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Questions and Answers
Which of the following best describes an electronic funds transfer?
Which of the following best describes an electronic funds transfer?
Why are electronic funds transfers commonly used in money laundering schemes?
Why are electronic funds transfers commonly used in money laundering schemes?
Which of the following is NOT a common method for money launderers to use electronic transfers?
Which of the following is NOT a common method for money launderers to use electronic transfers?
In the context of money laundering, what is the purpose of 'layering' using electronic transfers?
In the context of money laundering, what is the purpose of 'layering' using electronic transfers?
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What is a common precaution money launderers take when using electronic transfers to avoid detection?
What is a common precaution money launderers take when using electronic transfers to avoid detection?
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What is the role of transaction monitoring software in regards to electronic transfers?
What is the role of transaction monitoring software in regards to electronic transfers?
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What does the content suggest about the effectiveness of systems designed to detect money laundering via electronic transfer?
What does the content suggest about the effectiveness of systems designed to detect money laundering via electronic transfer?
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Which of the following is an example of a system that facilitates electronic funds transfers?
Which of the following is an example of a system that facilitates electronic funds transfers?
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What is a key function of a comprehensive AML/CFT framework?
What is a key function of a comprehensive AML/CFT framework?
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How do front companies gain an advantage over legitimate businesses?
How do front companies gain an advantage over legitimate businesses?
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What is a potential consequence of using front companies and investments to launder money?
What is a potential consequence of using front companies and investments to launder money?
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How can money laundering and terrorist financing affect a country's financial sector?
How can money laundering and terrorist financing affect a country's financial sector?
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What is a typical requirement for financial organizations concerning AML/CFT programs?
What is a typical requirement for financial organizations concerning AML/CFT programs?
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What is a potential outcome for a financial organization that does not comply with its AML/CFT program?
What is a potential outcome for a financial organization that does not comply with its AML/CFT program?
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Why can money laundering lead to a misallocation of resources?
Why can money laundering lead to a misallocation of resources?
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How does money laundering relate to tax evasion?
How does money laundering relate to tax evasion?
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Under the SM&CR, what explicit responsibility is given to a senior manager in relation to financial crime?
Under the SM&CR, what explicit responsibility is given to a senior manager in relation to financial crime?
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According to the New York State Department of Financial Services (DFS) Final Rule, what is a key requirement for transaction monitoring and filtering programs?
According to the New York State Department of Financial Services (DFS) Final Rule, what is a key requirement for transaction monitoring and filtering programs?
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What does 'Model Performance Calibration' refer to in the context of AML/CFT models, according to the DFS Final Rule?
What does 'Model Performance Calibration' refer to in the context of AML/CFT models, according to the DFS Final Rule?
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What specific type of testing is required for transaction monitoring systems under the DFS Final Rule to ensure rules are validated and data are complete and accurate?
What specific type of testing is required for transaction monitoring systems under the DFS Final Rule to ensure rules are validated and data are complete and accurate?
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Who is required to annually certify to the DFS that they have taken all necessary steps to comply with transaction monitoring and filtering program requirements?
Who is required to annually certify to the DFS that they have taken all necessary steps to comply with transaction monitoring and filtering program requirements?
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Which types of financial organizations are explicitly covered by the New York State DFS Final Rule?
Which types of financial organizations are explicitly covered by the New York State DFS Final Rule?
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Besides chartered financial institutions, what other type of organization is included in the scope of the New York State DFS Final Rule, for example, a business with a banking law license?
Besides chartered financial institutions, what other type of organization is included in the scope of the New York State DFS Final Rule, for example, a business with a banking law license?
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What is the consequence for a senior manager who is personally accountable for misconduct within an organization’s AML/CFT regime?
What is the consequence for a senior manager who is personally accountable for misconduct within an organization’s AML/CFT regime?
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Which of the following scenarios is LEAST indicative of potential money laundering activity involving electronic transfers?
Which of the following scenarios is LEAST indicative of potential money laundering activity involving electronic transfers?
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A series of small, incoming transfers via checks and money orders followed by the majority of the funds wired to another account in a different location is an indicator of:
A series of small, incoming transfers via checks and money orders followed by the majority of the funds wired to another account in a different location is an indicator of:
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What banking product allows customers to deposit checks remotely by scanning images, increasing convenience but also potential for abuse?
What banking product allows customers to deposit checks remotely by scanning images, increasing convenience but also potential for abuse?
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Why is Remote Deposit Capture (RDC) considered a risky service in the context of money laundering?
Why is Remote Deposit Capture (RDC) considered a risky service in the context of money laundering?
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What is a major way that money launderers are now abusing the convenience of Remote Deposit Capture (RDC)?
What is a major way that money launderers are now abusing the convenience of Remote Deposit Capture (RDC)?
