Funnel Accounts
an individual or business account in one geographic area that receives multiple cash deposits, often in
amounts below the cash reporting threshold, and from which the funds are withdrawn in a different
geographic area with little time elapsing between the deposits and withdrawals.
Black Market Peso Exchange
A process by which money in the United States derived from illegal activity is purchased by Colombian
peso brokers and deposited in US bank accounts that the brokers have established.
Electronic Purses
Cards that electronically store value on integrated circuit chips. Unlike pre-paid credit cards with
magnetic stripes that store account information, funds are stored on memory chips.
Virtual Currency (Digital Currency)
A medium of exchange that operates in the digital space. It can be converted into either a fiat (e.g., a
government-issued currency) or it can be a substitute for real currency.
International Business Company (IBC)
Entities formed outside of a person or businesses'
country of residence, typically in offshore jurisdictions, for confidentially or asset protection purposes.
Shelf Company
A corporation that has had no activity. It has been created and put on the shelf. This corporation is then
later sold to someone who prefers a previously registered corporation over a new one.
Shell Company
A company that at the time of incorporation has no significant assets or operations.
Asset Protection Trusts
A special form of irrevocable trust usually created offshore for the principle purpose of preserving one's
wealth from creditors.
The Hawala System
An informal value transfer system involving the international transfer of value outside the legitimate
banking system and based on a trusted network of individuals.
Numbered Account
A bank account where the identity of the account holder is not disclosed in the title of an account, and
identification to effect transactions takes place using a code word or number known only by the account
holder and a restricted number of bank employees, thus providing the account holder with a degree of
bank privacy in their financial transactions.
Comitology
, ACA Final Test Exam 2024\2025.
The EU system that oversees the implementation of acts proposed by the European Commission.
Third Country Citizen
Individuals who are in transit and/or applying for visas in countries that are not their country of origin
(i.e. country of transit)
The Wolfsberg Group
An association of 13 global banks that aims to develop financial services industry standards and guidance
related to Know Your Customer, Anti-Money Laundering and Counter-Terrorist Financing policies.
Egmont Group
An informal networking group of
financial intelligence units
CICAD
Commission within the Organization of American
States that deals with drug related issues, including money laundering
World Bank and International Monetary Fund
These organizations work together and in conjunction with FATF to encourage countries
to have adequate anti- money laundering laws and to review anti-money laundering laws and procedures
of FATF member countries.
Money Laundering Control Act of 1986
The world's first law to criminalize money laundering.
Section 311: US Patriot Act
Section of the US Patriot Act that provides the US Treasury Department with the authority to apply
graduated, proportionate measures against a foreign jurisdiction, a foreign financial institution, a type of
international transaction or a type of account that the Treasury Secretary determines to be a "primary
money laundering concern."
Section 312: US Patriot Act
Section of the US Patriot Act which requires
due diligence and, in certain situations, enhanced due diligence for foreign correspondent accounts
(which includes virtually all account relationships that institutions can have with a foreign financial
institution) and private banking for non-US persons.
Section 313: US Patriot Act
Section of the US Patriot Act which prohibits US banks and securities brokers and dealers from
maintaining correspondent accounts for foreign, unregulated shell banks that have no physical presence
anywhere.
Section 314 (A): US Patriot Act
Section of the US Patriot Act that enables US federal, state, local, and foreign (European Union) law
enforcement agencies, through FinCEN, to reach out to more than 43,000 points of contact at more than
