The Patriot Act, enacted in 2001, introduced several provisions to enhance the anti-money laundering and counter-terrorist financing (AML/CFT) measures for U.S. banks and their foreign correspondent relationships.
Some of the potential issues for foreign financial institutions (FFIs) maintaining correspondent accounts with U).S. banks under the Patriot Act are:
Cancellation of correspondent banking relationships: The Patriot Act requires U.S. banks to conduct due diligence and enhanced due diligence on their foreign correspondent accounts, and to terminate any account that poses a significant risk of money laundering or terrorist financing. This may result in the cancellation of correspondent banking relationships with FFIs that do not meet the U.S. standards or cooperate with the U.S.
authorities. The loss of correspondent banking relationships may affect the FFIs' ability to access the U.S.
financial system and provide services to their customers.
Forfeiture of funds in a U.S. interbank account: The Patriot Act authorizes the U.S. government to seize and forfeit any funds in a U.S. interbank account that are involved in or traceable to money laundering or terrorist financing activities. This means that FFIs may face the riskof losing their funds in a U.S. interbank account if they or their customers are suspected or accused of engaging in illicit activities. The forfeiture of funds may have significant financial and reputational consequences for the FFIs and their customers.
Prohibition of correspondent accounts for shell banks: The Patriot Act prohibits U.S. banks from establishing or maintaining correspondent accounts for shell banks, which are banks that have no physical presence in any country and are not affiliated with a regulated financial group. This means that FFIs that are shell banks or have relationships with shell banks cannot access the U.S. financial system through correspondent accounts.
The prohibition of correspondent accounts for shell banks aims to prevent the use of shell banks as vehicles for money laundering and terrorist financing.
CAMS Study Guide, 6th Edition, Chapter 4: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), pp. 81-841 USA PATRIOT Act, Title III: International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001, Sections 312, 319, and 3132 Wolfsberg Anti-Money Laundering Principles for Correspondent Banking, October 2014, pp. 3-43 Reference:http://www.ffiec.gov/bsa_aml_infobase/pages_manual/olm_027.htm

The anti-money laundering officer should advise the bank that compliance should have been involved during product development to perform a risk assessment of the product. This is because stored-value cards are considered high-risk products for money laundering and terrorist financing, as they can be used to store, transfer, or access funds anonymously, across borders, or through third parties. A risk assessment would help the bank identify and mitigate the potential vulnerabilities and threats associated with the product, such as customer due diligence, transaction monitoring, record keeping, reporting, and training. A risk assessment would also help the bank comply with the regulatory requirements and expectations for offering such products, as well as the industry best practices and standards.
ACAMS CAMS Certification Study Guide, 6th Edition, Chapter 5, Section 5.3.2, p. 140-1411 ACAMS CAMS Certification Exam Outline, 6th Edition, Domain 1, Task 1.1, p. 42 FATF Guidance on the Risk-Based Approach for Prepaid Cards, Mobile Payments and Internet-Based Payment Services, June 2013, p. 9-103

Enhanced due diligence (EDD) is a higher level of customer due diligence that is required for customers or accounts that pose a higher risk of money laundering or terrorist financing. According to the FATF Recommendations, EDD measures may include obtaining additional information on the customer, the beneficial owner, the intended nature and purpose of the business relationship, the source and destination of funds, and the reasons for transactions. EDD is also required for customers or accounts that are from or in countries that do not have adequate AML/CFT systems or are subject to sanctions or embargoes.
Among the four categories of customers or accounts listed in the question, lawyers, foreign exchange dealers, and precious metal dealers are considered as high-risk by the FATF and other international standards, and therefore require EDD. Lawyers may be involved in transactions that conceal the origin or ownership of illicit funds, such as creating shell companies, trusts, or foundations. Foreign exchange dealers may facilitate the movement of illicit funds across borders or jurisdictions, or provide anonymous or pseudonymous services.
Precious metal dealers may deal with high-value goods that are easily convertible into cash, or may be used to launder proceeds of crime or evade sanctions.
Retail account holders, on the other hand, are generally considered as low-risk customers or accounts, unless they exhibit unusual or suspicious behavior or transactions. Therefore, they do not require EDD by default, but only when there are specific indicators of higher risk.
[ACAMS Study Guide for the CAMS Certification Examination, 6th Edition], Chapter 3: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), pp. 75-76,
79-80.
FATF Guidance on Correspondent Banking Services, October 2016, pp. 7-8, 12-13.
Customer Due Diligence - Overview, Federal Financial Institutions Examination Council, April 2018, pp. 1-2,
5-6.
Customer due diligence, The Law Society, accessed on February 9, 2024.
Anti-Money Laundering (AML) Source Tool for Broker-Dealers, U.S. Securities and Exchange Commission, May 16, 2022, pp. 1-2, 5-6.

One of the methods that FATF-style regional bodies (FSRBs) use to understand the inherent money laundering and terrorist financing risks in their regions is to conduct regional-level research and analysis of the methods and trends used by criminals and terrorists to exploit the vulnerabilities of the financial system.
This research and analysis is done using the standards and templates developed by the FATF for its typologies reports, which are documents that describe the common features, techniques, and patterns of money laundering and terrorist financing activities. By producing their own typologies reports, FSRBs can identify the specific risks and challenges faced by their member countries and jurisdictions, and provide guidance and recommendations on how to mitigate them.
What are the 9 FATF-Style Regional Bodies (FSRBs)? - Sygna, What are FATF and FSRB typologies?
FATF-Style Regional Bodies (FSRBs) - Asia/Pacific Group on Money Laundering, What are the main duties of FSRBs?
Financial Action Task Force - Wikipedia, Typologies.
Reference:https://www.fatf-gafi.org/media/fatf/documents/recommendations/Private-Sector-Information- Sharing.pdf(18)

According to the ACAMS CAMS Certification Study Guide (6th edition), one of the red flags for money laundering is the structuring of cash transactions to avoid reporting thresholds. Structuring is the practice of breaking down large amounts of cash into smaller deposits or withdrawals that are below the reporting threshold of $10,000 in the United States or equivalent amounts in other jurisdictions. Structuring is done to evadethe detection and reporting of cash transactions by financial institutions to the authorities. Therefore, when an accountable institution identifies that a customer is engaging in structuring or other forms of cash transaction manipulation, it should file a SAR/STR to report the suspicious activity1
1: ACAMS CAMS Certification Study Guide (6th edition), page 64.
Reference: https://www.fdic.gov/regulations/examinations/supervisory/insights/siwin07/article03_connecting.
html