Which of the following scenarios warrants enhanced due diligence (EDD)? (Select Three.)

• A.An existing local league footballer trying to open a bank account with a bank in their local jurisdiction
• B.An individual with a current bank account who resides in one country becoming the ambassador of another country
• C.The current prime minister of a country trying to open a bank account in another country
• D.A bank located in a higher risk country trying to establish a correspondent-respondent banking relationship with a bank in a lower-risk country
• E.The former personal secretary to the minister of transport in a low-risk country 25 years ago opening a bank account at a bank in a neighboring low-risk country

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Upon learning of a potential weakness through an organization's enterprise-wide sanctions risk assessment relating to a low number of sanctions screening alerts generated compared to the business size and operations identified, which action would best ensure the risk area is properly managed and remediated to the best possible extent?

• A.Reviewing the enterprise-wide risk assessment methodology
• B.Enhancing staff training on the documentation of justification on closed alerts
• C.Revisiting the post-transaction monitoring system parameters and thresholds
• D.Reviewing the fuzzy logic currently adopted in the screening system

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A large international bank's chief compliance officer (CCO) is exploring ways to enhance the bank's ability to identify suspicious activities by using intelligence data more effectively. One potential solution is to engage in public-private partnerships (PPPs) to leverage shared intelligence and enhance collaboration with government agencies.
The bank considers joining a PPP initiative with the local Financial Intelligence Unit (FIU) and other financial institutions to improve its access to relevant data and intelligence. The CCO understands that while PPPs can provide significant benefits, such as improved risk detection and enhanced information sharing, there are also potential limitations, including data privacy concerns and differing priorities between public and private sector partners.
Which approach would best maximize the benefits of PPPs for the bank while mitigating the limitations associated with data sharing and intelligence?

• A.Engage in the PPP without strict data sharing protocols, allowing for open and unrestricted flow of information between the bank, FIUs, and other financial institutions
• B.Rely solely on the intelligence provided by government agencies through the PPP because they have the most comprehensive data on suspicious activities
• C.Establish a clear framework within the PPP that outlines data privacy protections and ensures that information sharing complies with legal and regulatory requirements in all jurisdictions involved
• D.Prioritize the bank's internal data sources over external intelligence from PPPs, as internal data is easier to control and does not present data privacy challenges

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A bank is preparing for a regulatory exam after a previous regulatory exam identified weaknesses in the bank's AML program. Since the last exam, the bank has improved the written AML program, hired an experienced AML compliance officer, and has taken actions to demonstrate a strong culture of compliance.
The bank is now focused on getting through their transaction monitoring case backlog and completing enhancements to its sanctions screening program.
Which of the following are correct? (Select Two.)

• A.The bank is likely to face secondary sanctions from global financial institutions despite addressing many of the previous concerns.
• B.The bank may face civil or criminal penalties if it is unable to demonstrate sustained improvement in addressing the previous concerns.
• C.The bank may face the risk of regulatory orders to remediate its AML program despite addressing many of the previous concerns.
• D.The bank is protected from reputational risk arising from any regulatory action because regulatory orders must remain confidential.
• E.The regulatory agency may require the bank's board of directors to publicly share the actions taken to address the previous concerns in order to limit its reputational risk.

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A wealthy individual is using a complex corporate structure to facilitate illegal logging and then illegal mining of the resulting resources from that land.
Which category of predicate crime is taking place?

• A.Trade-based money laundering
• B.Corruption
• C.Illicit resource trade
• D.Environmental crime

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