A United States (U.S.) bank was recently alerted by law enforcement of an increase in sale of large denomination U.S. bank notes to casas de cambio. They suspect that a Mexican syndicate is operating a money laundering scheme in the bank's jurisdiction.
Which two steps should be taken to trace funds through the bank to assist law enforcement in their investigation? (Choose two.)
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Sure, I'd be happy to explain in detail the steps that should be taken to trace funds through the bank to assist law enforcement in their investigation.
The scenario involves a U.S. bank that has been alerted by law enforcement of an increase in the sale of large denomination U.S. bank notes to casas de cambio. The suspicion is that a Mexican syndicate is operating a money laundering scheme in the bank's jurisdiction. The bank is now tasked with assisting law enforcement in their investigation.
To trace funds through the bank and assist law enforcement, the bank should take the following two steps:
Identify the money laundering scheme and submit a suspicious transaction report: The first step that the bank should take is to identify the money laundering scheme. This would involve analyzing the transactions that are taking place, particularly those involving the sale of large denomination U.S. bank notes to casas de cambio. By analyzing these transactions, the bank can identify any unusual patterns or red flags that may indicate that money laundering is taking place. Once the bank has identified the money laundering scheme, it should submit a suspicious transaction report (STR) to the Financial Crimes Enforcement Network (FinCEN), as required by the Bank Secrecy Act (BSA). The STR should include all relevant information about the suspicious activity, including the identity of the parties involved, the nature of the transactions, and any other relevant information that the bank has.
Identify deposits by casas de cambio that include third-party items including sequentially numbered monetary instruments or Identify multiple wire transfers initiated by casas de cambio to jurisdictions outside of Mexico that bear no apparent business relationship with that casa de cambio: The second step that the bank should take is to identify any deposits by casas de cambio that include third-party items, including sequentially numbered monetary instruments, or multiple wire transfers initiated by casas de cambio to jurisdictions outside of Mexico that bear no apparent business relationship with that casa de cambio. These transactions are often used in money laundering schemes to move funds across borders and to conceal the true source of the funds. By identifying these transactions, the bank can provide valuable information to law enforcement to help them track the movement of funds and identify the individuals or organizations involved in the money laundering scheme.
It is important to note that identifying and reporting suspicious activity is not only required by law but is also a critical part of the bank's responsibility to combat financial crime and protect the integrity of the financial system. By working with law enforcement and providing them with the information they need, the bank can help to prevent money laundering and other criminal activities and ensure that the financial system remains a safe and secure place for all users.