The most suspicious transaction indicators related to casino activities are:
* A client requests a winnings check (cheque) in a third party's name. This could indicate an attempt to conceal the source or ownership of the funds, or to evade reporting requirements.
* Acquaintances bet against each other in even-money games and it appears they are intentionally losing to one of the parties. This could indicate a scheme to launder money through the casino by transferring funds from one party to another without attracting attention.
* A client requests the transfer of winnings to the bank account of a third party in a country without an effective anti-money laundering regime. This could indicate an attempt to move funds to a high-risk jurisdiction or to a person or entity that is involved in illicit activities.
The option that is not suspicious is:
* A new client who is a large volume player asks the casino operator about the ability to transfer the funds to other locations in the same country. This could be a legitimate inquiry from a high-net-worth individual who travels frequently and wants to access their funds conveniently.
:
ACAMS CAMS Certification Video Training Course - Exam-Labs1
Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)2 ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 8, page 173: https://www.acams.org/wp-content/uploads/2019/08/ACAMS-Study-Guide-6th-Edition-Chapter-8.pdf

The compliance officer should provide a high level summary of the activity and the interactions with law enforcement to the board of directors, as this would be the most appropriate way to escalate the information without compromising the confidentiality of the STR or the ongoing investigation. Providing a copy of the STR or the letter from law enforcement could expose the bank to legal risks or jeopardize the investigation.
Informing the regulator to bring it up with the board would not be sufficient, as the compliance officer has the responsibility to report directly to the board on significant compliance issues.
:
ACAMS CAMS Certification Video Training Course, Module 5: Risk Management, Lesson 5.3: Reporting to Senior Management and the Board1 ACAMS CAMS Certification Study Guide, 6th Edition, Chapter 5: Risk Management, Section 5.3:Reporting to Senior Management and the Board2

According to the Basel guidelines on customer due diligence for banks, a trust is a legal arrangement whereby a person (the settlor or grantor) transfers the legal ownership of specific assets to another person or entity (the trustee) to hold for the benefit of a third person or persons (the beneficiaries)1. The Basel guidelines recommend that banks should identify and verify the identity of the following parties to determine the true nature of the trust relationship:
* The trustee, who is the person or entity that has the legal authority and duty to manage the trust assets and distribute them to the beneficiaries according to the trust deed2. The trustee may also be the settlor, the beneficiary, or both, depending on the type and structure of the trust3.
* The beneficiaries, who are the persons or entities that have a beneficial interest in the trust assets or income, either presently or in the future4. The beneficiaries may be named individuals, classes of persons, or charitable causes.
* The settlor or grantor, who is the person or entity that creates the trust and transfers the legal ownership of the assets to the trustee. The settlor or grantor may also retain some rights or powers over the trust, such as the ability to appoint or remove trustees, beneficiaries, or protectors.
The other three options are incorrect because:
* Respondents are not trust parties, but rather financial institutions that maintain correspondent banking relationships with other financial institutions. Respondents are not relevant for the identification of the trust relationship, but rather for the due diligence of the correspondent banking relationship.
* Payees are not trust parties, but rather persons or entities that receive payments from the trust or other sources. Payees are not relevant for the identification of the trust relationship, but rather for the monitoring of the transactions and activities of the trust.
* Trust administrators are not trust parties, but rather persons or entities that provide administrative services to the trust, such as accounting, record-keeping, or tax compliance. Trust administrators are not relevant for the identification of the trust relationship, but rather for the assessment of the risk and complexity of the trust.
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1: Basel Committee on Banking Supervision, Customer due diligence for banks, October 2001, 4, p. 17 2:
Basel Committee on Banking Supervision, Customer due diligence for banks, October 2001, 4, p. 17 3:
ACAMS, CAMS Study Guide, 6th Edition, Chapter 5,p. 111 4: Basel Committee on Banking Supervision, Customer due diligence for banks, October 2001, 4, p. 17 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 5, p. 111 : Basel Committee on Banking Supervision, Customer due diligence for banks, October
2001, 4, p. 17 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 5, p. 111 : Basel Committee on Banking Supervision, Customer due diligence for banks, October 2001, 4, p. 10 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 5, p. 112 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 5, p. 112

Structuring is the intentional evasion of a reporting or recordkeeping requirement by breaking down a large transaction into smaller ones, or by using multiple accounts, institutions, or persons to avoid triggering the threshold for reporting or recordkeeping. Structuring is also known as smurfing, and it is a common technique used by money launderers to conceal the source, ownership, or control of illicit funds.
ACAMS Study Guide for the CAMS Certification Examination, 6th Edition, Chapter 2, Section 2.1.1, page
511
ACAMS CAMS Certification Video Training Course, Module 2, Lesson 2.1, video time 7:00-8:002 ACAMS CAMS Certification Practice Exam, Question 134, page 2853

TheBoard of Directorsholdsultimate responsibilityforAML/CFT compliance and governance.
Option B (Correct):TheBoardmustoversee, approve, and ensure AML programs are effective.
Option A (Incorrect):TheCOO manages operations, butdoes not hold ultimate accountability.
Option C (Incorrect):While theAML officer executes compliance programs, theBoard provides oversight.
Option D (Incorrect):TheCEO is responsible for strategy, butAML failures fall under Board accountability.
Reference:Basel Committee's Corporate Governance Principles for Banks, FATF Recommendation 1 (Risk- Based Approach), U.S. OCC AML Compliance Guidelines.