Q: 5
A financial institution (Fl) banks a money transmitter business (MTB) located in Miami. The MTB
regularly initiates wire transfers with the ultimate beneficiary in Cuba and legally sells travel
packages to Cub
a. The wire transfers for money remittances comply with the country's economic sanctions policies. A
Fl investigator on the sanctions team reviews each wire transfer to ensure compliance with sanctions
and to monitor transfer details.
An airline located in Cuba, unrelated to the business, legally sells airline tickets in Cuba to Cuban
citizens wanting to travel outside of Cuba. The airline tickets are purchased using Cuban currency
(CUC).
The MTB wants 100,000 USD worth of CUC. Purchasing CUC from a Cuban bank includes a 4% fee.
The MTB contacts the airline to ask if the airline will trade its CUC for USD at a lower exchange fee
than the Cuban bank. The airline agrees to a 1% fee. The MTB initiates a wire transfer to the airline
which appears as normal activity in the monitoring system because of the business' travel package
sales.
Which investigative actions should the investigator take concerning the 100.000 USD wire transfer?
(Select Three.)
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