An institution should focus on the appropriateness of having a centralized review of suspicious transactions and recommendations to file an STR to ensure consistency. This is because a centralized review process can help to avoid duplication, inconsistency, or omission of STRs, as well as to ensure compliance with regulatory requirements and internal policies. A centralized review process can also facilitate the analysis of trends, patterns, and typologies of suspicious transactions across the institution, and enable the communication and coordination with relevant stakeholders, such as law enforcement, regulators, or other financial institutions.
ACAMS Study Guide for the CAMS Certification Examination, 6th Edition, Chapter 5, Section 5.3.1, page
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ACAMS CAMS Certification Video Training Course, Module 5, Lesson 5.3, video time 2:30-4:002 ACAMS CAMS Certification Practice Exam, Question 124, page 2843

the Office of Foreign Assets Control (OFAC) has the authority to prohibit or reject any trade or financial transactions involving specified countries, entities, and individuals that are subject to U.S. economic sanctions, unless such transactions are authorized by a general or specific license issued by OFAC. This applies to transactions that occur within the U.S. territory, as well as transactions that involve U.S. persons, U.
S. goods, or the U.S. financial system, regardless of where they take place. This is one of the key aspects of OFAC's extraterritorial reach, which means that OFAC can enforce its sanctions programs beyond the U.S.
borders.
:
Home | Office of Foreign Assets Control, section "Mission": "The Office of Foreign Assets Control ("OFAC") of the US Department of the Treasury administers and enforces economic and trade sanctions based on US foreign policy and national security goals against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the United States." The Aggressive Extraterritorial Reach of U.S. Economic Sanctions: Foreign Company Exposure to OFAC Enforcement, section "A. Bases for OFAC jurisdiction over foreign parties", paragraph 1: "One key aspect of the Office of Foreign Assets Control's extraterritorial reach includes the blocking of certain non-United States initiated transactions for or through the United States (U.S.) for benefit of a restricted person or entity." The global reach of OFAC sanctions, section "The global reach of OFAC sanctions", paragraph 1: "OFAC sanctions are trade and economic sanctions administered by The U.S. Treasury Department'sOffice of Foreign Asset Control (OFAC). They are often intended to have extra-territorial effect, meaning that they apply outside the U.S. territory. In some instances a connection with the U.S. territory is required."
"Prohibit or reject unlicensed trade and financial transactions with specified countries, entities, and individuals. "

Structuring is a technique used in the placement stage of money laundering, in which the launderer deposits or withdraws cash in amounts below the reporting threshold to avoid detection or suspicion. Structuring is also known as smurfing, because it involves using multiple individuals or locations to carry out the transactions. Structuring is illegal in many jurisdictions and is a red flag for money laundering12.
Option A is not an example of structuring, but of using an alternative remittance system, which is a method of transferring money outside the formal financial sector. Hawala is a type of alternative remittance system that relies on a network of brokers who settle the transactions through trust and honor. Hawala can be used for legitimate purposes, but also poses a risk for money laundering and terrorist financing13.
Option B is not an example of structuring, but of a large cash transaction, which is a common indicator of money laundering. Large cash transactions may involve the proceeds of crime or the attempt to evade taxes or currency controls. Financial institutions are required to report large cash transactions above a certain threshold to the relevant authorities14.
Option D is not an example of structuring, but of a wire transfer, which is a method of moving funds electronically from one account to another. Wire transfers can be used for legitimate purposes, but also pose a risk for money laundering and terrorist financing, especially if they involve high-risk jurisdictions, shell companies, or complex chains of transactions1 .
References: 1: ACAMS (2020), Study Guide for the Certification Examination, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams-certification-package-6th-edition, pp. 12-14, 18-19, 22-23, 26-27. 2:
ACAMS (2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.
acams.org/en/cams-certification-package-6th-edition, Module 1, Section 1.2.2. 3: ACAMS (2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams- certification-package-6th-edition, Module 1, Section 1.2.3. 4: ACAMS (2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams-certification-package-
6th-edition, Module 1, Section 1.2.1. : ACAMS (2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams-certification-package-6th-edition, Module 1, Section
1.2.4.

According to the ACAMS study guide, one of the red flags for money laundering in loan transactions is "the use of shell companies or other legal entities whose ownership is not transparent or whose beneficial owners are unknown" (p. 223). Money launderers may use such entities to hide their identity and the source of their funds, or to create complex layers of transactions to obscure the trail of money. The other options are not necessarily indicative of money laundering risk, as they could be explained by legitimate factors such as the location of the property, the repayment schedule, or the choice of attorney.
:
ACAMS. (2020). Study Guide for the Certification Examination for Anti-Money Laundering Specialists (6th ed.). Miami, FL: ACAMS.
MLO Mentor: Anti-Money Laundering 1
Compliance Obligations of Certain Loan or Finance Company Affiliates of Federally Regulated Banks and Other Financial Institutions 2

Lawyers and legal professionalsare frequently used inmoney laundering schemes, particularly throughtrust accountsthat offeranonymity and client privilege protections.
Option A (Correct):Repeated wire transfers from unknown sources followed by immediate outward transferssuggest that the lawyer's trust accountis being used as a pass-through account for laundering funds.
Option B (Incorrect):If legal services were actually rendered,this is a normal transactionunless other risk factors exist.
Option C (Incorrect):Receiving funds from aregulated insurance companyisnot inherently suspicious, unless the transaction isinconsistent with the lawyer's usual business activity.
Option D (Incorrect):Large transactions are normal inreal estate purchases, as long as proper documentation exists.
Red Flags in Legal Sector Money Laundering:
Use of lawyer trust accounts to move funds with no legitimate business purpose.
Frequent transactions from high-risk jurisdictions.
Transactions that are inconsistent with the lawyer's area of practice.
Clients who refuse to disclose the source of funds.
Best Practices:
Apply AML measures to law firmshandling financial transactions, as required by FATF'sDesignated Non- Financial Businesses and Professions (DNFBPs)guidelines.
Require enhanced due diligence (EDD) for high-risk clientsandunusual transactions.
Reference:
FATF Report on Legal Professionals & Money Laundering
Wolfsberg Group Legal Sector AML Guidance
6th EU Anti-Money Laundering Directive (6AMLD) on DNFBPs