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What is 'correspondent banking'?
What is 'correspondent banking'?
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Which pattern of funds activity is considered a potential indicator of money laundering?
Which pattern of funds activity is considered a potential indicator of money laundering?
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What is a key benefit of Remote Deposit Capture (RDC) for banks?
What is a key benefit of Remote Deposit Capture (RDC) for banks?
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What is a primary vulnerability of correspondent banking regarding financial crime?
What is a primary vulnerability of correspondent banking regarding financial crime?
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According to the Wolfsberg Group, what factor should primarily drive the due diligence a bank performs on a respondent bank?
According to the Wolfsberg Group, what factor should primarily drive the due diligence a bank performs on a respondent bank?
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Which of these is NOT a specific risk indicator that should be addressed during due diligence on a respondent bank?
Which of these is NOT a specific risk indicator that should be addressed during due diligence on a respondent bank?
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When should both a respondent bank and its ultimate parent undergo due diligence?
When should both a respondent bank and its ultimate parent undergo due diligence?
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What does the Wolfsberg Group provide to help standardized due diligence in correspondent banking?
What does the Wolfsberg Group provide to help standardized due diligence in correspondent banking?
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Which of these services would be least likely to be offered to a high-risk respondent bank by a correspondent bank?
Which of these services would be least likely to be offered to a high-risk respondent bank by a correspondent bank?
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Which of these best describes a risk found in correspondent banking?
Which of these best describes a risk found in correspondent banking?
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What is a key limitation in a correspondent's ability to oversee their respondent?
What is a key limitation in a correspondent's ability to oversee their respondent?
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Which of the following is NOT one of the three stages of the money laundering cycle?
Which of the following is NOT one of the three stages of the money laundering cycle?
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What is the primary risk associated with payable-through accounts?
What is the primary risk associated with payable-through accounts?
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Which of the following best describes 'structuring' in the context of money laundering?
Which of the following best describes 'structuring' in the context of money laundering?
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What is a key risk associated with the use of concentration accounts?
What is a key risk associated with the use of concentration accounts?
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What is the main purpose of a shell company in money laundering schemes?
What is the main purpose of a shell company in money laundering schemes?
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What is a key characteristic of trade-based money laundering (TBML)?
What is a key characteristic of trade-based money laundering (TBML)?
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Which international organization is primarily responsible for setting global standards on combating money laundering and terrorist financing?
Which international organization is primarily responsible for setting global standards on combating money laundering and terrorist financing?
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What is the primary function of the Egmont Group of Financial Intelligence Units (FIUs)?
What is the primary function of the Egmont Group of Financial Intelligence Units (FIUs)?
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What is the main purpose of the USA PATRIOT Act?
What is the main purpose of the USA PATRIOT Act?
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Which of the following is NOT a typical method terrorists use to raise funds?
Which of the following is NOT a typical method terrorists use to raise funds?
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What is the 'layering' stage of money laundering primarily designed to do?
What is the 'layering' stage of money laundering primarily designed to do?
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What is a 'politically exposed person' (PEP) in the context of AML/CFT?
What is a 'politically exposed person' (PEP) in the context of AML/CFT?
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What is the main focus of the Basel Committee on Banking Supervision?
What is the main focus of the Basel Committee on Banking Supervision?
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Which of the following is a key risk associated with private banking?
Which of the following is a key risk associated with private banking?
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In the context of money laundering, what is 'microstructuring'?
In the context of money laundering, what is 'microstructuring'?
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Flashcards
Front Companies
Front Companies
Businesses that appear legitimate, but are controlled by criminals to mix illegal funds with legitimate ones, hiding the source of money.
Competitive Disadvantage for Legitimate Businesses
Competitive Disadvantage for Legitimate Businesses
The practice of criminals using front companies to create an unfair advantage in the market by subsidizing products at below-market prices.
Economic Instability
Economic Instability
The negative impact of money laundering on economic stability due to the misuse of resources caused by manipulated prices.
