A new business opened an account at a bank. After a month of activity, the account is referred to AML Investigations for potential human trafficking activity. Which red flags most likely triggered the referral? (Choose two.)
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A. B. C. D. E.AC
Based on the information provided in the question, a new business opened an account at a bank, and after a month of activity, the account was referred to AML investigations for potential human trafficking activity. To determine which red flags most likely triggered the referral, we need to review the options provided and consider which ones are indicative of potential human trafficking activity.
A. Trade in large volumes conducted with countries that are part of the diamond pipeline: While trade with countries that are part of the diamond pipeline could be an indication of potential money laundering activity, it is not a red flag that is directly related to human trafficking activity.
B. Multiple purchases of virtual currency at or just below the reporting threshold: This is a red flag that could be indicative of human trafficking activity. Virtual currency can be used to facilitate online payments and transactions, including those related to human trafficking. Additionally, making multiple purchases just below the reporting threshold could be a tactic used to avoid triggering reporting requirements.
C. Conducting the businesses transactions online without visiting a branch: While this is not necessarily a red flag for human trafficking activity, it could be a risk factor for money laundering. Online transactions can be difficult to monitor and may provide opportunities for illicit actors to hide their activities.
D. Several lodging and food payments made on the same day at unusual hours for a business: This is not a clear indication of human trafficking activity. It could be a red flag for other types of illegal activity, such as drug trafficking, but there is not a direct connection to human trafficking.
E. Several cash deposits along the country's border that are quickly withdrawn by third parties: This is a red flag that could be indicative of human trafficking activity. Cash deposits and withdrawals made along the country's border, particularly if they involve third parties, could be an indication of attempts to move money across borders to fund human trafficking operations.
Based on the above analysis, options B and E are the most likely red flags that triggered the referral to AML investigations for potential human trafficking activity. Multiple purchases of virtual currency just below the reporting threshold and several cash deposits along the country's border that are quickly withdrawn by third parties are both potential indicators of human trafficking activity.