一家小型社區銀行的分行經理有一位新客戶,他將 5 萬歐元的支票存入一個帳戶。此後不久,客戶前往另一家分行,要求將除 1,500 歐元外的所有款項轉至位於不同外國司法管轄區的三個帳戶。
哪些可疑活動應成為可疑交易報告的重點?
Correct Answer: D
According to the ACAMS CAMS Certification Video Training Course1, one of the red flags for money laundering is "transferring funds to or from foreign countries or jurisdictions that are known to have weak anti-money laundering standards or are considered high-risk for money laundering or terrorist financing" (Module 2, Lesson 3, Part 2). This is also consistent with the suspicious activity report (SAR) criteria, which require financial institutions to report transactions that "involve funds derived from illegal activity or are intended or conducted to hide or disguise funds or assets derived from illegal activity" or "involve the use of the financial institution to facilitate criminal activity" (31 CFR § 1020.320(a)(2)). Therefore, the customer's request to transfer funds to accounts in three different foreign jurisdictions should be the focus of the SAR, as it may indicate an attempt to launder money or finance terrorism.
Reference:
ACAMS CAMS Certification Video Training Course
[31 CFR § 1020.320 - Reports by banks of suspicious transactions]