Controlling Industries Through Money Laundering
Controlling Industries Through Money Laundering
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Tax Evasion through Money Laundering
Tax Evasion through Money Laundering
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Weakening of Financial Organizations
Weakening of Financial Organizations
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Loss of Financial License
Loss of Financial License
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Importance of AML/CFT Compliance
Importance of AML/CFT Compliance
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Electronic Funds Transfer
Electronic Funds Transfer
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SWIFT (Society for Worldwide Interbank Financial Telecommunication)
SWIFT (Society for Worldwide Interbank Financial Telecommunication)
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Layering (in money laundering)
Layering (in money laundering)
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Structuring (in money laundering)
Structuring (in money laundering)
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Unauthorized Transfers
Unauthorized Transfers
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Automated Clearing House (ACH)
Automated Clearing House (ACH)
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Money Laundering (in general)
Money Laundering (in general)
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Transaction Monitoring Software
Transaction Monitoring Software
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Financial Secrecy Haven Transfers
Financial Secrecy Haven Transfers
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Unexplained Foreign Transfers
Unexplained Foreign Transfers
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Small Deposits, Big Transfers
Small Deposits, Big Transfers
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Unusual Financial Patterns
Unusual Financial Patterns
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Unrelated Payments
Unrelated Payments
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Multiple Accounts, Same Person
Multiple Accounts, Same Person
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Remote Deposit Capture (RDC)
Remote Deposit Capture (RDC)
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RDC Abuse Risk
RDC Abuse Risk
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Correspondent Bank
Correspondent Bank
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Respondent Bank
Respondent Bank
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Due Diligence on Respondent Banks
Due Diligence on Respondent Banks
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Respondent Bank Risk
Respondent Bank Risk
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Know Your Customer's Customer (KYCC)
Know Your Customer's Customer (KYCC)
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Transaction Monitoring of Respondent Banks
Transaction Monitoring of Respondent Banks
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Regulatory Oversight of Respondent Banks
Regulatory Oversight of Respondent Banks
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Wolfsberg Group Correspondent Banking Due Diligence Questionnaire
Wolfsberg Group Correspondent Banking Due Diligence Questionnaire
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Money Laundering Reporting Officer (MLRO)
Money Laundering Reporting Officer (MLRO)
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Transaction Monitoring
Transaction Monitoring
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AML/CFT Regime
AML/CFT Regime
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Model Performance Calibration
Model Performance Calibration
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End-to-End Testing
End-to-End Testing
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Risk-Based Approach
Risk-Based Approach
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Money Laundering
Money Laundering
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Placement
Placement
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Layering
Layering
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Integration
Integration
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Structuring
Structuring
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Correspondent Banking
Correspondent Banking
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Concentration Accounts
Concentration Accounts
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Private Banking
Private Banking
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Private Investment Companies (PICs)
Private Investment Companies (PICs)
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Politically Exposed Persons (PEPs)
Politically Exposed Persons (PEPs)
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Credit Unions
Credit Unions
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Third-Party Payment Processors
Third-Party Payment Processors
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Money Services Businesses (MSBs)
Money Services Businesses (MSBs)
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Trade-Based Money Laundering (TBML)
Trade-Based Money Laundering (TBML)
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Study Notes
Introduction to Money Laundering and Terrorist Financing
- ACAMS (Association of Certified Anti-Money Laundering Specialists) is an organization focused on anti-money laundering (AML) and combating the financing of terrorism (CFT).
- Access to this document is strictly for personal study purposes and is not permissible for any other usage without formal consent from ACAMS.
- ISBN: 978-0-9777495-2-2
Risks and Methods of Money Laundering and Terrorist Financing
- Money Laundering: The process of disguising illicitly obtained funds as legitimate.
- Three Stages of Money Laundering:
- Placement: Initially transferring illicit funds into legitimate financial systems.
- Layering: Complex transactions to mask the original source of funds.
- Integration: The proceeds appear to be legitimate funds.
- Money laundering and terrorist financing harm a nation's financial sector and private sector.
- Illicit activity can destabilize individual financial institutions and banks, shown by instances of past bank closures.
- Non-compliance with AML/CFT programs can lead to harsh civil penalties and loss of operating licenses.
Banks and Other Depository Institutions
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Electronic Funds Transfers: Rapid and versatile, easily concealing illicit transactions among legitimate ones.
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Various methods like ACH, ATM, mobile phones are used by perpetrators.
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Risks include unauthorized transfers, credit card fraud, and layering.
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Remote Deposit Capture (RDC): A service allowing customers to electronically deposit checks.
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Increased convenience but also easily abused by criminals.
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Correspondent Banking: One bank providing services to another.
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High risk from lack of direct customer knowledge.
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Banks should evaluate respondent banks for risks in due diligence.
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Questions based on risk profile, geography, management, and services are key.
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Payable-Through Accounts: Account used as an intermediary; Money laundering through these accounts are made possible by their inherent opacity.
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Concentration Accounts: Account designed to collect and aggregate funds from multiple sources.
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Private Banking: High-net-worth individuals can be high risk for engaging in money laundering.
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Private Investment Companies (PICs): Used for intricate money laundering schemes due to their obscurity; Funds are commingle into legitimate companies masking the source of assets .
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Politically Exposed Persons (PEPs): Individuals holding prominent positions who are significantly at risk of money laundering given their status.
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Structuring: Manipulating transactions to avoid regulatory reporting thresholds, this is a technique of avoiding triggering AML compliance protocols.
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Microstructuring: A type of structuring aimed to evade reporting requirements.
