CAMS Exam Practice | Suspicious Money Laundering Activity

Suspicious Activity: Depositing Cashier's Checks and Receiving Electronic Transfers

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Question

The owner of a real estate investment company deposits multiple cashier's checks that were bought using cash over a three month period, from the sale of two apartments. This account also receives several electronic transfers from other financial institutions for $10,000 USD each. What activity is considered suspicious of money laundering?

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Based on the provided scenario, using cash to buy multiple cashier's checks over a period of time is considered suspicious of money laundering.

Money laundering is the process of concealing the proceeds of criminal activity by making them appear legitimate. The three stages of money laundering are placement, layering, and integration. Placement involves introducing the illegal funds into the financial system, layering involves moving the funds through complex financial transactions to conceal their origin, and integration involves returning the funds to the criminal as apparently legitimate proceeds.

In the given scenario, the use of cashier's checks bought with cash is a common method of placement. Cashier's checks are often used to avoid the currency transaction reporting requirements of banks. This allows individuals to move large amounts of money without detection by law enforcement.

Additionally, the fact that multiple cashier's checks were deposited over a three-month period indicates a pattern of behavior that is consistent with structuring. Structuring is the practice of breaking up large transactions into smaller transactions to avoid reporting requirements. It is illegal to structure transactions in this way to avoid reporting requirements.

Furthermore, the electronic transfers from other financial institutions for $10,000 USD each could be considered suspicious, as this is a common threshold for reporting large transactions under the Bank Secrecy Act. However, without additional information, it is not possible to determine if these transfers are indicative of money laundering or other illicit activity.

Performing operations with real estate investment companies is not inherently suspicious, as real estate is a legitimate business. However, real estate is also a common vehicle for money laundering, and additional scrutiny should be applied to real estate transactions to ensure they are legitimate.

In conclusion, using cash to buy multiple cashier's checks over a period of time is the activity that is considered suspicious of money laundering in the provided scenario.