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A. Consistency of approach

B. Independent testing

C. Qualification of the team

D. Periodic training of the function

A. Conduct AML audits no less often than every 12 months for consistency in annual reporting.

B. Remain independent from expressing opinions on the sufficiency of remediation or action plans to address findings and recommendations.

C. Report to the audit committee of the board of directors to maintain independence.

D. Be involved in the day-to-day operations of the AML program to immediately prevent control failures.

A. civil and criminal penalties

B. increased reputation risk.

C. delisting of public filing status.

D. inclusion on the UN Consolidated List.

A. A customer requests loans made to local companies or secured by obligations of local banks.

B. A customer receives wire transfers from different unknown accounts which are immediately wired onwards to a third party.

C. A customer withdraws cash in amounts just under the reporting threshold.

D. A customer deposits a large number of consecutively numbered money orders.

E. A customer has regular deposits and withdrawals primarily in wire transfers.

A. Matches names with the same length and characters

B. Matches names on screening lists to names with similar spellings, patterns, or sounds

C. Relies exclusively on exact string matches

D. Uses machine learning to predict names based on historical data

A. Transactions involving non-profit organizations with no internet presence

B. Small dollar payments sent to crowdfunding initiatives with detailed descriptions of the project being financed

C. Transactions involving domestic non-profit organizations providing charitable aid to refugees from higher-risk countries

D. Transactions involving structured currency deposits below the reporting threshold to avoid paying taxes

E. Small dollar payments sent to higher-risk jurisdictions with no prior history

A. Generalized content designed to apply to a broad audience

B. In-person training sessions

C. Comprehensive curriculum delivered by senior management

D. Comprehensive content with engaging delivery methods

A. Enhancement of customer identification procedures to appropriately identify trust, nominee, and fiduciary accounts

B. Enhancement of a customer acceptance policy to more clearly identify high-risk customers

C. Increased frequency of training provided to front office employees

D. Implementation of a blacklist of correspondent customers with previously detected and investigated suspicious activity

A. The process is time-consuming and requires significant manual effort

B. Search engines provide unstructured data that complicates media analysis

C. Search results are often inefficient in identifying relevant adverse media

D. Outcomes can be inconsistent due to varying search engine algorithms

E. Search engines have limited global language coverage

A. Ensuring that the shared data complies with applicable data protection regulations while maintaining the integrity and accuracy of the information

B. The cost of the data-sharing system and whether it its within the existing IT budget

C. The potential return on investment (ROI) from the data shared versus the financial crime prevention effort

D. The preference of upper management regarding which teams should participate in the data- sharing initiative

A. The prospective client exhibits confidence when speaking to the accountant when providing personal details

B. The prospective client presents confusing details about the proposed business and has very little knowledge about the proposed business activity

C. The prospective client is unable to provide information about the beneficial owners

D. The prospective client is able to provide source of funds and source of wealth documents

E. The principal activities of the proposed company are importing and exporting new furniture