Bringing $15,000 worth of chips into the casino is a red flag because it could indicate that the customer is trying to avoid the currency transaction reporting (CTR) requirement for cash transactions over
$10,0001. Requesting a wire transfer to an unrelated third party is another red flag because it couldindicate that the customer is trying to conceal the source or destination of the funds, or transfer them to a high-risk jurisdiction2.
1: ACAMS CAMS Certification Video Training Course, Module 3: Casinos and Gaming, Section 3.1:
Regulatory Requirements, Slide 8 2: ACAMS CAMS Certification Video Training Course, Module 3:
Casinos and Gaming, Section 3.2: Money Laundering Methods and Red Flags, Slide 11

According to the Financial Action Task Force (FATF) 40 Recommendations, Recommendation 10 requires financial institutions to identify and verify the identity of their customers, including legal persons and arrangements, using reliable and independent sources. This includes verifying the legal existence and structure of the legal entity, such as by obtaining a certificate of incorporation, a partnership agreement, or a trust deed. Additionally, financial institutions should identify and verify the identity of the beneficial owners of the legal entity, such as by obtaining information on the natural persons who ultimately own or control the entity, or who exercise effective control over the entity.
The other options are not consistent with the FATF 40 Recommendations. Verifying the financial status of the legal entity, or the entity's other banking relations, is not a requirement for identification purposes, although it may be relevant for risk assessment or due diligence purposes. Verifying a person purporting to act on behalf of the legal entity is also not sufficient, as the person may not be authorized or may not disclose the true identity or beneficial ownership of the entity. Verifying funds or trusts maintained by terrorists is not a specific identification requirement, but rather a general obligation to comply with targeted financial sanctions and freeze the assets of designated persons or entities.
FATF 40 Recommendations, Recommendation 10, Interpretive Note to Recommendation 10, pages 14-18.
ACAMS CAMS Certification Study Guide, 6th Edition, Chapter 3, Section 3.2.1, page 77.

The best option for the compliance officer is to follow the financial institution's established STR reporting policy, which should include procedures for reporting suspicious activity involving senior management or board members. This would ensure that the compliance officer acts in accordance with the bank's internal controls and governance, and avoids any potential conflicts of interest or breaches of confidentiality. The other options are not advisable because they could either compromise the integrity of the STR filing, expose the compliance officer to legal or reputational risks, or alert the subject of the investigation.
ACAMS Study Guide for the CAMS Certification Examination, 6th Edition, Chapter 4, page 1401 ACAMS CAMS Certification Video Training Course, Module 4, Lesson 22 ACAMS CAMS Certification Practice Exam, Question 843

TheBoard of Directorsholdsultimate responsibilityforAML/CFT compliance and governance.
* Option B (Correct):TheBoardmustoversee, approve, and ensure AML programs are effective.
* Option A (Incorrect):TheCOO manages operations, butdoes not hold ultimate accountability.
* Option C (Incorrect):While theAML officer executes compliance programs, theBoard provides oversight.
* Option D (Incorrect):TheCEO is responsible for strategy, butAML failures fall under Board accountability.
Reference:Basel Committee's Corporate Governance Principles for Banks, FATF Recommendation 1 (Risk- Based Approach), U.S. OCC AML Compliance Guidelines.

Dealers in antiques, precious metals, precious stones, jewelry, and art are advised to follow these practices to reduce the element of money laundering risk:
Verify the identities of all new vendors and customers and conduct due diligence on them. This is to ensure that the dealers know who they are dealing with and can assess the risk level of each customer or vendor. Due diligence may include obtaining and verifying identification documents, checking against sanctions lists or watchlists, obtaining information on the source and purpose of funds, and applying a risk-based approach to the level and frequency of due diligence.
Avoid accepting cash payment from the buyers. This is to prevent the dealers from being used as a conduit for laundering illicit cash or facilitating cash smuggling. Cash transactions are more difficult to trace and may indicate attempts to evade reporting or record-keeping requirements. Dealers should encourage the use of non- cash payment methods, such as bank transfers, cheques, or credit cards, and keep records of all payment transactions.
Insist all vendors submit an appropriate license issued by enforcement agencies authorizing the sale. This is to ensure that the dealers are not involved in the trade of stolen, smuggled, or counterfeit goods, which may be linked to money laundering or other criminal activities. Dealers should verify the authenticity and validity of the licenses and keep copies of them for record-keeping purposes.
FATF Guidance on the Risk-Based Approach for Dealers in Precious Metals and Stones, pages 9-10, 13-14,
17-18, 21-22
AML-CFT Handbook for Dealers in Precious Metals and Stones, pages 25-26, 37-38, 52-53 The anti-money laundering framework for precious stones and metals dealers in Singapore, pages 7-8, 11-12,
15-16
Dealers in Precious Metals, Stones or Jewels Required to Establish Anti-Money Laundering Programs, pages
2-3, 6-7, 10-11