"The decision of whether or not to file a suspicious transaction report (also known as a suspicious activity report or SAR in the United States) often involves weighing the aggravating and mitigating factors arising from the research conducted during the investigative process. Financial institutions should draft procedures that document the factors to consider when determining whether a suspicious transaction report (STR) is appropriate."

Terrorist financing (TF) differs from traditional money laundering, as funds can originate fromlegitimate sources(e.g., donations, charities) and often involvelow-value transactions.
Option A (Correct):Non-profits with no online presencecan beshell organizations used to finance terrorism.
Option C (Correct):Small-dollar payments to high-risk jurisdictions(e.g., FATF-listed countries)may indicate terrorist funding activity.
Why Other Options Are Incorrect:
Option B (Incorrect):Crowdfunding payments with transparency and project detailsare generallylow-risk.
Option D (Incorrect):Charities helping refugeesmay behigh-risk but not automatically suspicious.
Option E (Incorrect):Structuring below reporting thresholds is more indicative of money laundering than terrorist financing.
Red Flags for Terrorist Financing:
Frequent low-value transactions to conflict zones.
Use of charities and non-profits as fronts for terror groups.
Funds moving through unregulated crowdfunding platforms.
Best Practices for Detecting Terrorist Financing:
Identify transactions involving known terrorist financing typologies.
Enhance monitoring of non-profit organizations operating in high-risk regions.
Use negative news screening to detect links to sanctioned entities.
Reference:
FATF Recommendation 8 (Non-Profit Organizations & Terrorist Financing)
FinCEN Guidelines on Terrorist Financing Risk Indicators
EU 6th AML Directive (6AMLD) on Terrorism Financing Controls

An anti-money laundering officer should coordinate with human resources when implementing a new hire screening program, because human resources is responsible for managing the recruitment, hiring, and training of employees, as well as ensuring compliance with labor laws and regulations. A new hire screening program is a key component of an effective anti-money laundering (AML) program, as it helps to prevent the hiring of individuals who may pose a risk of facilitating money laundering, terrorist financing, or other financial crimes, or who may have a criminal or disciplinary history that could compromise the integrity of the institution. A new hire screening program should include background checks, verification of credentials and references, and assessment of skills and competencies relevant to the AML function. An anti-money laundering officer should work closely with human resources to establish the criteria, procedures, and documentation for the screening program, as well as to monitor its implementation and effectiveness.
ACAMS CAMS Certification Video Training Course1, Module 4: Developing an AML Program, Lesson 4.2:
Developing an AML Program
ACAMS CAMS Study Guide, 6th Edition2, Chapter 4: Developing an AML Program, Section 4.2:
Developing an AML Program, pp. 81-82
ACAMS CAMS Examination Preparation Seminar, 6th Edition3, Chapter 4: Developing an AML Program, Section 4.2: Developing an AML Program, Slide 20

Conducting small cash transactions at multiple locations during the same day is the strongest example of avoiding reporting thresholds. This is a common technique used by money launderers to evade the attention of financial institutions and regulators, who are required to report cash transactions above a certain amount (usually $10,000) to the authorities. By splitting the large sum of money into smaller amounts and depositing them at different branches or ATMs, the money launderer can avoid triggering the reporting requirement and conceal the source and destination of the funds. This practice is also known as smurfing or structuring12.
ACAMS CAMS Certification Study Guide, 6th Edition, Chapter 2, page 36
ACAMS CAMS Certification Video Training Course, Module 2, Lesson 2.2, Structuring and Smurfing
1, Smurfing Money Laundering: Mechanics, Detection, and Prevention
2, AML & eWallets - The Risks & How To Comply | ComplyAdvantage

When investigating unusual transactions, financial institutions must focus on data-driven risk assessment and internal review first.
* Option A (Correct):Assessing business ownership and control structureshelps determine ifmultiple businesses are connected through hidden links(e.g., shell companies or common ownership).
* Option C (Correct):The account managermay provide valuable insight on whether the customer's activity aligns with their expected profile.
* Option B (Incorrect):Law enforcement should only be contacted after internal review confirms suspicious activity.
* Option D (Incorrect):Declining transactions without thorough investigationcould lead tomissed SAR filingsor improper risk assessment.
* Option E (Incorrect):Social media is not a reliable investigative toolfor AML casework.
Key Red Flags in Business AML Investigations:
* Frequent transactions between businesses with no clear commercial relationship.
* Ownership structures that obscure beneficial owners.
* Rapid movement of funds through multiple accounts without economic justification.
Best Practices for Investigating Complex Cases:
* Verify ownership and control through official company registries.
* Conduct negative news screening and PEP/sanctions screening.
* Request supporting documentation from the customer.
Reference:
FATF Recommendation 10 (Customer Due Diligence)
Wolfsberg Group Guidance on Transaction Monitoring and Investigations
FinCEN Red Flags for Business Money Laundering Investigations