According to the CAMS Study Guide, one of the methods to launder money using TCSPs is to create a complex web of transactions involving multiple entities and jurisdictions, often using shell companies and nominees. The payment of consultancy fees to unrelated companies and service providers established in a foreign jurisdiction could be a sign of such a scheme, as it could be used to disguise the origin and destination of illicit funds, or to evade taxes and regulations. Therefore, this transaction indicator warrants further escalation to the compliance officer.: CAMS Study Guide, 6th Edition, Chapter 2, page 69.

The Black Market Peso Exchange (BMPE) is a trade-based money laundering technique commonly used by narcotics traffickers in Colombia and Mexico. The central feature uses a money trader to ensure that US drug sales revenue doesn't cross any borders. Instead, those dollars are used to purchase any number of legitimate commodities from unsuspecting businesses on behalf of legitimate South American businesspersons, whose legitimate imports are used to obtain pesos for the drug cartels. This method is closely associated with international trade because it involves the exchange of goods and currencies across different countries, and it exploits the discrepancies between the official and unofficial exchange rates.
:
CAMS Certification Package - 6th Edition | ACAMS, Chapter 2: Money Laundering Risks and Methods, page
35
Black Market Peso Exchange in Money Laundering - Financial Crime Academy What is BMPE ? - Sanction Scanner Overview - FinCEN.gov Reference:http://fraudaid.com/Dictionary-of-Financial-Scam-Terms/black_market_peso_exchange.htm

AML risk assessments must beupdatedwhen there aresignificant changes in business operations.
* Option A (Correct):New products (e.g.,cryptocurrency services, trade finance) introducenew AML risks.
* Option D (Correct):Technology changes(e.g.,AI in transaction monitoring, new digital banking platforms) impactfraud and AML controls.
* Option E (Correct):Mergers or acquisitionsintroducenew customer bases, jurisdictions, and compliance frameworks, requiringrisk reevaluation.
* Option B (Incorrect):While compliance restructuring is important,it does not change inherent risk exposure.
* Option C (Incorrect):Management changesmay affect oversight, but they donot directly alter risk exposure.
Reference:Wolfsberg Group Risk-Based Approach, FATF Recommendation 1 (Risk-Based Approach), Basel Committee AML Guidelines.

Correspondent banking is the product type that is subject to US extra-jurisdictional reach over non-US banks and non-US persons under the USA PATRIOT Act. This is because correspondent banking involves the provision of banking services by one bank (the correspondent) to another bank (the respondent) or to the respondent's customers. Correspondent banking enables cross-border transactions and access to foreign financial systems, but also poses significant money laundering and terrorist financing risks due to the lack of transparency and accountability of the parties involved. The USA PATRIOT Act requires US financial institutions to apply enhanced due diligence measures to correspondent accounts for certain foreign banks, such as those operating under offshore banking licenses, those owned or controlled by foreign governments, or those of primary money laundering concern. These measures include obtaining information about the ownership, management, and anti-money laundering controls of the foreign bank, as well as the identity and activity of the customers using the correspondent account. The USA PATRIOT Act also authorizes the US Treasury to prohibit or impose conditions on the opening or maintaining of correspondent accounts for foreign banks that are involved in money laundering or terrorist financing activities.
References:
CAMS Study Guide, 6th Edition, Chapter 5, Section 5.2.1, p. 1611
Financial Crimes Enforcement Network; Anti-Money Laundering Programs; Special Due Diligence Programs for Certain Foreign Accounts, 31 CFR Part 103, RIN 1506-AA292
U.S. Extra-Jurisdictional Reach under the USA PATRIOT Act - Exam-Answer3

Transaction monitoring governance involves ensuring that AML detection systems are effective, aligned with regulatory standards, and capable of identifying evolving threats.
Option B (Correct): Legal cooperation is essential for responding to subpoenas and law enforcement inquiries.
Option D (Correct): Regularly updating transaction monitoring scenarios ensures that the system adapts to emerging financial crime trends.
Why Other Options Are Incorrect:
Option A (Incorrect): SARs cannot be withdrawn unless an error was made-once filed, SARs remain confidential and must be retained.
Option C (Incorrect): Client profile updates are a CDD/KYC function, not directly related to transaction monitoring governance.
Best Practices for Transaction Monitoring Governance:
Regularly review system effectiveness through validation tests.
Collaborate with legal and compliance teams for risk mitigation.
Use AI and data analytics to refine detection accuracy.
Reference:
FATF Recommendation 10 (Customer Due Diligence & Ongoing Monitoring)
Wolfsberg Group Guidance on Transaction Monitoring Effectiveness
Basel Committee's Guidelines on AML Technology and Data Analytics