These options involve transferring funds to another country, which could indicate cross-border movement of illicit funds, and cashing out winnings in checks under 10,000 USD, which could indicate structuring to avoid reporting thresholds. The other options do not seem as suspicious or relevant to money laundering.

According to the Anti-Money Laundering Specialist (the 6th edition) study guide, structuring is a technique used by money launderers to avoid triggering currency transaction reporting requirements by breaking down large amounts of cash into smaller deposits that are below the reporting threshold1. Structuring can also involve withdrawing cash in small amounts from different locations or branches to evade detection and scrutiny2. Therefore, the compliance analyst is potentially identifying structuring as the type of money laundering in this case.
References:
1: CAMS Study Guide, 6th Edition, Chapter 1, Section 1.3, page 14
2: CAMS Study Guide, 6th Edition, Chapter 1, Section 1.4, page 15

Businessesmust not engage with entities in sanctioned jurisdictionswithout proper licensing.
* Option D (Correct):Providing services to sanctioned areasexposes an organization toOFAC or EU penalties.
* Option A (Incorrect):Personal historydoes not necessarily indicateAML risk.
* Option B (Incorrect):Lack of individual ownership above 10%does not inherently indicate risk.
* Option C (Incorrect):Private ownership alonedoes not pose an AML concern.
Reference:OFAC Sanctions Compliance, EU Sanctions Regulations, Wolfsberg Group Vendor Risk Management Guidance.

According to the Anti-Money Laundering Specialist (the 6th edition) resources, the situation that is the highest risk for money laundering and terrorist financing activity is A. A customer purchases casino chips, using small denomination bank notes, but does not engage in game play before redeeming the chips for a casino check. This is because this situation may indicate some red flags of money laundering, such as:
* Using small denomination bank notes, which may be an attempt to avoid detection or reporting by the casino or the authorities, as large amounts of cash are usually associated with criminal activity1.
* Not engaging in game play, which may indicate a lack of interest in gambling and a sole purpose of exchanging cash for a casino check, which is a more legitimate and less traceable form of payment2.
* Redeeming the chips for a casino check, which may be a way of laundering the cash through the casino, as the check can be deposited into a bank account or cashed at another location, without revealing the source of the funds3.
The other three options are less risky because:
* B. A customer purchases casino chips and engages in significant game play before requesting a casino check for the remainder is less risky, as it may indicate a genuine interest in gambling and a legitimate source of funds. However, this situation may still require further investigation and verification, as some money launderers may use gambling as a cover for their illicit activities, or may use the casino check as a way of transferring funds to another jurisdiction or person4.
* C. A customer purchases casino chips using a credit card and engages in minimal game play before redeeming the chips for a casino check is less risky, as it may indicate a low level of funds involved and a traceable source of funds. However, this situation may still require further investigation and verification, as some money launderers may use credit cards to obtain cash advances from the casino, or may use the casino check as a way of repaying their credit card debt or transferring funds to another jurisdiction or person.
* D. A customer purchases casino chips using credit from an account at an affiliated casino and engages in significant game play before redeeming the chips for a casino check is less risky, as it may indicate a regular and loyal customer of the casino and a legitimate source of funds. However, this situation may still require further investigation and verification, as some money launderers may use credit from an affiliated casino to avoid carrying cash or using credit cards, or may use the casino check as a way of transferring funds to another jurisdiction or person.
:
1: ACAMS, CAMS Study Guide, 6th Edition, Chapter 5, p. 106 2: ACAMS, CAMS Study Guide, 6th Edition, Chapter 5, p. 110 3: ACAMS, CAMS Study Guide, 6th Edition, Chapter 5, p. 110 4: ACAMS, CAMS Study Guide, 6th Edition, Chapter 5, p. 110 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 5, p.
110 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 5, p. 110

When reviewing business operations of a Money Services Business (MSB), it is critical to identify behaviors that indicate potential money laundering activity. TheCAMS Study Guide - 6th Editionoutlines severalred flagscommonly associated with MSBs.
Option Ais correct:
A customer beinghesitant to provide beneficiary information, such as the name or address, is a red flag. It may indicate attempts to hide the true purpose or recipient of the funds and could suggeststructuring or layering activity.
Option Dis correct:
A customer usingmultiple accounts under different namesto conduct transactions is a strong red flag. This could indicate efforts toobscure ownership, avoid detection, or conductsuspicious structuringbehavior to stay below reporting thresholds.
Option Bis incorrect:
While large cash deposits from cash-intensive businesses may require further review, they are not inherently suspicious unlessinconsistent with the nature of the business or transaction volume.
Option Cis incorrect:
Currency exchanges under the reporting threshold, even from high-risk jurisdictions, are not in themselves red flags unless they show a pattern ofstructuringor are part oflarger suspicious behavior.
Option Eis incorrect:
Frequent small-dollar transfers to a native country may benormal remittance behaviorand only become suspicious if tied to additional indicators such asstructuring or third-party involvement.
Reference: ACAMS CAMS Study Guide - 6th Edition, Chapter:Recognizing and Reporting Suspicious Activity- Section:Red Flags for Money Services Businesses