Anti-Money Laundering Flashcards

Under the Bank Secrecy Act, what is the minimum threshold that triggers a mandatory Currency Transaction Report (CTR)?

Answer: $10,000

The BSA requires banks to file a CTR for any cash transaction exceeding $10,000 in a single business day.

Which of the following best describes 'layering' in the money laundering process?

Answer: Moving funds through multiple transactions to obscure their origin

Layering involves complex financial transactions designed to disguise the audit trail and separate the funds from their illegal source.

A customer makes multiple cash deposits of $9,500 on consecutive days. What AML concern does this raise?

Answer: Structuring (smurfing)

Structuring, also called smurfing, involves breaking up large cash amounts into smaller deposits to evade CTR filing requirements.

Which federal agency primarily administers and enforces the Bank Secrecy Act?

Answer: Financial Crimes Enforcement Network (FinCEN)

FinCEN, a bureau of the U.S. Treasury Department, is the primary regulator responsible for administering the BSA.

What does the term 'beneficial owner' refer to in the context of AML compliance?

Answer: The individual who ultimately owns or controls a legal entity

A beneficial owner is the natural person who ultimately owns or exercises control over a legal entity customer, as required to be identified under FinCEN's CDD Rule.

Which of the following is NOT one of the three stages of money laundering?

Answer: Structuring

The three stages of money laundering are placement, layering, and integration; structuring is a technique used during the placement stage, not a separate stage.

Under FinCEN's Customer Due Diligence (CDD) Rule, banks must identify beneficial owners of legal entity customers who own what percentage or more?

Answer: 25%

The CDD Rule requires identifying all natural persons who own 25% or more of a legal entity, plus one control person regardless of ownership percentage.