A money transmitter's nation-wide agent network remits funds to a country in Africa on behalf of an immigrant community based in the United States. A terrorist group is known to operate openly in this African country. In reviewing transaction records, the compliance officer detects a pattern where two customers together visit the same agent each week and remit the same amount of funds, $2,500, to the same recipient in the country in Africa.
What should alert the compliance officer to possible money laundering or terrorist financing activity by the two customers?
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A. B. C. D.D
In this scenario, the compliance officer is reviewing transaction records of a money transmitter's nation-wide agent network. The customers, who are part of an immigrant community in the United States, visit the same agent together each week and remit $2,500 to the same recipient in an African country known to have a presence of a terrorist group. The compliance officer needs to identify any potential indicators of money laundering or terrorist financing activity based on the given information.
Let's analyze each answer choice to determine which one is the most relevant indicator:
A. The customers always visit together. This information alone does not necessarily indicate money laundering or terrorist financing. Customers visiting together may have various legitimate reasons for doing so, such as convenience or shared business interests.
B. The customers always visit the same agent. Again, while this behavior can be an interesting observation, it does not directly point to money laundering or terrorist financing. Customers may prefer a specific agent due to factors like location, familiarity, or trust.
C. The funds are being sent to the same recipient each week. This is a crucial piece of information that should raise suspicion. The fact that the funds are consistently sent to the same recipient in the African country, especially if it is known to have a terrorist group operating openly, increases the risk of money laundering or terrorist financing. This pattern suggests a possible illicit activity where funds may be intentionally directed to support the activities of the terrorist group.
D. The dollar amount of each transaction is just below the record-keeping threshold. While transactions just below the record-keeping threshold might raise regulatory concerns due to potential structuring (i.e., breaking down larger transactions into smaller ones to avoid scrutiny), it is not directly indicative of money laundering or terrorist financing in this specific case. The focus should primarily be on the consistent pattern of sending funds to the same recipient in the high-risk African country.
Considering the given information, option C is the most relevant indicator that should alert the compliance officer to possible money laundering or terrorist financing activity by the two customers.