1. D. The account received a large cash deposit followed by systematic automated teller machine (ATM) withdrawals until the balance was nominal.
This pattern of behavior, known as "structuring" or "smurfing," is often associated with money laundering.
The large cash deposit followed by smaller withdrawals in a systematic manner raises red flags and requires further investigation.
2. E. The customer conducts multiple cash transactions on a regular basis which do not match the customer's occupation.
Conducting frequent cash transactions that do not align with the customer's stated occupation or income source is suspicious. It suggests potential attempts to hide the true origin of funds or evade reporting requirements1.
D). Large Cash Deposit Followed by ATM Withdrawals:
The large cash deposit followed by systematic ATM withdrawals is indicative of structuring, a common money laundering technique. Structuring involves breaking down large sums of money into smaller transactions to avoid detection. In this case, the customer's behavior warrants further scrutiny to determine the purpose behind these transactions.
E). Inconsistent Cash Transactions:
When a customer conducts multiple cash transactions that do not align with their stated occupation or income source, it raises suspicions. Such behavior may indicate an attempt to obscure the true origin of funds or evade reporting requirements. Investigating the reasons behind these inconsistent cash transactions is essential to assess potential money laundering risks1.
References: 1: Anti-Money Laundering Specialist (6th edition), ACAMS, Chapter 3: "Money Laundering and Terrorist Financing Methods," Section 3.1.2: "Structuring," and Section 3.1.3: "Inconsistent Cash Transactions."

Data sharingbetween financial institutions, FIUs, and law enforcement is essential toAML compliance.
Option A (Correct):Transparent financial systemsdetermoney laundering and terrorist financing.
Option B (Incorrect):FIUsdo not impose sanctions; theycollect and analyze data.
Option C (Incorrect):While data analysis is valuable, thekey goal is financial transparency.
Option D (Incorrect):In many jurisdictions,data sharing is encouraged, withsome restrictions.
Reference:FATF Recommendation 40 (International Cooperation), GDPR and AMLD Regulations, Wolfsberg Group Information Sharing Principles.

The line of business is responsible for creating, implementing and maintaining policies and procedures, as well as communicating these to all personnel. It must also establish processes for screening employees to ensure high ethical and professional standards and deliver appropriate training on AML policies and procedures based on roles and functions performed so employees aware of their responsibilities. To facilitate this, employees should be trained as soon as possible after being hired, with refresher training as appropriate.

According to the Anti-Money Laundering Specialist (the 6th edition) study guide, when a financial institution receives a law enforcement inquiry, it should cooperate as much as possible and respond to all formal requests for information, unless there is a valid objection that can and should be made1. The institution should also file a suspicious transaction report (STR) if the inquiry or the customer's activity triggers any red flags or indicators of money laundering or other financial crimes2. Additionally, the institution should monitor the account for suspicious activity and review the money laundering risk posed by the account, as these are part of the ongoing due diligence and risk assessment processes3. Closing the account immediately is not a recommended action, as it may alert the customer or interfere with the investigation4.
1: ACAMS, CAMS Certification Package - 6th Edition, Chapter 4, page 121
2: ACAMS, CAMS Certification Package - 6th Edition, Chapter 4, page 122
3: ACAMS, CAMS Certification Package - 6th Edition, Chapter 4, page 123
4: ACAMS, CAMS Certification Package - 6th Edition, Chapter 4, page 124

According to the ACAMS CAMS Certification Study Guide (6th edition), the bank's anti-money laundering officer is responsible for overseeing the implementation and maintenance of the bank's anti-money laundering program, which includes reporting and escalating suspicious activities involving PEPs. The anti-money laundering officer should be informed of any unusual or potentially illicit transactions involving PEPs, and decide on the appropriate course of action, such as filing additional reports, conducting enhanced due diligence, or terminating the relationship with the PEP. The other options are not correct because they are either not directly involved in the anti-money laundering program, or not the appropriate authority to contact in this situation.
ACAMS CAMS Certification Study Guide (6th edition), page 77-78. 123456789