Company ownership is held in bearer share form. Bearer share ownership can make it difficult to identify the actual owners of a company and is therefore considered a high risk for money laundering or terrorist financing. Enhanced due diligence measures may include obtaining additional identification and ownership information, conducting more frequent reviews of the account, and monitoring transactions more closely.
Reference: Certified Anti-Money Laundering Specialist (the 6th edition) Study Guide, Chapter 6, "Customer Due Diligence (CDD) and Know Your Customer (KYC)", page 115.

A domestic business account receiving a wire transfer from an international business with no history of such activity or business needs should be escalated as potentially suspicious activity. This is because this scenario may indicate an attempt to launder money, evade taxes, or finance terrorism through cross-border transfers that have no apparent economic or lawful purpose. The lack of prior relationship or business justification for the wire transfer may also suggest that the transaction is not consistent with the customer's profile or expected activity. Therefore, this scenario should be investigated further and reported if necessary.
9 Financial & Bank Suspicious Activity Examples, Example 2.
CAMS Study Guide 6th Edition, page 40-41.
Reference: https://www.utica.edu/academic/institutes/ecii/conferences/Conducting%20a%20Money%
20Laundering%20Investigation%20-%20C%20King.pptx

Casinos arehigh-riskformoney launderingdue to theircash-intensive natureandease of moving funds anonymously.
* Option A (Correct):Aprivate company sending funds into multiple patron accountsissuspiciousbecause it may indicatemoney laundering structuringor use ofmules.
* Option B (Incorrect):Betting on multiple events isnormal behaviorunless there isevidence of match- fixing.
* Option C (Incorrect):Large cash buy-ins are common in casinos; however, they become suspicious when coupled withother red flags(e.g., no actual gambling).
* Option D (Incorrect):Transferring winnings may be aregular transactionunless linked tostructured transactions.
Reference:FATF Report on Money Laundering in Casinos (2022), FATF Recommendation 22 (DNFBPs), FinCEN Casino AML Guidance.

Institutions that violate anti-money laundering laws may face various risks and consequences, such as legal, regulatory, reputational, and operational risks. As demonstrated by the 2012 HSBC settlement with United States authorities, two of the most significant risks are:
Forfeiture of assets. This means that the institution may have to surrender some or all of its assets that are related to the money laundering activities or violations. For example, HSBC agreed to forfeit $1.256 billion as part of its deferred prosecution agreement with the US Department of Justice1.
Civil money penalties. This means that the institution may have to pay fines or penalties to the government or other regulatory agencies for violating the anti-money laundering laws or regulations. For example, HSBC agreed to pay $665 million in civil money penalties to various US regulators, including the Office of Foreign Assets Control, the Federal Reserve Board, and the Office of the Comptroller of the Currency1.
The other two options, C and D, are not as common or relevant to the 2012 HSBC settlement. Loss of bank charter/license may occur in extreme cases where the institution is deemed unfit to operate or poses a serious threat to the financial system. Imprisonment of bank employees may occur if the employees are found guilty of criminal charges, such as fraud, conspiracy, or wilful violation of anti-money laundering laws. However, these outcomes are usually reserved for individuals, not institutions, and depend on the specific facts and circumstances of each case.
1: HSBC announces settlements with authorities, 2012, https://www.hsbc.com/-/files/hsbc/investors/stock- exchange-announcements/2012/december/2012-12-11-hsbc-announces-settlements-with-authorities.pdf
2: Settlement Agreement between the U.S. Department of the Treasury's Office of Foreign Assets Control and HSBC Holdings plc, 2012, https://ofac.treasury.gov/recent-actions/20121211_33
3: HSBC settles on record US fee, 2012, https://www.dw.com/en/hsbc-settles-in-us-money-laundering-probe
/a-16443391
4: HSBC pays record $1.9bn fine to settle US money-laundering accusations, 2012, https://www.theguardian.
com/business/2012/dec/11/hsbc-bank-us-money-laundering
5: HSBC to pay $1.9bn in US money laundering penalties, 2012, https://www.bbc.com/news/business-
20673466

Section 319(b) of the USA PATRIOT Act authorizes the U.S. government to subpoena records from any foreign bank that maintains a correspondent account in the U.S., regardless of whether the foreign bank has a physical presence in the U.S. or not. The subpoena may request any records relating to the correspondent account or any account at the foreign bank, including records maintained outside the U.S. If the foreign bank fails to comply with the subpoena, the U.S. government may direct any U.S. financial institution to terminate its correspondent relationship with the foreign bank and impose civil penalties.
References:
Bank Records Related to Anti-Money Laundering Programs, FinCEN, accessed February 2024.
How Patriot Act Affects Financial Institutions?, Sanction Scanner, November 2020.