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• THREE STAGES IN THE MONEYLAUNDERING CYCLEWhat is money laundering?

  
  Money laundering is the taking of criminal proceeds and
  disguising their illegal sources in order to use the funds to
  perform legal or illegal acts.

• THREE STAGES IN THE MONEYLAUNDERING CYCLEGive an example of the first stageof money laundering.

  
  Electronically moving funds from one country to another;
  moving funds from one financial institution to another;
  and converting the cash placed into the system into
  monetary instruments.

• THREE STAGES IN THE MONEYLAUNDERING CYCLEGive an example of the third stage ofmoney laundering.

  
  Purchasing luxury assets like property, artwork,
  jewelry or high-end automobiles; and investing in
  business enterprises.

• THREE STAGES IN THE MONEYLAUNDERING CYCLEGive an example of the first stageof money laundering.

  
  Co-mingling illegitimate funds with legitimate
  ones; making foreign exchange transactions with
  illegal funds; and depositing small amounts of cash
  into various accounts.

• INDIVIDUAL ACCOUNTABILITYWhat does the Yates memo say?

  
  The Yates memo, issued by then-Deputy Attorney
  General Sally Yates of the Department of Justice, reminds
  prosecutors that criminal and civil investigations into
  corporate misconduct should also focus on individuals
  who perpetrated the wrongdoing.

• ELECTRONIC TRANSFERSOF MONEYWhat are some indicators of moneylaundering using electronic transfersof funds?

  
  Funds transfers to or from a financial secrecy haven; large,
  incoming fund transfers from a foreign client with little
  or no explanation or apparent reason; and fund transfers
  that have no apparent link to legitimate business.

• REMOTE DEPOSIT CAPTUREWhat is remote deposit capture andwhat risk is associated with it?

  
  Remote deposit capture is a product offered by
  banks that allows customers to scan a check and
  transmit an electronic image to the bank for deposit.
  The risk associated with it is that it enables a money
  launderer to deposit checks without having to visit the
  bank and risk detection.

• PAYABLE THROUGH ACCOUNTSWhat are some of the moneylaundering risks pertaining to the useof payable through accounts (PTAs)?

  
  PTAs with foreign institutions licensed in offshore centers
  with each bank supervision; PTAs where the respondent
  bank (the foreign bank) fails to conduct adequate
  customer due diligence; and PTAs where the sub-account
  holders have currency deposit and withdrawal privileges.

• CONCENTRATION ACCOUNTSWhat is a money laundering riskpertaining to the use ofconcentration accounts?

  
  The primary money laundering risk pertaining to the use
  of concentration accounts is the fact that the customeridentifying
  information may not be included, making the
  audit trail difficult or impossible to follow.

• PEPSWhat is a PEP and what is theprimary risk in dealing with a PEP?

  
  A PEP is a “politically exposed person,” meaning a
  person who has or has had a prominent government or
  quasi-public position in a country. The primary risk in
  dealing with a PEP is that the source of funds from a PEP
  may be from corruption.