Which scenario would most likely trigger a suspicious matter report (SMR) under AML/CTF obligations?
Correct Answer
B) A client asking to split $50,000 into ten separate cash payments of $5,000
Splitting a $50,000 cash payment into ten $5,000 amounts, each well below the $10,000 threshold, suggests an attempt to avoid threshold transaction reporting. That is structuring, a classic red flag and an offence, and it should lead the agency to consider lodging a suspicious matter report.
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