Vendors and third-party relationships pose financial crime risks, particularly when theyoperate in sanctioned jurisdictions. Organizations must ensure thatthey are not directly or indirectly violating economic sanctionswhen engaging with vendors.
Option D (Correct):If a vendor provides services tosanctioned entities or individuals, an organizationrisks violating OFAC, EU, or UN sanctions laws, potentially leading tofines, legal action, or reputational damage.
Engaging in business in asanctioned regionrequires strictdue diligence and licensing.
Option A (Incorrect):Thepersonal backgroundof an employee isnot relevantunless theycurrently have direct ties to a sanctioned jurisdiction or person.
Option B (Incorrect):Alack of majority ownershipdoes not automatically indicateAML risk; however, organizations should still assessownership structures for opacity.
Option C (Incorrect):Privately held companiescan betransparentif theydisclose ownership and operate within compliance standards.
Why This Matters:
Failing toscreen vendors for sanctions riskscan result insevere penalties, reputational harm, and regulatory scrutiny.OFAC (U.S.), EU, and UN sanctions prohibit business transactions with specific countries, entities, and individuals. Organizations mustconduct thorough due diligencetoidentify and mitigate sanctions risks.
Reference:
OFAC Sanctions Guidelines & Compliance Framework
EU Sanctions Regulations
FATF Recommendation 6 (Targeted Financial Sanctions Related to Terrorism & Proliferation)

Money laundering and terrorist financing are both forms of financial crime that involve the movement of illicit funds. However, they differ in the source and purpose of the funds. Money laundering is the process of disguising the origin, ownership, or destination of funds that are derived from illegal activities, such as drug trafficking, fraud, or tax evasion. Terrorist financing is the provision or collection of funds, by legitimate or illegitimate means, for the purpose of carrying out terrorist acts. Therefore, the anti-money laundering specialist should consider the following factors in developing a compliance program:
Related practices are used to conceal the nature of the funds. Both money launderers and terrorist financiers use similar methods to hide the true identity, source, or destination of the funds, such as using shell companies, front organizations, complex transactions, cash couriers, or cryptoassets. A compliance program should include measures to identify and verify the customers, beneficial owners, and counterparties involved in the transactions, as well as to monitor and report any suspicious or unusual activities.
Similar techniques are used to move funds. Both money launderers and terrorist financiers use the same stages of placement, layering, and integration to move funds through the financial system. Placement is the introduction of illicit funds into the legitimate financial system, such as by depositing cash, purchasing assets, or transferring funds electronically. Layering is the separation of the funds from their source, such as by using multiple accounts, jurisdictions, or intermediaries. Integration is the re-entry of the funds into the legitimate economy, such as by investing in businesses, real estate, or securities. A compliance program should include measures to detect and prevent the movement of illicit funds through the financial system, such as by applying risk-based due diligence, record-keeping, and transaction limits.
CAMS Certification Package - 6th Edition | ACAMS
CAMS Certifications: How to Get CAMS Certified | ACAMS
ACAMS CAMS Certification Video Training Course - Exam-Labs
Exam CAMS: Certified Anti-Money Laundering Specialist (the6th edition)

The board of directors or designated specialized committee should be provided with statistical data regarding SARs filed during the reported period, such as the number, type, and amount of SARs, as well as any trends or patterns identified. This would enable them to oversee the effectiveness of the anti-money laundering program and ensure compliance with regulatory requirements. Providing too much detail, such as names of customers or copies of SARs, could compromise the confidentiality of the SARs and expose the institution to legal risks.
References:
ACAMS Study Guide for the CAMS Certification Examination, 6th Edition, Chapter 5, page 153, section
"Reporting to the Board of Directors or Designated Specialized Committee".
ACAMS CAMS Certification Video Training Course, Module 5, Lesson 5.4, "Reporting to the Board of Directors or Designated Specialized Committee".

The Basel Committee on Banking Supervision (BCBS) is an international body that sets standards and guidelines for the prudential regulation of banks. One of its key publications is the Customer Due Diligence for Banks, which outlines the essential elements of Know Your Customer (KYC) standards for banks.
According to this document, customer acceptance, customer due diligence, and record-keeping policies and procedures should be changed as necessary to address variations in risk among each line of business within the organization. This means that banks should adopt a risk-based approach to KYC, taking into account the different types, levels, and sources of risk associated with different customers, products, services, transactions, and delivery channels. By doing so, banks can allocate their resources more efficiently and effectively, and mitigate the potential for money laundering, terrorist financing, and other financial crimes.
References:
Customer Due Diligence for Banks, BCBS, October 2001, p. 5, 14-15.
The Basel Committee: The Important Set Of International Banking Regulations, Financial Crime Academy, November 2023.

The best course of action for the FI in this scenario is to consider retaining qualified, experienced legal counsel. This is because the investigation request from the local law enforcement agency may involve complex legal issues, such as confidentiality, privacy, data protection, and cooperation obligations. The FI may need to balance the interests of the customer, the law enforcement agency, and the FI itself, and ensure that it complies with the applicable laws and regulations in responding to the request. The legal counsel can advise the FI on the scope, validity, and implications of the request, and help the FI to prepare and submit the required information in a timely and appropriate manner. The legal counsel can also protect the FI from any potential liability or litigation arising from the investigation.
1: Requests by Law Enforcement for Financial Institutions to Maintain Accounts and/or Conduct Transactions1
2: Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations2
3: ACAMS Study Guide for the CAMS Certification Examination3