An AML compliance officer is drafting plans to address deficiencies identified in an independent audit. Which approach is the best option?

• A. Draft action plans to address the root cause of the deficiencies, regardless of how long they will take to fully implement
• B. Draft action plans in consultation with the jurisdiction's FIU to remain aligned with other similar companies
• C. Only commit to action plans that can be implemented and closed within the three-month management reporting cycle
• D. Only commit to action plans that require no new investment to maximize shareholder value

An AML analyst at a bank is investigating cases triggered by transaction monitoring alerts. Which circumstances might cause the analyst to suspect a case involves terrorist financing? (Select Two.)

• A. Small dollar payments sent to crowdfunding initiatives with detailed descriptions of the project being financed
• B. Small dollar payments sent to higher-risk jurisdictions with no prior history
• C. Transactions involving structured currency deposits below the reporting threshold to avoid paying taxes
• D. Transactions involving non-profit organizations with no internet presence
• E. Transactions involving domestic non-profit organizations providing charitable aid to refugees from higher-risk countries

The new KYC lead at a bank is particularly focused on enhancing the risk management component of its KYC program and refers to the Basel Committee's customer due diligence (CDD) principles. Which of the following describe key improvements to a KYC program established in the Basel Committee's CDD principles? (Select Two.)

• A. Implementation of a blacklist of correspondent customers with previously detected and investigated suspicious activity
• 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. Enhancement of customer identification procedures to appropriately identify trust, nominee, and fiduciary accounts

An AML/CFT unit often compiles information about customer activity and product usage that might be of interest to other parts of the organization. Before allowing the unit to communicate such information internally, the organization must review:

• A. The risk rating of the customers to avoid sharing data relating to higher risk customers
• B. The organization's AML compliance policies to ensure that customer data can be easily shared internally and internationally
• C. Applicable data privacy laws in relevant jurisdictions and the organization's data security and privacy policies for any limitations
• D. Enterprise-wide risk assessments and the employee handbook for any limitations on sharing commercially sensitive customer data

A customer refuses to provide requested beneficial ownership information. What is the MOST appropriate response?

• A. Reduce monitoring requirements
• B. Continue onboarding without documentation
• C. Consider declining or restricting the relationship
• D. Approve the account due to customer privacy rights