Transfers of money over the last 6 months to a corporation in a jurisdiction with strict secrecy laws triggered an alert. Which of the following…

According to the CAMS study guide, chapter 4, page 851, bearer shares are shares that do not have

the name of the owner registered on them, and the ownership is transferred by the physical delivery

of the share certificate. This means that the true beneficial owner of the company can be hidden or

changed without any record or notification. Bearer shares are considered a high-risk factor for money

laundering and terrorist financing, as they can facilitate the movement and concealment of illicit

funds through anonymous corporate vehicles. Therefore, the company having bearer shares should

cause the most suspicion of money laundering among the options given.

The other options are not necessarily indicative of money laundering, although they may have some

risk implications depending on the context and the customer profile. Option A, the jurisdiction being

a known tax haven, may suggest that the company is seeking to avoid or minimize taxes, but this

does not imply that the company is involved in money laundering, as there may be legitimate tax

planning or optimization purposes. Option C, the corporation director being a European citizen, may

indicate that the company has some cross-border or international activities, but this does not imply

that the company is involved in money laundering, as there may be valid business or personal

reasons for the director’s nationality. Option D, no financial statements being filed for 3 years,

maysuggest that the company is not complying with the accounting or reporting standards of the

jurisdiction, but this does not imply that the company is involved in money laundering, as there may

be other explanations or mitigating factors for the lack of financial statements.

1: ACAMS CAMS Study Guide - 6th Edition, Chapter 4, page 85: https://www.acams.org/wpcontent/uploads/2019/09/ACAMS-CAMS-Study-Guide-6th-Edition-Chapter-4.pdf