AML Quiz

The statement is false because presenting a Visa Credit card as proof of identification is not sufficient for a withdrawal to be made. Verification typically requires additional forms of identification, such as a government-issued ID or a passport, to ensure the account holder's identity and prevent fraud.

The stages of money laundering are placement, integration, and layering. Placement refers to the process of introducing illegally obtained funds into the financial system. Integration involves merging the illicit funds with legitimate assets to make them appear legal. Layering is the complex process of disguising the source of funds through multiple transactions and transfers, making it difficult to trace the original source of the money. This sequence of stages allows criminals to effectively launder their illicit proceeds and make them appear legitimate.

You have a personal responsibility…

Even if you are a junior member of the team;
Even if you are a new member of the team.

Tipping off refers to the act of disclosing information about an ongoing investigation to the customer or any other party involved, which could potentially compromise the investigation. This is considered illegal and unethical as it allows the individual being investigated to take steps to evade detection or destroy evidence. It is important to maintain confidentiality and not disclose any information that could tip off the subject of an investigation.

If the company fails to implement counteractive measures in preventing AML, there are several potential risks that can occur. Firstly, there may be a loss of revenue as the company could face fines and penalties for non-compliance with AML regulations. Additionally, the company may attract the wrong kind of business, such as money launderers, which can damage its reputation and credibility. Furthermore, there is a risk of having the license to operate revoked by regulatory authorities if the company does not take appropriate measures to prevent AML. Lastly, the directors of the company may be fined individually for their failure to implement necessary measures. Therefore, all of the above risks are potential consequences of not implementing counteractive measures for AML prevention.

If a player is under investigation – we can keep the documents as long as required by the regulator / authorities.

We can accept PEP but they are placed on High risk list for ongoing monitoring

They are more vulnerable on the Placement stage due to the fact that placing large amounts of money (cash) into the legitimate financial system may raise suspicions of officials.

Layering is the correct answer because it refers to the stage of money laundering where illicit funds are separated from their original source. During this stage, individuals or organizations engage in complex transactions to obscure the audit trails and sever any links with the original crime. The purpose of layering is to make the money appear as if it is part of a legitimate financial transaction, thus making it difficult to trace back to its illegal origins.

Suspicions must be reported to our MLRO

Suspicions must alerted to the MLRO (Money Laundering Reporting Officer) using the Suspicious Transaction form (Lisa Karran is MLRO & Chris Kirkham is Deputy MLRO);

Discrepancies between the information submitted by the customer and information detected by monitoring systems;
Unusual volume of payment destinations, often with the same provider;
A large and diverse source of funds (i.e., bank transfers, credit card and cash funding from different locations) used to fund the same account(s);
Multiple reference bank accounts from banks located in various cities used to fund the same account ;
Loading or funding of account always done by third parties;
Numerous withdrawals, just under the qualifying threshold;
Multiple and frequent deposits followed by multiple and frequent withdrawals, either shortly afterwards or overlapping further deposits;
Multiple deposits conducted from different payment methods;
Large number of bank accounts held by the same individual (sometimes in different countries) apparently used as flow- through accounts (may be indicative of layering activity);
Individual resides in one country but holding accounts in other countries;
Reluctance to provide Identification information .

The explanation for the given correct answer (Option 1) is not available.

The threshold transaction amount for this question is EUR 3,000. This means that any transaction below this amount will not be considered significant or require special attention.

With regard to Online Gaming, the use of the site is generally the means of committing the crime rather than being used as a major means of laundering money obtained through other criminal activity. This still means that the activity falls under the Money Laundering law.