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MONEY LAUNDERING
What is money laundering? - CORRECTANSWER Money laundering is the taking of criminal
proceeds and disguising their illegal sources in order to use the funds to perform legal or illegal
acts.
THREE STAGES IN THE MONEY LAUNDERING CYCLE
Give an example of the second stage of money laundering. - CORRECTANSWER Electronically
moving funds from one country to another; moving funds from one financial institution to
another; and converting the cash placed into the system into monetary instruments.
THREE STAGES IN THE MONEY LAUNDERING CYCLE
Give an example of the third stage of money laundering. - CORRECTANSWER Purchasing luxury
assets like property, artwork, jewelry or high-end automobiles; and investing in business
enterprises.
THREE STAGES IN THE MONEY LAUNDERING CYCLE
,Give an example of the first stage of money laundering. - CORRECTANSWER Commingling
illegitimate funds with legitimate ones; making foreign exchange transactions with illegal funds;
and depositing small amounts of cash into various accounts.
INDIVIDUAL ACCOUNTABILITY
What does the Yates memo say? - CORRECTANSWER The Yates memo, issued by then-Deputy
Attorney General Sally Yates of the Department of Justice, reminds prosecutors that criminal
and civil investigations into corporate misconduct should also focus on individuals who
perpetrated the wrongdoing.
ELECTRONIC TRANSFERS OF MONEY
What are some indicators of money laundering using electronic transfers of funds? -
CORRECTANSWER Funds transfers to or from a financial secrecy haven; large, incoming fund
transfers from a foreign client with littleor no explanation or apparent reason; and fund
transfers that have no apparent link to legitimate business.
REMOTE DEPOSIT CAPTURE
What is remote deposit capture and what risk is associated with it? - CORRECTANSWER Remote
deposit capture is a product offered by banks that allows customers to scan a check and
transmitan electronic image to the bank for deposit. The risk associated with it is that it enables
a money launderer to deposit checks without having to visit the bank and risk detection.
PAYABLE THROUGH ACCOUNTS
What are some of the money laundering risks pertaining to the use of payable through accounts
(PTAs)? - CORRECTANSWER PTAs with foreign institutions licensed in offshore centers with each
bank supervision; PTAs where the respondent bank (the foreign bank) fails to conduct adequate
customer due diligence; and PTAs where the sub-account holders have currency deposit and
withdrawal privileges.
CONCENTRATION ACCOUNTS
,What is a money laundering risk pertaining to the use of concentration accounts? -
CORRECTANSWER The primary money laundering risk pertaining to the use of concentration
accounts is the fact that the customer- identifying information may not be included, making the
audit trail difficult or impossible to follow.
PEPS
What is a PEP and what is the primary risk in dealing with a PEP? - CORRECTANSWER A PEP is a
"politically exposed person," meaning a person who has or has had a prominent government or
quasi-public position in a country. The primary risk in dealing with a PEP is that the source of
funds from a PEP may be from corruption.
STRUCTURING
What is structuring? - CORRECTANSWER Structuring involves taking a large cash deposit and
breaking it into smaller amounts to be deposited into separate banks, separate accounts or on
separate days in order to avoid currency transaction reports.
CREDIT CARDS
Which money laundering stage(s) are credit cards most likely to be used and what is an example
of money laundering through the use of credit cards? - CORRECTANSWER Credit cards are not
likely to be used in the initial placement of money laundering. They are more likely to be used in
the layering or integration stages of money laundering. One example of using credit cards for
money laundering purposes is overpaying a credit card balance and then asking for a refund.
Receiving a check from the reputable credit card company makes it look like the funds received
are legitimate.
THIRD-PARTY PAYMENT PROCESSORS
What are some of the risks posed by Third-Party Payment Processors (TPPPs)? -
CORRECTANSWER Multiple financial institution relationships whereby the TPPP's suspicious
activity cannot be seen in its entirety by one institution; engaging in ACH transactions from
overseas whereby the suspicious transactions get hidden by the large number of other
transactions the TPPP engages in; and the possibility of the return rates stemming from
unauthorized transactions are higher than average.
, MONEY SERVICES BUSINESSES
What are some ways Money Services Businesses can be used for money laundering? -
CORRECTANSWER Cashing checks without obtaining adequate proof of identity; failing to file
Currency Transaction Reports when required; and transmitting funds overseas without sufficient
due diligence.
SECURITIES BROKER-DEALERS
What are some of the aspects associated with securities broker- dealers that increase the risk of
money laundering? - CORRECTANSWER Its international nature; the speed of their transactions;
the ease of converting holdings into cash without significant loss of principal; the large volume
of wires used; the competitive, commission-driven environment; the practice of maintaining
securities accounts in the name of nominees or trusts; and weak AML programs.
CASINOS
What are some red flags associated with casinos and gambling? - CORRECTANSWER Paying off
gambling debts in cash just under the reporting requirements; purchasing chips, but engaging in
minimal gambling and then cashing the chips backin; using the gambling house for banking-like
financial services, including wiring funds overseas; betting on both "red" and "black" spaces in
roulette; and purchasing chips with cash just under the reporting requirements.
DEALERS IN HIGH-VALUE ITEMS
What were two of the key findings by FATF in its report on "Money Laundering/Terrorist
Financing Risks and Vulnerabilities Associated With Gold," issued in July, 2015? -
CORRECTANSWER The fact that gold is an extremely attractive vehicle for laundering money
due to the fact that it is relatively compact and easy to transport; and the fact that the gold
market is a target for criminal activity because it is lucrative and holds its value regardless of the
form it takes.
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