CySEC AML Chapter 7 Flashcards: Transaction Monitoring and Suspicious Reporting | ExamPass CY

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What makes a transaction suspicious?: Inconsistency — it does not fit the customer's known legitimate activities or economic profile, regardless of size or currency.

What is the first step when a staff member spots something suspicious?: An internal report to the AML Compliance Officer (the 'Internal Suspicion Report'), who evaluates it and decides whether to escalate to MOKAS.
What documents the AMLCO's assessment, and what if they decide not to escalate?: The 'Internal Evaluation Report'; a decision not to escalate must be fully justified in writing on that report.

How and when are external SARs filed with MOKAS?: Via the GoAML electronic platform, immediately and on the firm's own initiative, irrespective of the amount — including attempted transactions.

Who must the AML Compliance Officer be?: A senior management member with the ability, knowledge and expertise to evaluate reports and liaise with the Unit.
What is the AMLCO's role once an investigation starts?: The firm's first point of contact and liaison with the Unit throughout the investigation.

What protection does a good-faith disclosure carry?: It is not a breach of any confidentiality restriction and implies no liability — even if the reporter was unsure of the underlying crime.
What does whistle-blower protection (Article 69B) cover?: It shields reporters from threats, hostility and workplace discrimination, so staff are not deterred from reporting.

What should a firm do with a suspected transaction before reporting?: Refrain from conducting it until the suspicion has been reported to MOKAS.
What if a suspicious transaction cannot be stopped, or stopping it would tip off suspects?: Let it proceed but notify MOKAS immediately afterwards.

What is 'churning'?: Repeated, purposeless trading in the same instrument — a pattern used to layer funds or manufacture the appearance of activity.
Give an example of a structuring red flag.: Depositing cash in several accounts in amounts below the reporting threshold, then consolidating and wiring the funds abroad.
What are common employee red flags?: A lavish lifestyle beyond their salary, never taking leave (preventing review of their work), and overriding controls.
What does rapid pass-through of funds through an account suggest?: Money in and straight back out, leaving little balance, is a hallmark of layering rather than genuine account use.

Is refusing or delaying a transaction a breach of duty to the customer?: No — non-execution where information is withheld or funds look ML/TF-related is not a breach of any contractual or other obligation.