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The compliance officer should inform the bank’s legal counsel and follow their instructions when informed of the regulator’s notice. This is the most prudent and professionalcourse of action, as it ensures that the compliance officer acts in accordance with the bank’s policies and procedures, as well as the applicable laws and regulations. The compliance officer should also document the communication and cooperation with the legal counsel and the regulator, and preserve all relevant records and evidence relating to the matter. The compliance officer should not take any action that could compromise the integrity or confidentiality of the investigation, such as destroying records, insisting on the president’s resignation, or informing the president of the suspicions.

ACAMS CAMS Certification Study Guide, 6th Edition, page 47

ACAMS CAMS Certification Exam Outline, 6th Edition, Domain 2, Task 2.4

ACAMS CAMS Certification Video Training Course, Module 2, Lesson 2.4

Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition), Question 337

an employee who avoids taking periodic vacations despite having accrued vacation time may be trying to conceal fraudulent or illegal activities that would be exposed in their absence. This is a common red flag for internal fraud and money laundering, as it indicates a lack of segregation of duties, internal controls, and oversight. Employees who engage in such behavior may also exhibit other signs of stress, defensiveness, or secrecy.

Learn about red flags for internal fraud, section “An employee may be a higher internal fraud risk when a combination of the following red flags are present”, bullet point 1: “Unwilling to share duties or take leave.”

Money Laundering Red Flags | Key Behaviours and Indicators, section “Employee Red Flags”, bullet point 1: “Avoiding taking holidays or time off work.”

Top 10 AML Red Flags: Warning Signs and Financial Risks, section “AML Red Flags Categories”, sub-section “Employee Red Flags”, bullet point 1: “Avoiding taking vacations or sick leaves.”

When implementing a risk-based approach related to casinos, the risks related to the customer as an individual are mainly based on the customer’s profile, behaviour, source of funds, and geographic location. Among the options given, B and D are the most relevant factors that could indicate a higher risk of money laundering or terrorist financing.

Casual customers are those who do not have a regular or established relationship with the casino, and who may visit the casino only once or occasionally. They may not provide sufficient or reliable identification information, or may use false or stolen identities. They may also engage in suspicious transactions, such as large cash purchases of chips, minimal or no gaming activity, or frequent transfers of chips between customers. Casual customers pose a higher risk of money laundering or terrorist financing because they are harder to verify, monitor, and trace by the casino operators.

Customer from a high-risk country is a customer who resides in, or has links to, a country that is subject to sanctions, embargoes, or similar measures, or that is identified by credible sources as having significant levels of corruption, or as being a source, transit, or destination of illicit funds. Such customers pose a higher risk of money laundering or terrorist financing because they may be involved in, or connected to, criminal or terrorist activities, or may be using funds that are derived from or intended for such activities.

= The main reference for this question is the document titled “FATF Guidance on the Risk-Based Approach for Casinos” published by the FATF in October 2008. You can access it by clicking here. You can also find more information about the risk-based approach and the customer risks for casinos on the Gambling Commission website and the Exam Answer website.

The Egmont Group is a global network of 170 financial intelligence units (FIUs) that facilitate the exchange of information and cooperation among member FIUs to combat money laundering, terrorist financing, and associated predicate offences12. FIUs are national agencies that collect, analyze, and disseminate financial intelligence to relevant authorities3. The Egmont Group supports the implementation of international standardsand best practices for FIUs, provides training and technical assistance, and promotes the development of secure and effective communication channels12.

Egmont Group website

Egmont Group of Financial Intelligence Units - Wikipedia

ACAMS CAMS Study Guide (the 6thedition), Chapter 5: The Role of the Financial Intelligence Unit in Combating Money Laundering and Terrorist Financing, page 1532