* A: The purchase of high-value real estate using cash in multiple transactions-especially without clear economic justification-is a classic money laundering typology. The goal is typically to integrate illicit funds into the legitimate economy and obscure their origin.
* "Large cash purchases of property without an obvious economic rationale are a significant red flag for money laundering in the real estate sector."
* This typology is highlighted in CAMS 6th Edition and the FATF's guidance on real estate ML/TF risks.
References:
CAMS 6th Edition, Real Estate and ML Typologies
FATF, Money Laundering and Terrorist Financing through the Real Estate Sector

ARisk Appetite Statement (RAS)helps financial institutions defineacceptable risk levelsand align them withregulatory compliance and business strategy.
* Option A (Correct):Incorporating risk appetite adherence into internal reporting ensures consistent enforcementandaccountabilityacross business functions.
* Option D (Correct):Embedding risk appetite into daily processes ensures that compliance is built into the organization's culture and operations.
* Option E (Correct):Training employees on risk appetite awareness helps them understand compliance limits and risk management principles.
Why Other Options Are Incorrect:
* Option B (Incorrect):Whiletraining managers on "good" risk-takingis valuable,it does not directly enhance risk appetite awareness for compliance.
* Option C (Incorrect):Describing risk controls is useful but insufficientfor embedding risk appetite into an organization's structure.
Best Practices for Implementing Risk Appetite Awareness:
* Ensure risk appetite is a key part of regulatory and operational reporting.
* Train employees at all levels on risk tolerance boundaries.
* Integrate risk appetite considerations into product development and customer onboarding processes.
Reference:
Basel Committee's Principles for Risk Management
FATF Recommendation 1 (Risk-Based Approach to AML)
Wolfsberg Group Guidance on Risk Appetite in Compliance

The correct answer is B, because it describes a method of money laundering known as structuring or smurfing. This is when a customer or a group of customers break down large amounts of illicit funds into smaller transactions that are below the reporting threshold, and then send them to another customer or entity, often in another country. This way, they avoid triggering any suspicion or regulatory reporting by the bureau de change or money services business (MSB) that processes the wire transfers.
Structuring or smurfing is a common technique used by money launderers to move funds across borders and disguise their origin and destination.
The other options are not necessarily indicative of money laundering, although they may require further investigation depending on the circumstances and the risk profile of the customers and countries involved.
Option A describes a regular and small wire transfer that may be legitimate, such as a remittance to a family member or a friend. Option Cdescribes a large volume of wire transfers that may be related to a seasonal or business activity, such as a holiday or a trade event. Option D describes a series of small wire transfers that may be coincidental or random, and do not necessarily add up to a significant amount.
ACAMS CAMS Certification Video Training Course - 6th Edition1
Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)2 ACAMS CAMS Study Guide - 6th Edition, Chapter 2, pages 36-37
https://www.acams.org/wp-content/uploads/2019/09/ACAMS-CAMS-Study-Guide-6th-Edition-Chapter-2.pdf

Money laundering has a significant negative impact on the financial sector by undermining the integrity of financial markets. It distorts asset and commodity prices and leads to the misallocation of resources, which can dampen economic growth. The process also erodes public trust in the financial system and can deter foreign investment.