According to a report by the OECD, government officers are among the occupations that are particularly vulnerable to the use of false identities and identity theft. This is because government officers have access to sensitive and confidential information, such as personal data, tax records, social security benefits, passports, visas, and licenses. Identity fraudsters may target government officers to obtain or alter such information, or to impersonate them to access restricted areas or systems. Identity fraud involving government officers may facilitate tax evasion, money laundering, corruption, terrorism, and other crimes1.
Some examples of identity fraud schemes involving government officers are:
Rogue agents in the immigration services sector who issue fake or fraudulent documents, such as passports, visas, orresidence permits, to facilitate the entry or stay of illegal immigrants, criminals, or terrorists12.
Corrupt tax officials who use false identities to create fictitious taxpayers or employers, or to modify tax records, to evade taxes or to claim fraudulent refunds or credits13.
Impostors who pose as government officers, such as police, customs, or revenue agents, to extort money or information from unsuspecting victims, or to access secure facilities or databases1 .
REPORT ON IDENTITY FRAUD: TAX EVASION AND MONEY LAUNDERING VULNERABILITIES Identity Fraud and Immigration Services Identity Theft and Tax Fraud
[Identity Theft and Government Impersonation Scams]

One of the core components of a strong AFC (Anti-Financial Crimes) compliance program is establishingclear roles, responsibilities, and lines of accountability, especially forescalating and addressing AFC risks and compliance issues. This governance clarity ensures effective implementation, transparency in decision-making, and timely resolution of compliance concerns.
While external audits (option A) and internal controls (option B) are important,defining governance structure and escalation responsibilities (option D)is a foundational element. Additionally, the board of directors (option C) provides oversight-not day-to-day compliance monitoring.
Reference: ACAMS CAMS Study Guide - 6th Edition, Chapter: Compliance Program Structures - Section:
Governance and Oversight Functions

as there's NO mitigating control, the temporary control system must be developed and implemented until the permanent mitigating control is developed and implemented.

The USA PATRIOT Act of 20011 is a comprehensive anti-terrorism and anti-money laundering legislation that grants various powers and authorities to the US government to combat money laundering, terrorist financing, and other financial crimes. Among its provisions, Title III of the Act, also known as the International Money Laundering Abatement and Anti-Terrorist Financing Act of 20012, specifically addresses the issue of correspondent banking and the risks of money laundering and terrorist financing through foreign banks that maintain accounts with US banks. Section 319 of Title III3 authorizes the US Attorney General or the Secretary of the Treasury to issue a subpoena or summons to any foreign bank that maintains a correspondent account in the US, and to request any records relating to such account, including records maintained outside the US. Furthermore, Section 319(b) of Title III4 allows the US authorities to seize the funds of the foreign bank held with the US bank, if the foreign bank fails to comply with such a subpoena or summons, or if the US authorities initiate a civil forfeiture action against the funds in the correspondent account. Therefore, the USA PATRIOT Act is the correct answer, as it enables the US authorities to seize the funds of the foreign bank held with the US bank, if the correspondent account is found to have facilitated a transaction involving tainted funds.
References:
USA PATRIOT Act
Title III of the USA PATRIOT Act
Section 319(a) of the USA PATRIOT Act
Section 319(b) of the USA PATRIOT Act