PAST QUESTION PAPER Thomasson & Co. Ans. The process by which criminals attempt to conceal the true origin of the illegal money and tries to depict the money has been obtained from legal sources. The high level of cash based sales and high volume of sales report create a significant risk that illegal funds are being passed off as legitimate sales. The company chief executive sold $33000 worth cleaning products to business associate which looks suspicious given the nature of the industry and this could be an illegal fund which the CEO is trying to place and depict as genuine sale. Placement is defined as the proceeds of crime into the financial system. This is to avoid suspicion that large sum of cash’s would arouse. There are many transactions happening with the off shore bank account which could be an indicator of layering the illegal money and Mr. Blackers being the sole signatory makes it even more suspicious and easy to launder. This indicates lack of segregation of duties where one personnel has all the authority making it easy to carry out illegal activities and is deficiency in internal control. Layering is process by passing it through several institutions to mask its true identity. There are also purchases and sales of properties happening which could be real estate laundering where CEO might be placing his money to buy properties and later sell to integrate that money. Integration is defined as integration back into legitimate economy.