The customer activity that poses the highest risk of money laundering is making multiple cash deposits slightly below a required reporting limit. This could indicate a practice known as structuring or smurfing, which is a method of breaking down large amounts of cash into smaller transactions to avoid detection or reporting by financial institutions12. Structuring is a common technique used by money launderers to conceal the source, ownership, or destination of illicit funds3.
The other options are not necessarily indicative of money laundering, although they may require further due diligence or monitoring depending on the customer profile and the nature of the transaction. For example:
* Transferring funds to pay for flight training lessons could be a legitimate educational expense, or it could be related to terrorist financing or other criminal activities. The financial institution should verify the identity and background of the customer and the recipient, and check for any red flags or suspicious indicators4.
* Paying a supplier of precious metals at regular quarterly intervals could be a normal business practice, or it could be a way of moving or storing value in an alternative asset class. The financial institution should assess the customer's source of funds, business rationale, and market conditions, and monitor for any changes or inconsistencies.
* Conducting business in a country that represents a high risk of money laundering could be a legitimate commercial opportunity, or it could be a sign of involvement in illicit activities or tax evasion. The financial institution should apply enhanced due diligence measures, such asverifying the identity and reputation of the customer and the counterparties, obtaining information on the purpose and nature of the business relationship, and screening for any sanctions or adverse media.
:
ACAMS CAMS Certification Video Training Course - Exam-Labs3
Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)4 ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 2, page 29: https://www.acams.
org/wp-content/uploads/2019/08/ACAMS-Study-Guide-6th-Edition-Chapter-2.pdf ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 6, page 121: https://www.acams.
org/wp-content/uploads/2019/08/ACAMS-Study-Guide-6th-Edition-Chapter-6.pdf ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 7, page 139: https://www.acams.
org/wp-content/uploads/2019/08/ACAMS-Study-Guide-6th-Edition-Chapter-7.pdf ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 4, page 77: https://www.acams.
org/wp-content/uploads/2019/08/ACAMS-Study-Guide-6th-Edition-Chapter-4.pdf

As part of its enforcement efforts, OFAC publishes a list of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not country-specific. Collectively, such individuals and companies are called "Specially Designated Nationals" or "SDNs." Their assets are blocked and U.S. persons are generally prohibited from dealing with them. So it's covering all

Casinos and gambling institutions are highly vulnerable to money laundering because they allow the conversion of cash into chips, checks, or electronic credits, which can later be redeemed as "clean" funds.
Option A (Correct): A privately held company funding multiple patrons' betting accounts is highly suspicious and may indicate:
Structuring/smurfing, where multiple individuals are used to move illicit funds.
Third-party money laundering, where the real source of funds is obscured.
Trade-based money laundering, if linked to non-gaming businesses.
Why Other Options Are Incorrect:
Option B (Incorrect): Placing multiple bets on the same event is not inherently suspicious unless linked to fraudulent betting patterns.
Option C (Incorrect): Large chip purchases in cash may require reporting, but they do not necessarily indicate money laundering.
Option D (Incorrect): Transferring winnings to another operator may be unusual, but not automatically suspicious unless the amount is large and unjustified.
Common Money Laundering Techniques in Casinos:
Chip Walking - Buying chips with illicit funds and cashing them out later as "clean" funds.
Casino Account Transfers - Using multiple accounts or third-party accounts to move funds.
High-Value Gambling with No Loss Intent - Betting on both sides of an event to ensure clean withdrawal of funds.
Best Practices for Casino AML Compliance:
Monitor suspicious large transactions and third-party funding activities.
Perform enhanced due diligence (EDD) on high-risk patrons.
File Suspicious Transaction Reports (STRs) for unusual gambling activity.
Reference:
FATF Report on Money Laundering in Casinos
6th EU AML Directive (6AMLD) on Gaming & Gambling AML Risks
FinCEN Guidance on Casino AML Compliance

Transaction monitoring alerts requirefurther analysisto determine whether they indicategenuine suspicious activity or a false positive.
* Option C (Correct):Requesting information from the relationship manager helps gather customer background details, past transaction patterns, and business rationale.
* Option A (Incorrect):Below-the-line testing assesses system effectiveness but does not resolve an immediate AML alert.
* Option B (Incorrect):Directly contacting a counterparty bank may violate privacy regulations and should only be done if escalation is required.
* Option D (Incorrect):Restricting access without due diligence may lead to regulatory and reputational risks.
Best Practices for Investigating AML Alerts:
* Review transaction history and customer risk profile.
* Engage the relationship manager for business context.
* Escalate to AML compliance teams if red flags persist.
Reference:
FATF Recommendation 10 (Customer Due Diligence & Monitoring)
Wolfsberg Group Guidance on Transaction Monitoring & Alert Handling
6th EU AML Directive (6AMLD) on Suspicious Transaction Investigations

Financial institutions must screen customers against adverse information and determine whether they pose a significant financial crime risk.
* Option B (Correct):A direct link to an organized crime group is a severe red flag. Organized crime networks engage in money laundering, corruption, and other illicit activities. UnderFATF Recommendations 10 and 12, financial institutions must implement enhanced due diligence (EDD) for high-risk customers and consider account closure if they pose undue risk.
* Option A (Incorrect):Bankruptcy does not necessarily indicate financial crime risk, though it may raise financial stability concerns.
* Option C (Incorrect):While PEPs pose a higher risk for corruption, financial institutions typically apply EDD rather than immediately terminating the relationship.
* Option D (Incorrect):Violating a construction permit is a regulatory issue, not directly linked to financial crime.
Reference:FATF Recommendation 10 (Customer Due Diligence); FATF Recommendation 12 (PEPs); Wolfsberg Principles on Risk-Based Due Diligence.