AML Certification CAMS Exam Dumps

 According to the Anti-Money Laundering Specialist (the 6th edition) resources, one of the challenges of online financial technologies is the difficulty of verifying the identity and legitimacy of the customers and counterparties. This creates opportunities formoney launderers and other criminals to exploit the anonymity and speed of online transactions to move and conceal illicit funds. The other options are not directly related to the money laundering risk posed by online financial technologies.

The customer’s business activity as a domestic carpet cleaning company is not inherently suspicious, as it aligns with their registered business. However, the significant weekly transactions from an international reputable antique auction house raise red flags.

The sudden increase in the customer’s initial international receipt from $15,000 USD to an average of $30,000 USD per transaction per week is also noteworthy. Such a substantial change warrants further scrutiny.

The fact that 90% of the incoming deposits are matched by cash outgoings to non-related individuals could indicate layering or structuring activities associated with money laundering.

Overall, the combination of large international transactions, increased receipts, and cash outflows to unrelated parties from an antique auction house is the most concerning aspect.

Casinos and gambling institutionsare highly vulnerable to money launderingbecause they allow theconversion of cash into chips, checks, or electronic credits, which can later be redeemed as “clean” funds.

Option A (Correct):A privately held company funding multiple patrons' betting accounts is highly suspiciousand may indicate:

Structuring/smurfing, where multiple individuals are used to move illicit funds.

Third-party money laundering, where the real source of funds is obscured.

Trade-based money laundering, if linked to non-gaming businesses.

Why Other Options Are Incorrect:

Option B (Incorrect):Placing multiple bets on the same eventis not inherently suspiciousunless linked tofraudulent betting patterns.

Option C (Incorrect):Large chip purchases in cashmay requirereporting, but they do not necessarily indicatemoney laundering.

Option D (Incorrect):Transferring winnings to another operator may beunusual, butnot automatically suspiciousunless the amount is large and unjustified.

Common Money Laundering Techniques in Casinos:

Chip Walking– Buying chips with illicit funds and cashing them out later as "clean" funds.

Casino Account Transfers– Using multiple accounts or third-party accounts to move funds.

High-Value Gambling with No Loss Intent– Betting on both sides of an event to ensure clean withdrawal of funds.

Best Practices for Casino AML Compliance:

Monitor suspicious large transactions and third-party funding activities.

Perform enhanced due diligence (EDD) on high-risk patrons.

File Suspicious Transaction Reports (STRs) for unusual gambling activity.

Financial institutions (FIs) are required to cooperate with law enforcement agencies (LEAs) in their investigations of money laundering, terrorist financing, and other financial crimes. However, sometimes LEAs may submit requests for information or documents that are overly broad, unduly intrusive, or unreasonable in scope or volume. Such requests may pose challenges or risks for FIs, such as violating customer privacy, compromising data security, disrupting business operations, or incurring excessive costs.

The most appropriate response for an FI in such a situation is to narrow the request through a prompt response to the LEA. This means that the FI should communicate with the LEA as soon as possible to clarify the purpose, scope, and relevance of the request, and to negotiate a more reasonable and proportionate request that meets the LEA’s needs and the FI’s capabilities. The FI should also explain the potential difficulties or consequences of complying with the original request, and propose alternative or additional sources of information that may be more useful or accessible. The FI should document the communication and the agreed terms of the request, and comply with the request in a timely and accurate manner.

By narrowing the request through a prompt response, the FI can demonstrate its good faith and willingness to cooperate with the LEA, while also protecting its own interests and obligations. This can help avoid or resolve any conflicts or misunderstandings between the FI and the LEA, and facilitate a more efficient and effective investigation.