A 國一家國際私人銀行的一位初級客戶經理,其一位在該機構持有帳戶多年的尊貴客戶向她詢問有關將大筆現金存入她帳戶的事宜。初級客戶經理告訴他的客戶,他的銀行不接受現金。初級客戶經理後來查看了一份客戶活動報告,注意到鄰國 B 的銀行發出了一些較小的美元電匯,該國貨幣管制寬鬆,總額與客戶打算存入的金額差不多。
初級客戶經理該做什麼?
Correct Answer: B
The junior account manager should file a suspicious transaction report (STR) with the Financial Intelligence Unit (FIU) of Country A, as he has reasonable grounds to suspect that the customer is involved in money laundering or terrorist financing. The customer's attempt to deposit a large sum of cash, followed by a series of smaller wire transfers from a high-risk jurisdiction, indicates a possible case of structuring or smurfing, which are techniques used by criminals to avoid detection and reporting thresholds. The junior account manager should not close the account, as this could alert the customer and disrupt the investigation by the FIU or law enforcement. The junior account manager should also not notify the anti-money laundering specialist of his bank, as this could create a conflict of interest or breach of confidentiality, unless the bank's policy requires such notification. The junior account manager should also not offer the customer a more secure method of depositing, as this could be seen as facilitating or condoning the customer's illicit activities, or exposing the bank to legal or reputational risks.
Reference:
CAMS Study Guide, pages 97-98, 103-104, 107-108.
CAMS Exam Questions and Free Practice Test, Question 272.