Which of the following scenarios exhibit classic indicators of suspicious transactions? (Select Two.)
A.
A business owner mortgages his home with a financial institution that was recently fined for AML violations
B.
A customer regularly invests in equity funds using her spouse’s bank account where she is a second account holder
C.
An individual who is the secretary to a government official frequently accesses the bank’s safe deposit vault to withdraw cash
D.
An individual regularly imports sophisticated electronic items for civil use and pays all applicable customs duties
E.
An individual wants to execute wire transfers to a person in a FATF grey-listed jurisdiction and asks a close friend to send the money on his behalf, citing financial difficulties
Classic indicators of suspicious activity often involve use of proxies, unusual cash access, or attempts to avoid scrutiny, as highlighted in FATF and FIU guidance.
Frequent access to a safe deposit vault to withdraw cash by a person closely associated with a government official raises heightened concern. Such behavior may indicate attempts to conceal illicit funds, particularly given the potential exposure to corruption risk associated with politically exposed persons (PEPs) and their close associates.
Similarly, requesting a third party to execute wire transfers on one’s behalf to a FATF grey-listed jurisdiction is a well-recognized red flag. This behavior suggests an attempt to evade transaction monitoring, sanctions screening, or enhanced due diligence requirements by distancing oneself from the transaction.
The remaining scenarios describe activities that are either legitimate or explainable with proper documentation and transparency. Merely dealing with an institution previously fined for AML violations or conducting legitimate trade with customs compliance does not, on its own, constitute suspicious activity.
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