CFE-LAW practice question 10 of 25

Each day, Rachel purchases $14 500 in bearer instruments with cash from a bank where all currency transactions above 515,000 must be reported to the government Rachets actions are a red flag of which of the following schemes'?

Full set: 158 questions
Answer options
A: Channel stuffing
B: Alternative remittance system
C: Structuring Correct answer
D: Real estate laundering
Correct Answer:
C. Structuring
Explanation

Structuring, also known as "smurfing," is the illegal practice of breaking down a single large cash transaction into multiple smaller transactions to evade legal reporting requirements. Financial institutions are often required to report cash transactions exceeding a certain threshold. In this scenario, Rachel intentionally conducts daily transactions of $14,500, which is just below the government's mandatory reporting threshold of $15,000. This pattern of repeated, sub-threshold transactions is a classic indicator of structuring, designed to launder illicit funds while avoiding detection by authorities.

Why Incorrect

A. Channel stuffing is a fraudulent revenue recognition scheme used to inflate sales and earnings figures, unrelated to money laundering through cash transactions.
B. An alternative remittance system (e.g., Hawala) is an informal value transfer network that operates outside the traditional banking system; Rachel is using a bank.
D. Real estate laundering involves using property transactions to legitimize illicit funds, which is a different method than the specific act of structuring cash deposits.

References

1. Association of Certified Fraud Examiners. (2023). Fraud Examiners Manual, International Edition. Section 2: The Law, Subsection: Money Laundering and Transnational Fraud, pp. 2.1110-2.1111. The manual defines structuring as "the act of breaking up a single transaction above the reporting threshold into multiple, smaller transactions, all of which are below the threshold."

2. King, C., & Walker, C. (2014). Dirty money: The evolution of money laundering countermeasures. Routledge. In Chapter 3, "The Money Laundering Process," the authors describe structuring as a primary placement technique where launderers make multiple deposits under the reporting limit to avoid triggering a Currency Transaction Report (CTR). (DOI: https://doi.org/10.4324/9781315814980)

3. Boston University School of Law. (n.d.). Graduate Program in Banking & Financial Law: Course Descriptions. In courses such as "Financial Crimes, AML & Sanctions Compliance," the curriculum covers money laundering typologies, including structuring, where cash-intensive transactions are deliberately kept below reporting thresholds like the U.S. $10,000 limit to avoid scrutiny.

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