The three statements from the procedure that are in line with Wolfsberg are:
B). The responsible private banker must establish the identity of a holder of general powers over an account (e.
g. a signatory for the account) and, as appropriate, verify that identity. This is consistent with the Wolfsberg Principle 1.2.1, which states that the bank will establish the identity of its clients and beneficial owners prior to establishing business relationships with such persons1.
D). The responsible private banker must obtain the necessary documentation establishing the authorized signer' s authority to act on behalf of the account holder or beneficial owner (e.g. a Power of Attorney). This is consistent with the Wolfsberg Principle 1.2.3, which states that the bank will obtain the necessary documentation establishing the authority of the authorized signatory to act on behalf of the client or beneficial owner1.
E). If an individual has signing authority over an account but does not act on a professional basis as a manager of funds, the responsible private banker must understand and document the relationship between that authorized signer, the account holder, and, if different, the beneficial owner of the account. This is consistent with the Wolfsberg Principle 1.2.4, which states that the bank will understand and document the relationship between the authorized signatory, the client and, if different, the beneficial owner of the account1.
1: Wolfsberg Anti-Money Laundering Principles for Private Banking (2012)

Along-term, root cause-based approach ensures AML deficiencies are fully remediated.
* Option C (Correct):Addressing root causes ensures the institution remains compliant and prevents recurring violations.
* Option A (Incorrect):Consulting with an FIU is unnecessary for internal remediation plans.
* Option B (Incorrect):Short-term fixes do not resolve systemic AML issues.
* Option D (Incorrect):AML compliance improvements may require investment-cost-cutting should not compromise compliance.
Best Practices for AML Audit Remediation:
* Conduct root cause analysis before implementing corrective measures.
* Develop a long-term compliance improvement plan.
* Allocate sufficient resources for sustainable AML enhancements.
Reference:
FATF Recommendation 18 (AML Compliance & Internal Controls)
Wolfsberg Group Guidance on AML Audit Remediation
Basel Committee's AML Risk Management Guidelines

According to the ACAMS CAMS Study Guide (the 6th edition), one of the common methods of money laundering in the insurance sector is to purchase policies with illicit funds, overpay premiums, and then cancel or surrender the policies to receive refunds or payouts1. This allows criminals to move and disguise the source of their funds through the insurance company. Therefore, the regular withdrawals from the policy by the end of the month could indicate a money laundering scheme. Moreover, the FATF Guidance for a Risk-Based Approach for the Life Insurance Sector states that unidentified third parties depositing cash to the policy could also pose a high money laundering risk, as cash transactions are difficult to trace and third parties may act as intermediaries or nominees for the real beneficiaries2. Therefore, the insurance company should conduct enhanced due diligence on the policyholder and the third parties, and monitor the transactions for any suspicious activity.
References:
ACAMS CAMS Study Guide (the 6th edition), Chapter 2: Money Laundering Risks and Methods, page 671 FATF Guidance for a Risk-Based Approach for the Life Insurance Sector, pages 18-192

Thetimely filing of SARs is legally mandated, and financial institutions mustfollow jurisdiction-specific reporting deadlines.
Option A (Correct):Regulatory requirements dictate SAR filing deadlines(e.g., in the U.S., SARs must be filed within30 calendar daysof detecting suspicious activity).
Option B (Incorrect):30 days is the U.S. standard, but different jurisdictions may havedifferent SAR deadlines (e.g.,EU AMLD mandates prompt reporting).
Option C (Incorrect):Complexity-based reporting delaysare not permitted if theyexceed regulatory timelines.
Option D (Incorrect):Relying solely on professional judgmentrather than regulatory rules can lead tonon- compliance.
SAR Filing Deadlines in Different Jurisdictions:
Jurisdiction
SAR Filing Deadline
United States (FinCEN)
30 calendar days(60 days if no suspect is identified)
United Kingdom (FCA/NCA)
As soon as practicable
European Union (6AMLD)
"Promptly" (no fixed number of days)
Australia (AUSTRAC)
3 business daysfor terrorism financing,14 business daysfor other cases
Why Timely SAR Filing Matters:
Delays in reporting can result in regulatory penalties.
Early SAR filing enables FIUs to take swift action against financial crime.
Non-compliance can lead to fines, criminal charges, and reputational damage.
Reference:
FATF Recommendation 20 (Reporting Suspicious Transactions)
FinCEN SAR Filing Requirements
6th EU Anti-Money Laundering Directive (6AMLD)