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Credit Unions and Building Societies (CU/BS): Similar AML risk to banks but face some unique challenges.
Non-bank Financial Institutions
- Credit Cards: High-volume transactions; potential avenue for illicit activity.
- Third-Party Payment Processors: Facilitating electronic payments; may be involved in money laundering.
- Money Services Businesses (MSBs): Companies involved in financial transactions; prone to money laundering (ex: Bureaus and money transfer services).
Insurance Companies, Securities Broker-Dealers, and Nonfinancial Businesses
- Insurance Companies and Securities Broker-Dealers: These institutions are vulnerable to money laundering. Dealers frequently handle large volume of assets from high-value transactions.
- Casinos: High-value transactions without extensive oversight, increasing vulnerability to money laundering.
- Dealers in High-Value Items: Dealers in precious metals, gems, art, etc. face elevated money laundering risks as these assets easily conceal illicit capital.
- Travel Agencies and Websites: Facilitating international travel, vulnerable to money laundering.
- Vehicle Sales: Selling luxury vehicles and use of vehicles as fronts for money laundering.
- Gatekeepers: Notaries, accountants, auditors, and lawyers can be instrumental in facilitating suspicious activity.
- Investment and Commodity Advisors: Expertise in financial instruments; potential facilitators in money laundering schemes.
- Trust and Company Service Providers: Assist in setting up complex structures concealing beneficial ownership; facilitate concealing assets in trust schemes.
- Real Estate: Can be used to launder assets through shell entities or property ownership.
International Trade Activity (Trade-Based Money Laundering)
- Free Trade Zones: Designated areas; money can be moved easily given the reduced regulatory oversight.
- Trade-Based Money Laundering (TBML): Using international trade processes to conceal illicit funds.
- Black Market Peso Exchange (BMPE): A type of trade-based money laundering, characterized by the use of an illicit market.
- Wildlife Trafficking: another avenue to launder funds.
Risk Associated with New Payment Products and Services
- Prepaid Cards, Mobile Payments, and Internet-Based Payment Services: Newer payment methods can obfuscate transactions making them vulnerable.
- Virtual Currency (Crypto-currency): Cryptocurrency can be used to hide transactions.
- Dark Web: A portion of the internet used anonymously; serves as a hub for illicit financial activities involving cryptocurrency.
Corporate Vehicles Used to Facilitate Illicit Finance
- Public Companies and Private Limited Companies: Corporations can be used to conceal ownership and transactions.
- Shell and Shelf Companies: Companies with minimal activities used to hide true ownership.
- Trusts: Used to obscure ownership and control in asset transfers.
Terrorist Financing
- Differences and Similarities between Terrorist Financing and Money Laundering: Both involve financial transactions.
- Detection of Terrorist Financing: Evaluating suspicious transactions and sources of funds used by terrorist organizations.
- Use of Hawala and Informal Value Transfer Systems: Cryptographic mechanisms used by terrorist organizations to conceal financial activities.
- Use of Charities and Nonprofit Organizations (NPOs): Fundraising through NGOs (Non-profit organizations) to channel funds.
International AML/CFT Standards
- Financial Action Task Force (FATF): Develops standards and guidelines for AML and CFT.
- FATF 40 Recommendations: Key guidelines; 40 specific recommendations to facilitate money laundering compliance.
- FATF-Style Regional Bodies: Regional organizations following the FATF model (ex: APG, CFATF).
Key US Legislative and Regulatory Initiatives
- USA PATRIOT Act: Important US Law; significantly increases US AML and CFT measures.
- Anti-Money Laundering Act (AMLA) of 2020: Updated legislation, aimed at curbing money laundering.
- Office of Foreign Assets Control (OFAC): US department; enforced US sanctions.
- Bank Secrecy Act (BSA): US Act; imposes requirements on US. Financial organizations regarding recordkeeping and reporting suspicious activity.
- New York State Department of Financial Services (DFS): Key regulator in US; responsible for enforcing AML compliance in financial institutions.
AML/CFT Compliance Programs
- Assessing AML/CFT Risk: Evaluating the probability and impact of financial crimes.
- Risk-based models are crucial in accurately assessing the susceptibility to money laundering
- AML/CFT Program: Essentials of a compliance program include Policies, procedures, training, monitoring, and independent audit.
- Compliance Officer Accountability: Senior officers are accountable for AML program effectiveness.
- AML/CFT Training: Comprehensive training is required to ensure operational staff has an understanding of money laundering
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Description
This quiz explores the essential concepts of money laundering and terrorist financing, as introduced by ACAMS. It covers the risks associated with these financial crimes and elaborates on the three stages of money laundering: placement, layering, and integration. Gain insights into how these activities affect the financial sector and measures to combat them.