A deferred prosecution agreement (DPA) is a type of enforcement action that allows a financial institution to avoid criminal prosecution if it admits to wrongdoing, pays a fine, and agrees to remediate its AML program deficiencies within a specified period of time1. A cease and desist order (C&D) is another type of enforcement action that requires a financial institution to stop engaging in unsafe or unsound practices or violations of law, and to take corrective actions to address its AML program weaknesses2. Both of these actions are commonly used by regulators to address serious or systemic AML program failures by financial institutions, as evidenced by recent cases345.
References:
1: Deferred Prosecution Agreement - Wikipedia
2: FFIEC BSA/AML Appendices - Appendix R - Enforcement Guidance
3: FinCEN Announces $15 Million Civil Money Penalty against Bancredito International Bank for Willful Violations of the Bank Secrecy Act
4: Lessons From The Seven Largest AML Bank Fines In 2021
5: Fines for AML Compliance Failures - ACAMS Today

The investigator should escalate these concerns to the bank anti-money laundering officer, who is responsible for overseeing the implementation and effectiveness of the bank's AML/CFT policies and procedures, as well as ensuring compliance with relevant laws and regulations. The bank anti-money laundering officer can then decide on the appropriate course of action, such as conducting further investigation, reporting to the regulators, or terminating the relationship with the customer. The other options are not suitable for escalating these concerns, as they may not have the authority, expertise, or responsibility to handle such matters.
ACAMS, CAMS Examination Study Guide, 6th Edition, Chapter 4, pp. 113-114 FATF Guidance: The Role of Hawala and Other Similar Service Providers in Money Laundering and Terrorist Financing, October 20131, p. 19 Basel Committee on Banking Supervision, Sound management of risks related to money laundering and financing of terrorism, June 20172, p. 10

According to the Basel Committee on Banking Supervision, a sound KYC program should include four essential elements: customer acceptance policy, customer identification, on-going monitoring of higher risk accounts, and risk management1. Customer acceptance policy defines the types of customers that the financial institution (FI) is willing to accept and the criteria for doing so. Customer identification involves verifying the identity and beneficial ownership of the customers and obtaining information on their activities and sources of funds. On-going monitoring of higher risk accounts involves reviewing the transactions and behavior of the customers that pose higher risks of money laundering or terrorist financing and updating their information and risk profiles. Risk management involves establishing appropriate policies, procedures, controls, and audit functions to ensure the effective implementation and oversight of the KYC program1.
1: Basel Committee on Banking Supervision - Bank for International Settlements1

According to the Basel Committee on Banking Supervision principles, the most important question the banker should ask when opening a numbered or alternate name account is who will control the account. This is because such accounts pose a higher risk of money laundering and terrorist financing, as they can be used to conceal the identity and beneficial ownership of the funds. Therefore, the banker should perform enhanceddue diligence and verify the identity and source of funds of the person who has the authority to operate the account, as well as the purpose and nature of the business relationship12 The other questions are less relevant or secondary to the issue of control. The inheritance of the proceeds in the event of the businessman's death is a matter of succession law and does not affect the identification of the beneficial owner. The amount of money deposited into the account may indicate the level of risk, but does not reveal the origin or destination of the funds. The account-opening date is a procedural detail thatdoes not affect the compliance with the anti-money laundering and counter-terrorist financing standards12
1: Basel Committee on Banking Supervision - Core principles for effective banking supervision, 2012, Principle 14 and Essential Criterion 14.1
2: Basel Committee on Banking Supervision - Sound management of risks related to money laundering and financing of terrorism, 2014, Paragraphs 30 and 31

Banks within theEUmust comply withAML laws and data privacy regulationsbefore sharing customer data.
* Option D (Correct):Information sharing should belimited to what is necessary and proportionate, followingGDPR and AMLDregulations.
* Option A (Incorrect):AML laws allowinformation-sharing in certaincross-border investigations.
* Option B (Incorrect):Whilelegal review is necessary, aproduction order is not always requiredforAML- related information sharing.
* Option C (Incorrect):Data protection laws (e.g., GDPR) must still be respected, even in financial crime investigations.
Reference:EU General Data Protection Regulation (GDPR), 6th Anti-Money Laundering Directive (6AMLD), FATF Recommendation 40 (International Cooperation).