Gatekeepers (e.g., accountants, auditors, lawyers) play a critical role in detecting financial crime.
* Option B (Correct):Corporate clientsposehigher money laundering risksdue tocomplex ownership structures and cross-border financial activities.
* Option C (Correct):The nature of requested services(e.g.,offshore structuring, large cash transactions) can indicate potentialmoney laundering attempts.
Why Other Options Are Incorrect:
* Option A (Incorrect):The length of time a client has been with an accounting firm does not necessarily indicate financial crime risk.
* Option D (Incorrect):Short-term relationships may be high-risk, but understanding the business type and services requested is more critical.
Red Flags for Money Laundering in Professional Services:
* Clients requesting offshore structures for no apparent business reason.
* Use of complex trusts or nominee directors to obscure ownership.
* Unexplained large transactions moving through legal or accounting firms.
Best Practices for Gatekeepers to Prevent Money Laundering:
* Perform Enhanced Due Diligence (EDD) on high-risk clients.
* Report unusual financial activity to FIUs.
* Follow FATF's DNFBP (Designated Non-Financial Businesses and Professions) AML guidelines.
Reference:
FATF Recommendation 22 (AML Compliance for Accountants and Lawyers)
Wolfsberg Group Guidance on DNFBP AML Risks
EU 6th AML Directive (6AMLD) on DNFBP Risk Management
Final Thoughts:
FIUs play a central role in financial intelligence collection and sharing.
The Egmont Group enables cross-border AML cooperation among FIUs.
Gatekeepers, such as accountants and lawyers, must monitor corporate clients for money laundering risks.

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)

The correct answer is C. Wires received in large, even dollar amounts are a suspicious behavior, as they may indicate an attempt to avoid reporting thresholds or to conceal the source of funds. Large and round numbers are often used by money launderers to simplify calculations or to avoid arousing suspicion12. The other options are not necessarily suspicious, as they may reflect the normal business operations of a wholesale auto business that ships vehicles internationally. The dock shipping receipts match the vehicles (A), vehicles are regularly shipped internationally (B), and account debits are payable to transport companies (D) are all plausible and legitimate activities for such a business.
ACAMS CAMS Certification Video Training Course3, Module 3: Risks and Methods of Money Laundering and Terrorism Financing, Lesson 2: Methods of Money Laundering ACAMS CAMS Certification Study Guide1, Chapter 3: Risks and Methods of Money Laundering and Terrorism Financing, Section 3.2: Methods of Money Laundering, pp. 79-80

The USA PATRIOT Act, enacted in 2001, is a comprehensive legislation that aims to enhance the US government's ability to combat terrorism, money laundering, and other criminal activities. One of the aspects of the Act that has extraterritorial reach is the requirement for US financial institutions (FIs) to apply certain due diligence and reporting obligations to their correspondent accounts and private banking accounts for foreign FIs and non-US persons, respectively12. These obligations are intended to prevent foreign FIs and individuals from using the US financial system to facilitate money laundering, terrorist financing, or other illicit activities. The Act also authorizes the Secretary of the Treasury to impose special measures, such as recordkeeping, reporting, or prohibitions, on certain foreign jurisdictions, FIs, or transactions that are found to be of primary money laundering concern34. These special measures can have significant impact on the access and operations of foreign FIs and persons in the US financial market.
1: USA PATRIOT Act, Title III, Subtitle A, Section 3121
2: 31 CFR 1010.610 - Due diligence programs for correspondent accounts for foreign financial institutions2
3: USA PATRIOT Act, Title III, Subtitle A, Section 3113
4: 31 CFR 1010.651 - Imposition of special measure against foreign jurisdictions, foreign financial institutions, classes of international transactions, or types of accounts of primary money laundering concern4 Reference: https://www.fincen.gov/resources/statutes-regulations/usa-patriot-act

Concentration accounts are internal accounts used by financial institutions to aggregate funds from or for various clients or other accounts. They are also known as omnibus accounts or suspense accounts. The use of concentration accounts may obscure the audit trail and the identity of the clients involved in the transactions. Therefore, the Wolfsberg Principles on Private Banking, which are a set of voluntary guidelines for preventing money laundering and terrorist financing in the private banking sector, prohibit the use of concentration accounts in a way that would prevent appropriate monitoring or identification of the clients or their funds12.
1: Wolfsberg Anti-Money Laundering Principles for Private Banking (2012), Section 4.3 2: The Wolfsberg Principles - an analysis, Journal of Money Laundering Control, Vol. 7 No. 3, 2004, pp. 237-240 Reference:http://www.wolfsberg-principles.com/privat-banking.html(1.2.2,
5th bullet)