金融機構為客戶辦理抵押貸款。在隨後對貸款進行的內部審查中,有人指出,用於支持貸款的評估是由不在該機構批准的評估師名單上的評估師進行的。這一例外得到了高級貸款承銷商的批准。審查人員審查了同一地區的其他貸款,指出該貸款的價值明顯高於其他可比較房產的價值。反洗錢專家接下來應該推薦下列哪一項?
Correct Answer: C
According to the Anti-Money Laundering Specialist (the 6th edition) resources, one of the red flags for money laundering in real estate transactions is the use of an appraiser who is not on the approved list of the financial institution. This could indicate a possible collusion between the appraiser and the borrower or the underwriter to inflate the value of the property and obtain a higher loan amount. The anti-money laundering specialist should document the underwriter's actions and the reasons for approving the exception, as well as the discrepancy between the appraised value and the market value of the property. The specialist should then file a suspicious transaction report (STR) to the relevant authorities, as required by the local regulations .
References:
ACAMS Study Guide for the Certified Anti-Money Laundering Specialist (the 6th edition), Chapter 7: Money Laundering Risks and Methods, page 201.
ACAMS Study Guide for the Certified Anti-Money Laundering Specialist (the 6th edition), Chapter 8:
Anti-Money Laundering Programs, page 227.
ACAMS Study Guide for the Certified Anti-Money Laundering Specialist (the 6th edition), Chapter 9:
Conducting or Supporting the Investigation Process, page 255.