A compliance analyst has recently investigated an account where money was deposited in amounts below the reporting limit and almost entirely withdrawn in a foreign country. Which type of money laundering is the compliance analyst potentially identifying?
Microstructuring refers to breaking up large transactions into multiple, smaller transactions, each below reporting thresholds, to avoid detection (''smurfing''). In this scenario, deposits are consistently below the reporting limit---indicative of microstructuring (B). While ''structuring'' (C) is the general term, microstructuring specifically describes the use of very small amounts, often over a prolonged period, which matches this case. The CAMS 6th Edition and FinCEN guidance both recognize microstructuring as a prevalent money laundering typology. Reference:
CAMS 6th Edition, Chapter 3: ''Detection and Reporting of Suspicious Transactions,'' Section: Structuring and Microstructuring
FinCEN, ''Advisory on Structuring and Smurfing,'' 2014
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