The Basel Committee's AML guidelines emphasize risk-based customer due diligence (CDD) and beneficial ownership transparency.
Option A (Correct): CDD policies must be risk-based to apply enhanced due diligence (EDD) for high-risk customers and simplified due diligence (SDD) for low-risk customers.
Option C (Correct): Banks must verify the identity of customers and beneficial owners to prevent financial crime risks.
Why Other Options Are Incorrect:
Option B (Incorrect): Numbered accounts are not strictly prohibited but require strict transparency and due diligence measures.
Option D (Incorrect): CDD procedures must be risk-based, not uniform across all customers.
Option E (Incorrect): Transactions should not be processed until full due diligence is completed, except in rare cases where regulatory exceptions apply.
Best Practices for Risk-Based Customer Due Diligence:
Apply EDD for high-risk entities (e.g., PEPs, offshore companies).
Ensure full beneficial ownership transparency.
Implement ongoing transaction monitoring for risk assessment.
Reference:
Basel Committee's "Sound Management of ML/TF Risks"
FATF Recommendation 10 (Customer Due Diligence)
6th EU AML Directive (6AMLD) on Beneficial Ownership Transparency

The Office of Foreign Assets Control (OFAC) is a US agency that administers and enforces economic and trade sanctions based on US foreign policy and national security goals1. OFAC has a list of sanctions programs and country information for various regions and topics, such as Russia, Iran, North Korea, Cuba, and more2. If a charity is headquartered in a country on the OFAC list, it means that the US government has imposed restrictions or prohibitions on transactions or dealings with that country, its government, entities, or individuals. This poses a high risk of violating the sanctions regulations and exposing the bank to legal, regulatory, or reputational consequences. Therefore, the bank may decide to terminate the banking relationship with the charity to avoid such risks.
The other options are not sufficient reasons to terminate the banking relationship, as they may not indicate illegal or suspicious activities by the charity. A high turnover rate of official positions may be due to various factors, such as organizational changes, staff turnover, or personal reasons. It does not necessarily imply that the charity is involved in money laundering or terrorist financing. However, the bank should verify the identity and authority of the new officials and update the customer due diligence information accordingly. The charity may have several incoming international funds transfers because it receives donations or grants from different sources or countries. This is not unusual for an international charity, as long as the funds are consistent with its stated purpose and activities. The bank should monitor the transactions and report any anomalies or red flags to the relevant authorities. The flow of funds both in and out may be complex and hard to trace because the charity operates in multiple jurisdictions or sectors, or has a decentralized or layered structure. This may increase the risk of money laundering or terrorist financing, but it does not necessarily mean that the charity is engaged in such activities. The bank should conduct enhanced due diligence and ongoing monitoring of the charity's transactions and beneficiaries, and apply a risk-based approach to mitigate the potential risks.: 1: Sanctions List Search Tool | Office of Foreign Assets Control 2: Sanctions Programs and Country Information | U.S. Department of the Treasury

Large and frequent credit balances on a credit card resulting in request for refunds is an indicator of suspicious activity because it may suggest that the cardholder is using the credit card to launder money or to conceal the source of funds. This is also known as credit card refund fraud or credit card laundering. The cardholder may make purchases with the credit card using illicit funds, then request refunds to another account or in cash, thus transferring the funds to a legitimate or less traceable channel. This activity may also be used to evade currency reporting requirements or to avoid detection by law enforcement or financial institutions.
:
ACAMS Study Guide for the CAMS Certification Examination, 6th Edition, Chapter 2: Money Laundering Risks and Methods, page 381 Suspicious Activity Reporting Indicators and Examples, U.S. Department of Homeland Security, Indicator 14:
Excess Purchases or Transactions2
Credit Card Laundering, Money Laundering Bulletin, Issue 245, October 2019

According to the Anti-Money Laundering Specialist (the 6th edition) study guide, one of the best practices for hiring an AML officer is to do a thorough background check, including verifying the candidate's credentials, qualifications, references, and reputation1. This is because the AML officer plays a crucial role in ensuring the compliance and integrity of the financial institution, and therefore must have the necessary skills, knowledge, experience, and ethics to perform the job effectively and professionally. A background check can also help to identify any potential conflicts of interest, criminal records, or regulatory sanctions that may affect the candidate's suitability for the position1. The other options are incorrect because:
* B. Confering with the regulatory agency may not be necessary or appropriate, as the hiring decision is ultimately the responsibility of the financial institution, and the regulatory agency may not have any specific or relevant information or guidance on the candidate2.
* C. Hiring the individual, relying on the recommendation of the correspondent, may not be sufficient or prudent, as the correspondent may have different standards, expectations, or interests than the financial institution, and may not have conducted a comprehensive or objective assessment of the candidate3.
* D. Hiring the individual on a probationary basis may not be feasible or fair, as the AML officer role requires a high level of trust, authority, and responsibility, and the financial institution may not be able to evaluate the candidate's performance or potential in a short period of time4.
:
1: ACAMS, CAMS Certification Package - 6th Edition, Chapter 5, page 147
2: ACAMS, CAMS Certification Package - 6th Edition, Chapter 5, page 148
3: ACAMS, CAMS Certification Package - 6th Edition, Chapter 5, page 147
4: ACAMS, CAMS Certification Package - 6th Edition, Chapter 5, page 148

The branch manager should conduct further investigation before taking any other action, as this activity may indicate possible money laundering or fraud. The branch manager should review the transaction records of the customers and the teller, and look for any unusual or suspicious patterns, such as large or frequent cash deposits, round amounts, structured transactions, or inconsistent information. The branch manager should also interview the teller and the customers, and ask them about the nature and purpose of their relationship, the source and use of funds, and the reason for choosing the same teller. The branch manager should document the findings and report any suspicious activity to the appropriate authorities, if necessary.
:
CAMS Study Guide, 6th Edition, Chapter 3, Section 3.21
CAMS Study Guide, 6th Edition, Chapter 4, Section 4.21
CAMS Exam Questions and Free Practice Test, Question 322