* A: The first step in any suspicious activity investigation is to review the transaction history and other relevant account information to establish context, identify patterns, and determine if the behavior is consistent with known typologies of money laundering.
* "The initial phase of an AML investigation is to review relevant account information and transaction activity to assess whether a SAR filing is warranted."
* This approach ensures that any subsequent decisions, such as escalation, SAR filing, or customer outreach, are based on a comprehensive understanding of the facts.
References:
CAMS 6th Edition, Suspicious Activity Monitoring and Investigation
FFIEC BSA/AML Manual, Suspicious Activity Reporting

對於包括政治公眾人物在內的高風險客戶，銀行應該收集足夠的資金和財富來源信息，評估每個客戶的洗錢風險，並確保合規和反洗錢資源與業務增長相適應，以維持有效的系統和控制。

基於場景的系統使用演算法來偵測可疑行為，例如在異常時間發生的交易、超過指定閾值的交易，或發生在與客戶典型活動不一致的地點的交易。這些異常情況有助於識別潛在的金融犯罪風險。

Cryptoassets, such as cryptocurrencies, pose specific ML/TF risks due to their technological characteristics and usage patterns:
* Potential for anonymity (C): Cryptoassets allow users to make transactions without revealing their true identities, which hinders law enforcement from tracking illicit activity. The CAMS 6th Edition states:
"Cryptoassets can be transferred or exchanged between users without the need for identification, presenting a significant risk due to the potential for anonymity."(CAMS 6th Edition, Chapter: Risks and Methods of Money Laundering and Terrorist Financing, Virtual Assets section)
* Global reach (D): Cryptoassets operate on a global scale, enabling rapid cross-border transfers without the limitations of traditional financial systems. This increases the complexity of monitoring and controlling illicit transactions."The global nature of virtual assets makes it easy for criminals to move value across borders quickly, evading jurisdictional controls."(CAMS 6th Edition; FATF Guidance on Virtual Assets 2019)
* Use to layer illicit funds (F): The ability to move cryptoassets between numerous wallets and exchanges allows criminals to obscure the source of funds through layering, a key stage of money laundering.
"Layering can be achieved by rapidly moving cryptoassets between wallets, exchanges, and across different jurisdictions, making tracing more difficult."(CAMS 6th Edition, Chapter: Risks and Methods of Money Laundering and Terrorist Financing) References:
ACAMS Study Guide 6th Edition, Chapter: Risks and Methods of Money Laundering and Terrorist Financing, Virtual Assets/Virtual Currencies FATF Guidance for a Risk-Based Approach to Virtual Assets (2019) EU 5th AML Directive (2018/843)

聯合國安理會有權實施制裁，具體目的是維護或恢復國際和平與安全。