Money Services Businesses (MSBs)are commonly recognized by regulatory and supervisory authorities as havinghigher inherent AML/CFT risk, particularly due to certain business characteristics.
Option B - The prevalence of international wire transfers:
MSBs often facilitatecross-border transactions, which present a higher money laundering and terrorist financing risk due to challenges in verifying customer identity, the origin of funds, and the end destination- especially when dealing with higher-risk jurisdictions.
Option D - The cash-intensive nature of the services offered:
Many MSBs deal primarily incash, which increases the risk ofanonymous transactionsandfunds layering, making it harder to trace illicit activity. Cash is the most vulnerable medium for placement of illicit funds into the financial system.
Option AandOption E, while involving modern technologies,can actually reduce riskwhen implemented with proper controls (e.g., secure digital onboarding and traceable payments enhance auditability).
Option Cdoes not in itself signal high AML risk unless combined with other red flags.
Reference: ACAMS CAMS Study Guide - 6th Edition, Chapter:Industry-Specific Risks- Section:Money Services Businesses (MSBs) and Their Risk Characteristics

Gatekeepers (e.g., accountants, auditors, lawyers) play a critical role in detecting financial crime.
* Option B (Correct):Corporate clientsposehigher money laundering risksdue tocomplex ownership structures and cross-border financial activities.
* Option C (Correct):The nature of requested services(e.g.,offshore structuring, large cash transactions) can indicate potentialmoney laundering attempts.
Why Other Options Are Incorrect:
* Option A (Incorrect):The length of time a client has been with an accounting firm does not necessarily indicate financial crime risk.
* Option D (Incorrect):Short-term relationships may be high-risk, but understanding the business type and services requested is more critical.
Red Flags for Money Laundering in Professional Services:
* Clients requesting offshore structures for no apparent business reason.
* Use of complex trusts or nominee directors to obscure ownership.
* Unexplained large transactions moving through legal or accounting firms.
Best Practices for Gatekeepers to Prevent Money Laundering:
* Perform Enhanced Due Diligence (EDD) on high-risk clients.
* Report unusual financial activity to FIUs.
* Follow FATF's DNFBP (Designated Non-Financial Businesses and Professions) AML guidelines.
Reference:
FATF Recommendation 22 (AML Compliance for Accountants and Lawyers)
Wolfsberg Group Guidance on DNFBP AML Risks
EU 6th AML Directive (6AMLD) on DNFBP Risk Management
Final Thoughts:
FIUs play a central role in financial intelligence collection and sharing.
The Egmont Group enables cross-border AML cooperation among FIUs.
Gatekeepers, such as accountants and lawyers, must monitor corporate clients for money laundering risks.

According to the Wolfsberg Anti-Money Laundering (AML) Principles for Correspondent Banking, one of the key aspects of establishing and maintaining a correspondent relationship is to conduct a risk-based due diligence on the respondent bank, which includes obtaining approval from at least one person other than the person sponsoring the relationship12. This is to ensure that the correspondent bank has a clear understanding of the nature, purpose, and expected activity of the relationship, as well as the respondent bank's ownership, governance, AML policies, and customer base12.
Another aspect of the Wolfsberg AML Principles is to recognize and assess the factors that may increase the risk inherent in a correspondent relationship, such as the involvement of politically exposed persons (PEPs), the presence of downstream (nested) correspondents, the geographic location of the respondent bank and its customers, and thetypes of products and services offered by the respondent bank12. These factors may require enhanced due diligence, monitoring, and reporting of suspicious activities by thecorrespondent bank, as well as the application of appropriate risk mitigation measures12.
:
1: Wolfsberg Correspondent Banking Principles 20221
2: Wolfsberg Anti-Money Laundering Principles for Correspondent Banking2 Reference: https://www.wolfsberg-principles.com/sites/default/files/wb/pdfs/wolfsberg-standards/8.%
20Wolfsberg-Correspondent-Banking-Principles-2014.pdf

AMutual Legal Assistance Treaty (MLAT)is aformal agreement between two or more countriesthat facilitatescooperation in legal and law enforcement matters, includingAML investigations.
* Option D (Correct):MLATs allow governments to share financial intelligence, request legal assistance, and conduct joint investigations.
* Option A (Incorrect):A Memorandum of Agreement (MOA) is typically a non-binding contract used for general business or governmental cooperation.
* Option B (Incorrect):A Declaration of Understanding is an informal agreement and does not provide a legal framework for law enforcement cooperation.
* Option C (Incorrect):A Memorandum of Understanding (MOU) is often used for informal cooperation but lacks the legal enforceability of an MLAT.
* Option E (Incorrect):A Request for Urgent Information is not a recognized international legal instrument.
Best Practices for Cross-Border AML Cooperation:
* Use MLATs to request access to financial records in foreign jurisdictions.
* Collaborate with Financial Intelligence Units (FIUs) via the Egmont Group.
* Leverage FATF's International Cooperation Review Group (ICRG) for guidance.
Reference:
FATF Recommendation 37 (International Cooperation & MLATs)
U.S. Department of Justice MLAT Procedures
Egmont Group Guidelines on Cross-Border FIU Information Sharing

According to the Anti-Money Laundering Specialist (the 6th edition) study guide, when a financial institution receives a law enforcement request to keep an account open that may be associated with suspicious or criminal activity, it should take the following two steps:
* Maintain account records for at least five years after the request expires. This is to ensure that the financial institution can provide evidence of its compliance with the law enforcement request and the applicable anti-money laundering regulations. The five-year retention period isbased on the international standard set by the Financial Action Task Force (FATF) and adopted by many jurisdictions12.
* Ask for a written request from the law enforcement agency that defines the duration. This is to protect the financial institution from potential liability and to clarify the scope and purpose of the law enforcement request. The written request should specify the time period for which the account should remain open, the reason for the request, the contact information of the law enforcement officer, and the legal authority for the request34.
:
Anti-Money Laundering Specialist (the 6th edition) study guide, page 57 FATF Recommendation 11, paragraph 2 Anti-Money Laundering Specialist (the 6th edition) study guide, page 58 Money Laundering website, article on "Law Enforcement Requests to Keep Accounts Open"
https://www.fincen.gov/resources/statutes-regulations/guidance/requests-law-enforcement-financial- institutions-maintain