AML audit findings must be analyzed and addressed through remedial actions based on root cause analysis.
Option D (Correct): Root cause analysis helps develop effective corrective measures to prevent recurring AML deficiencies.
Option A (Incorrect): Retesting controls may be useful, but addressing deficiencies is more critical.
Option B (Incorrect): While the board oversees compliance, the responsibility for implementing fixes lies with AML teams.
Option C (Incorrect): Audit teams provide findings but do not execute corrective actions.
Best Practices for Addressing AML Audit Findings:
Identify the root cause of AML control failures.
Develop risk-based remediation plans.
Implement and monitor corrective actions.
Reference:
FATF Recommendation 18 (AML Internal Controls & Audit)
Basel Committee's Guidelines on AML Audits
Wolfsberg Group Principles for AML Risk Management
Final Thoughts:
Suspicious stock price movements can indicate market manipulation linked to money laundering.
EU AML and GDPR regulations enforce strict data minimization and AI compliance requirements.
Bearer shares, nominee directors, and tax-haven corporations increase money laundering risks.
AML audit findings should be addressed through root cause analysis and corrective actions.

FIs must handlelaw enforcement subpoenas carefullytocomply with legal and AML obligations.
Option A (Correct):Legal counsel must review subpoenasto ensure compliance withAML and privacy laws.
Option B (Incorrect):Original documentsshould only be provided underspecific legal conditions.
Option C (Incorrect):Account closure decisionsmust followAML risk-based assessment.
Option D (Incorrect):Tipping offa customer about an investigation isillegalunder AML laws.
Reference:FinCEN Subpoena Compliance Guidelines, U.S. Bank Secrecy Act (BSA) Subpoena Rules, FATF Recommendation 40 (International Cooperation).

Structuring transactions is a common method of money laundering, where cash deposits or withdrawals are broken down into smaller amounts to avoid reporting or record-keeping requirements. Employees who unintentionally assist customers in structuring transactions may not be aware of the legal and regulatory implications of their actions, or may have been misled or coerced by the customers. Therefore, the most appropriate and proportionate response is to provide remedial training to these employees, to ensure they understand the anti-money laundering policies and procedures, the red flags of suspicious activity, and their reporting obligations. Terminating, contacting law enforcement, or transferring these employees may be excessive, premature, or ineffective measures, depending on the circumstances and the level of involvement of the employees.
ACAMS Study Guide for the CAMS Certification Examination - 6th Edition, Chapter 2: Money Laundering Risks and Methods, page 31.
ACAMS CAMS Certification Video Training Course, Module 2: Money Laundering Risks and Methods, Lesson 2.3: Structuring and Smurfing.

According to the CAMS Study Guide, EDD is a higher level of scrutiny applied to customers who pose a greater risk of money laundering or terrorist financing. EDD may include obtaining additional information on the customer's identity, source of funds, businessactivities, beneficial owners, and expected transactions.
Details on individuals with control over the account are relevant for EDD, as they may indicate the involvement of politically exposed persons (PEPs), sanctioned individuals, or other high-risk entities.
Therefore, this information should be gathered as part of EDD for a high-risk customer.
CAMS Study Guide, 6th Edition, Chapter 4, page 121.
Reference: https://sanctionscanner.com/knowledge-base/customer-due-diligence-cdd-15

When seekinglegal evidence across borders,MLATsare themost formal and effective mechanism.
Option A (Correct):MLATsprovide alegal frameworkfor exchangingevidence in criminal investigations.
Option B (Incorrect):TheEgmont Secure Webfacilitatesintelligence sharing between FIUs, butnot legal evidence.
Option C (Incorrect):INTERPOL focuses on law enforcement cooperation, but not formalevidence gathering for prosecutions.
Option D (Incorrect):Direct requestsbetween anti-corruption authorities may not havelegal standing in court.
Reference:FATF Recommendation 40 (International Cooperation), UN Convention Against Corruption (UNCAC), Mutual Legal Assistance Treaties (MLATs).