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…

According to the ACAMS Study Guide 6th Edition, Chapter 2, page 38, one of the steps that a

financial institution should take when it suspects money laundering activity is to file a suspicious

transaction report (STR) or a suspicious activity report (SAR) to the relevant authorities. This will alert

the regulators and law enforcement of the potentialmoney laundering scheme and provide them

with valuable information to trace the funds and identify the perpetrators.

Another step that a financial institution should take is to identify any unusual or suspicious wire

transfers initiated by casas de cambio to jurisdictions outside of Mexico that bear no apparent

business relationship with that casa de cambio. This could indicate that the casas de cambio are

involved in layering and integration stages of money laundering, where they are moving the illicit

funds across borders and disguising their origin and ownership. The financial institution should

monitor and document these wire transfers and report them to the authorities if necessary.

Option B is not a relevant step to trace funds through the bank, as it does not provide any

information about the source, destination, or purpose of the funds. A decrease in the sale of large

denomination U.S. bank notes to casas de cambio by the bank could be due to various factors, such

as market demand, exchange rates, or regulatory changes, and does not necessarily indicate money

laundering activity.

Option C is also not a relevant step to trace funds through the bank, as it does not indicate any

connection to the suspected money laundering scheme. Deposits by casas de cambio that include

third-party items, such as sequentially numbered monetary instruments, could be legitimate

transactions that are part of the normal business operations of the casas de cambio. Unless there is

evidence that these deposits are related to the sale of large denomination U.S. bank notes or the

Mexican syndicate, they are not useful for tracing the funds.

ACAMS Study Guide 6th Edition, Chapter 2, page 38

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