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ACCA Strategic Professional · Advanced Audit and Assurance (International) · Money laundering

Kestrel & Co, an audit firm, discovers that a client's director deposited small cash sums, each below the bank's reporting threshold, into many different accounts over several weeks. Which stage of money laundering does this activity most clearly represent?

This is placement, the first stage of money laundering. Depositing illicit cash in small amounts across several accounts to stay under reporting thresholds introduces the money into the financial system, which is placement rather than layering or integration.

  1. APlacementCorrect
  2. BLayering
  3. CIntegration
  4. DPredicate offending

Explanation

Placement is the first stage, where illicit cash is introduced into the financial system. Splitting cash into small deposits (structuring or smurfing) to avoid reporting thresholds is a classic placement technique. Layering would involve later complex transfers to obscure the trail.

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