Practice question
A covered bank sees a transfer that sharply deviates from a customer's established transaction profile, although the amount is consistent with the customer's wealth and is below the ordinary covered threshold. The bank says those two facts legally rule out every suspicious classification. Which is best?
- Yes; wealth necessarily removes all suspicious indicators.
- No; deviation from profile is an independent statutory suspicious circumstance requiring assessment.
- Yes; a subthreshold transfer cannot be suspicious.
- No; every deviation conclusively proves a completed laundering offense.
- Yes; only convicted customers may generate suspicious transactions.
Legal references
- RA 9194, Sections 1-2 and 6, AMLA transaction definitions and Section 9(c) safe harbor: https://lawphil.net/statutes/repacts/ra2003/ra_9194_2003.html
- RA 10927, casino coverage and casino covered-transaction threshold: https://lawphil.net/statutes/repacts/ra2017/ra_10927_2017.html
- RA 11521, amended covered-person and covered-transaction provisions: https://lawphil.net/statutes/repacts/ra2021/ra_11521_2021.html
- RA 12312, Sections 8 and 17, Anti-POGO Act AMLA amendment: https://lawphil.net/statutes/repacts/ra2025/ra_12312_2025.html
Answer this question in flashcards to review your response and continue practicing.