Detecting Money Laundering Activity | Difficulties in Customer Account Analysis

Difficulties in Analyzing Account Activity for Money Laundering Suspicion

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Question

A compliance analyst is reviewing account activity of a customer that they suspect may be indicative of money laundering activity. Which is difficult to determine solely from the customer's account activity and KYC file?

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A. B. C. D.

C

When a compliance analyst suspects money laundering activity, they must carefully review the customer's account activity and Know Your Customer (KYC) file. While analyzing the account activity, there are certain aspects that can be difficult to determine, such as:

Option A: If the account is mostly dormant or has little activity

This option does not necessarily indicate any suspicious activity as it is common for some customers to have inactive accounts or low transaction volume. However, it is still necessary to verify the source of funds and the purpose of maintaining such an account.

Option B: If the account has multiple transfers to the same, related businesses

Multiple transfers to the same or related businesses can indicate that the customer is involved in a business or trade that requires frequent transactions with these entities. However, it is also possible that these transfers are part of a money laundering scheme, where the customer is trying to layer the illicit funds through a complex web of transactions.

Option C: If the activity is materially different from related businesses

If the customer's activity is significantly different from the typical activity of related businesses, this could indicate that the customer is involved in illicit activities, such as smuggling or terrorism financing. However, it is important to note that some legitimate businesses may also have different activity patterns than their peers.

Option D: If there is negative media associated with counterparties

Negative media associated with counterparties, such as allegations of corruption or fraud, can raise concerns about the customer's involvement in illegal activities. However, it is important to verify the accuracy of such media and to determine whether there is any actual link between the customer and the counterparties in question.

In summary, all of the options presented can be indicators of money laundering activity, but each situation must be assessed individually, and the compliance analyst must use their professional judgment to determine the appropriate course of action.