Understanding Money Laundering, Terrorist Financing and Sanctions

18 free CySEC AML Chapter 2 flashcards. Tap a card to flip, or use the arrow keys to move through the deck.

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Money laundering

Define money laundering.
Concealing or disguising illicitly derived property so it appears legitimate — hiding where criminal proceeds came from so they can be used openly.
What are the three stages of money laundering, in order?
Placement, layering, integration.
What is placement?
The first and riskiest stage — physically introducing criminal cash proceeds into the financial system.
What is the difference between structuring and smurfing?
Structuring splits deposits below the reporting threshold; smurfing uses many people making many small deposits across many accounts and institutions.
What is layering?
Moving money through complex transactions (e.g. cross-border wires, offshore companies) to disguise the audit trail, source and ownership.
What is integration?
Re-entering laundered funds into the economy so they look legitimate — e.g. buying property, businesses or luxury assets.

Cyprus NRA

How does the National Risk Assessment rate Cyprus's overall domestic ML threat?
Medium.
Which five sectors does the NRA name as most vulnerable to ML?
Banking, securities, insurance, other Obliged Entities, and DNFBPs — banking heads the list due to its international exposure.

Products

How is virtual currency different from electronic money?
Virtual currency is a digital representation of value existing only electronically; it must not be confused with e-money. Its near-untraceability raises ML risk.
Who licenses electronic money institutions in Cyprus?
The Central Bank of Cyprus, under the Electronic Money Law of 2012.

Terrorist financing

How does terrorist financing differ from money laundering on source of funds?
TF may use clean, legally obtained funds, whereas ML always uses the proceeds of crime.
How do the motives and money-flow of ML and TF differ?
ML is profit-driven and circular (proceeds return to the criminal); TF is ideology-driven and linear (funds flow outward to an attack).
What is Cyprus's terrorism threat level, and why?
Raised to medium because of geographic proximity to conflict areas, though Cyprus has not faced a violent terrorist incident in the last 27 years.

Sanctions

Which two sanctions regimes must Cyprus apply?
EU restrictive measures and UN Security Council sanctions.
How do EU sanctions operate?
They are list-based: it is prohibited to make funds or economic resources available to, or receive them from, designated persons and entities.
From which part of the UN Charter do UN Security Council sanctions derive?
Chapter VII.
Who recommends, and who decides, on releasing frozen funds in Cyprus?
SEOK (the Advisory Committee on Economic Sanctions) recommends; the Minister of Finance takes the final decision.
What must happen to the assets of listed (designated) persons found in Cyprus?
They must be frozen immediately, without delay.
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