What additional information would trigger filing a SAR/STR?

CLIENT INFORMATION FORM Client Name: ABC Tech Corp Client I.D. Number: 08125 Name: ABC

Tech Corp Registered Address: Mumbai, India Work Address: Mumbai. India Cell Phone: *■*•"― Alt

Phone: Email: *•*•*«•*•

Client Profile Information:

Sector: Financial

Engaged in business from (date): 02 Jan 2020

Sub-sector: Software-Cryptocurrency Exchange

Expected Annual Transaction Amount: 125.000 USD

Payment Nature: Transfer received from client’s fund

Received from: Clients

Received for: Sale of digital assets

The client identified themselves as "Cryptocurrency Exchange" Client has submitted the limited liability partnership deed. However, the bank’s auditing team is unable to identify the client’s exact business profile as the cryptocurrency exchange specified by the client as their major business awaits clearance from the country’s regulator. The client has submitted documents/communications exchanged with the regulator and has cited the lack of governing laws in the country of their operation as the reason for the delay.

Investigators determine the ultimate beneficial owner of ABC Tech Corp is a high-net-worth client. The client owns a real estate agency left to her when her spouse died. The spouse provided seed capital for ABC Tech Corp through a direct 1,000.000 Great British Pound (GBP) deposit.

What additional information would trigger filing a SAR/STR?
A . The client’s spouse’s source of wealth was a salary of 250,000 GBP per annum for the past 4 years and rental of properties of 150,000 GBP per annum for the past 6 years.
B . The client’s current net asset value is 8 million GBP, of which 7.5 million GBP was derived from the inheritance.
C . An open-source search revealed that the client’s spouse was a PEP.
D . The funds for the seed capital were in the form of 50 cashier’s checks of 10,000 GBP each and 50 money orders of 10,000 GBP.

View Answer

Answer: D

Explanation:

The additional information that would trigger filing a SAR/STR is the fact that the funds for the seed capital were in the form of 50 cashier’s checks of 10,000 GBP each and 50 money orders of 10,000 GBP. This is because this indicates a possible attempt to avoid the reporting threshold of 10,000 GBP for cash transactions, which is a common money laundering technique known as structuring or

smurfing12. The other options are not necessarily suspicious, as they do not involve cash transactions or indicate any illicit source of funds. The fact that the client’s spouse was a PEP does not automatically make the transaction suspicious unless there are other red flags or risk factors associated with the PEP34

Reference: 1: Money Laundering Techniques 2: Structuring 3: Politically exposed person 4: PEP Definition & Meaning – Merriam-Webster