Money Laundering
Breaking large cash deposits into smaller amounts to avoid detection
What is structuring or smurfing?
The single cash transaction limit under POCA 101A before breaching the law.
What is J\$1 million?
The origin of the specific money being deposited into an account
What is source of funds
The two key parties you must identify in any wire transfer
Who are the sender and the ultimate beneficiary?
Depositing amounts just under the reporting threshold repeatedly
What is structuring?
The first stage of money laundering where illicit funds enter the financial system
What is placement?
rue or False: Sagicor Bank is considered a “permitted person” under POCA.
What is true?
The total financial history of how a client built their wealth over time
What is source of wealth?
The U.S. body that enforces economic sanctions and manages the Specially Designated Nationals list.
What is the Office of Foreign Assets Control (OFAC)
Avoiding suspicious facts on purpose
What is willful blindness?
Accounts used to move criminal funds, with or without the owner’s knowledge.
What are mule accounts
What type of report is required for a cash transaction of USD \$15,000 or more?
What is a Threshold Transaction Report (TTR)?
One acceptable proof for wages or salary as a source of funds.
What is a last pay slip or a letter from the employer?
Name one of the three countries Sagicor will not conduct any business with.
What is North Korea, Iran, or Myanmar?
The type of report filed when a suspicious transaction is attempted but not completed.
What is a UTR for an attempted transaction
Name two predicate offences to money laundering
What are drug trafficking, fraud, tax evasion, or corruption?
disclosing any information to a client that they are being investigated, or infer that you have submitted or will submit an suspicious transaction report.
what is tipping off?
How often must client information be updated at a minimum?
Every 5 years, or more often based on risk profile
What must be done before onboarding a client from a high-risk sanctioned country?
Apply Enhanced Due Diligence and obtain senior management approval.
Three employee red flags that could indicate internal fraud
Living beyond means, avoiding internal controls, refusing vacation, or unusual access to systems
Explain how “layering” differs from “integration” in the money laundering process
Layering is moving illicit funds through complex transactions to obscure their origin, while integration is returning those funds to the economy as seemingly legitimate assets.
Describe the conditions that would make a cash transaction a breach of POCA 101A.
If a single or linked cash transaction exceeds J\$1M and is conducted by someone who is not a permitted or exempted person.
The KYC process helps prevent these two major crime
What are money laundering and terrorist financing?
State the maximum fine and imprisonment term for failing to maintain wire transfer records for individuals in Jamaica.
$3 million and/or 3 years imprisonment.
This ACT complements POCA by targeting terrorism financing
What is Terrorism Prevention Act (TPA)