Submitting the concern anonymously to the bank's internal Compliance Hotline is the most appropriate action that a bank CEO's assistant should take when the bank CEO expenses large sums of money to a charitable organization run by the bank CEO's direct family member. This is because this action would allow the assistant to report a potential case of fraud, conflict of interest, or misuse of funds without fear of retaliation or reprisal from the bank CEO. The Compliance Hotline is a confidential and secure channel for employees to raise any concerns or suspicions about unethical or illegal activities within the bank. The Compliance Hotline would then forward the concern to the relevant authorities or departments for further investigation and action.
= The main references for this question are the following sources:
The document titled "Anti-Fraud Policy" published by the World Bank Group. You can access it by clicking here. This document states that "The World Bank Group has established a Compliance Hotline to receive reports of suspected fraud or corruption in World Bank Group-financed projects or activities, or in the World Bank Group's corporate procurement or administrative activities. The Compliance Hotline is available to all staff and external parties, such ascontractors, consultants, beneficiaries of World Bank Group-financed projects, and the general public.

"Increasingly, countries are using economic sanctions instead of military force as an instrument of foreign policy" Reference: https://en.wikipedia.org/wiki/Economic_sanctions

* A: FIs should ensure they have a general understanding of virtual assets and VASP operations to assess risks accurately.
* C: Enhanced KYC measures are recommended for VASPs due to their higher ML/TF risk profile.
* "FIs must understand the business model and risk of VASPs and apply enhanced due diligence as required by FATF and regulatory guidance."(CAMS 6th Edition, Virtual Assets and VASPs; FATF Guidance) Incorrect:
* B: While monitoring transactions is important, it's not a primary initial consideration for onboarding.
* D: The FI's own holdings are not relevant to due diligence on VASPs.
References:
CAMS 6th Edition, Virtual Assets and VASPs
FATF, Guidance for a Risk-Based Approach to Virtual Assets and VASPs

According to the ACAMS Study Guide, an effective AML program should include four key elements:
internal controls, independent testing, designated compliance officer, and training1. Internal controls are policies, procedures, and processes that help prevent, detect, and report money laundering and terrorist financing activities. One of the essential components of internal controls is customer due diligence (CDD), which involves identifying and verifying the customer, understanding the nature and purpose of the customer relationship, and conducting ongoing monitoring of customer transactions and risk profiles2. Ongoing monitoring is crucial for detecting and reporting suspicious activities, updating customer information, and reassessing customer risk ratings3.
In this case, the bank's written AML program does not address monitoring of customer account activity, which is a significant gap in its internal controls. The bank serves high-income, high net-worth clients who include non-residents and offshore businesses, which are considered high-risk customers for AML purposes4. The bank should have enhanced due diligence (EDD) measures for these customers, such as obtaining additional information, conducting more frequent reviews, and applying stricter transaction limits5.
The fact that the consultant and the bank have mutual clients does not affect the risk rating or the due diligence requirements of those customers. Therefore, the consultant should recommend the bank to revise its procedures to better assess ongoing customer activity and comply with the AML standards.
1: ACAMS Study Guide, Chapter 2: Developing an Effective Anti-Money Laundering Program
2: ACAMS Study Guide, Chapter 3: Conducting Customer Due Diligence
3: ACAMS Study Guide, Chapter 4: Ongoing Monitoring and Suspicious Activity Reporting
4: ACAMS Study Guide, Chapter 5: Identifying High-Risk Customers
5: ACAMS Study Guide, Chapter 6: Applying Enhanced Due Diligence Measures