The method of purchasing chips with cash and redeeming them for a check is used to launder money in casinos. This is because the check can be deposited into a bank account or cashed at another location, creating a paper trail that appears to be legitimate. The check can also be used to conceal the source and amount of the cash, as well as the identity of the person who obtained it. This method is also known as "chip washing" or
"chip dumping" and is one of the common ways that money launderers exploit casinos12.
1:
CAMS Certification Package - 6th Edition | ACAMS, Chapter 2: Money Laundering Risks and Methods, p. 32-33 2: FATF Report: Money Laundering through the Physical Transportation of Cash, October 2015, p.
28-29, http://www.fatf-gafi.org/media/fatf/documents/reports/money-laundering-through-transportation-cash.
pdf

Banks must adhere to strictprivacy lawsandSAR confidentiality ruleswhen handling customer information, especially in cross-border investigations.
Option A (Correct):Banks must consider privacy laws such as theUS Bank Secrecy Act (BSA), theEU General Data Protection Regulation (GDPR), and their internal policies before sharing data.
Option B (Correct):Information should beshared only on a need-to-know basis, ensuring compliance withAML regulations and internal procedures.
Option C (Incorrect):While FinCEN provides SAR guidance, banks do not need to seek FinCEN's permission for every internal information request.
Option D (Incorrect):International requests must comply with legal frameworks, but there is no universal requirement for approval by national authorities.
Reference:US Bank Secrecy Act (BSA), FATF Recommendation 40 (International Cooperation), and GDPR Rules on Data Sharing.

When implementing a risk-based approach related to casinos, the risks related to the customer as an individual are mainly based on the customer's profile, behaviour, source of funds, and geographic location. Among the options given, B and D are the most relevant factors that could indicate a higher risk of money laundering or terrorist financing.
Casual customers are those who do not have a regular or established relationship with the casino, and who may visit the casino only once or occasionally. They may not provide sufficient or reliable identification information, or may use false or stolen identities. They may also engage in suspicious transactions, such as large cash purchases of chips, minimal or no gaming activity, or frequent transfers of chips between customers. Casual customers pose a higher risk of money laundering or terrorist financing because they are harder to verify, monitor, and trace by the casino operators.
Customer from a high-risk country is a customer who resides in, or has links to, a country that is subject to sanctions, embargoes, or similar measures, or that is identified by credible sources as having significant levels of corruption, or as being a source, transit, or destination of illicit funds. Such customers pose a higher risk of money laundering or terrorist financing because they may be involved in, or connected to, criminal or terrorist activities, or may be using funds that are derived from or intended for such activities.
= The main reference for this question is the document titled "FATF Guidance on the Risk-Based Approach for Casinos" published by the FATF in October 2008. You can access it by clicking here. You can also find more information about the risk-based approach and the customer risks for casinos on the Gambling Commission website and the Exam Answer website.

TheAML analyst must gather additional informationbefore determining if an alert is suspicious.
Option C (Correct):Requesting information from the relationship managerhelps determineif the transaction is in line with the customer's profile.
Option A (Incorrect):Below-the-line testingis useful forcalibrating AML models, but it doesnot help in real- time case evaluation.
Option B (Incorrect):Directly contacting a counterparty bankmaynot be appropriatewithout internal analysis first.
Option D (Incorrect):Restricting accessis aserious actionthat should only be takenafter a full investigation.
Reference:FATF Recommendation 10 (Customer Due Diligence), Wolfsberg Group Guidance on AML Investigations, FinCEN Transaction Monitoring Guidelines.

Option B is closest to the definition of money laundering provided by the United Nations Convention against Transnational Organized Crime and Other Protocols, which states that money laundering is "the conversion or transfer of property, knowing that such property is the proceeds of crime, for the purpose of concealing or disguising the illicit origin of the property or of helping any person who is involved in the commission of the predicate offence to evade the legal consequences of his or her action". In this scenario, the person is knowingly financing a resort development with the proceeds of arms trafficking, which is a crime, and thus concealing or disguising the illicit origin of the property.
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CAMS Certification Package - 6th Edition | ACAMS1
CAMS Certifications: How to Get CAMS Certified | ACAMS2
ACAMS CAMS Certification Video Training Course - Exam-Labs3
Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)4 United Nations Convention against Transnational Organized Crime and the Protocols Thereto