An FIU is a central, national agency responsible for receiving, analyzing, and disseminating to the competent authorities disclosures of financial information concerning suspected proceeds of crime and potential financing of terrorism or required by nationallegislation or regulation1. FIUs play a crucial role in the detection and prevention of money laundering and terrorist financing by collecting, processing, and analyzing financial intelligence and sharing it with domestic and foreign counterparts2. FIUs may have different organizational structures, functions, and legal frameworks, but they all adhere tothe international standards and best practices set by the Egmont Group of FIUs3.
What We Do | FinCEN.gov
Financial Intelligence Units: An Overview (June 2004) - IMF, page 1
[Egmont Group of Financial Intelligence Units]
Reference: https://www.fatf-gafi.org/media/fatf/content/images/National_ML_TF_Risk_Assessment.pdf

According to the Anti-Money Laundering Specialist (the 6th edition) by ACAMS, an institution's anti-money laundering program should be reassessed at least annually to ensure that it is current, effective, and compliant with the applicable laws and regulations. The reassessment should include a review of the institution's risk assessment, policies and procedures, internal controls, training, and independent testing. The reassessment should also consider any changes in the institution's products, services, customers, geographic locations, or business environment that may affect its exposure to money laundering and terrorist financing risks1.
The other options are not consistent with the best practices of maintaining an up-to-date anti-money laundering program. For example:
The program should be evaluated and updated at least every six months by the Board of Directors. While the Board of Directors has the ultimate responsibility for overseeing the institution's anti-money laundering program, it is not required to evaluate and update the program every six months. This may be too frequent and impractical, especially for large and complex institutions. The Board of Directors should, however, approve the program and any significant changes, and ensure that senior management implements and enforces the program effectively1.
The program should be reviewed by a federal law enforcement officer for gaps in controls. While federal law enforcement agencies may conduct investigations or examinations of the institution's anti-money laundering program, they are not responsible for reviewing the program for gaps in controls. This is the role of the institution's internal audit function or an external independent party, who should conduct periodic testing of the program's adequacy and effectiveness1.
The program should be sent to the institution's government regulator on a periodic basis. While the institution' s government regulator may request or review the institution's anti-money laundering program as part of its supervisory or enforcement activities, the institution is not obligated to send the program to the regulator on a periodic basis. The institution should, however, report any suspicious or unusual transactions or activities to the relevant authorities, such as the Financial Crimes Enforcement Network (FinCEN) or the Office of Foreign Assets Control (OFAC)1.
Anti-Money Laundering Specialist (the 6th edition) by ACAMS

A compliance officer should consider the following three factors as part of the approach to implement an enterprise-wide anti-money laundering program for a bank that operates in multiple countries:
* The types of customers serviced by the bank: Different types of customers may pose different levels of money laundering risk, depending on their nature, source of funds, geographic location, transaction patterns, and other factors. A compliance officer should identify and assess the money laundering risk associated with each customer type and segment, and apply appropriate due diligence measures, monitoring systems, and risk mitigation strategies accordingly12.
* The extent of anti-money laundering regulations in the various countries: A compliance officer should be aware of the legal and regulatory requirements and expectations for anti-money laundering compliance in each country where the bank operates, and ensure that the bank's policies and procedures are consistent with them. A compliance officer should also monitor any changes or updates in the anti- money laundering laws and regulations in the various countries, and adjust the bank's program accordingly34.
* The anti-money laundering risk posed by the products and services offered by the bank: Different products and services may have different features and functionalities that could be exploited by money launderers, such as anonymity, cross-border transfers, cash transactions,complex structures, or new technologies. A compliance officer should evaluate the money laundering risk associated with each product and service offered by the bank, and implement appropriate controls, safeguards, and oversight mechanisms to prevent and detect money laundering activities5 .
1: ACAMS, CAMS Study Guide, 6th Edition, Chapter 2: Risk Assessments
2: FATF, Guidance for a Risk-Based Approach: The Banking Sector
3: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT)
4: Deloitte, AML Program Effectiveness Reform
5: ACAMS, CAMS Study Guide, 6th Edition, Chapter 4: AML Program Design
[6]: OCC, Money Laundering: A Banker's Guide to Avoiding Problems
Reference: https://www.fatf-gafi.org/publications/mutualevaluations/documents/more-about-mutual- evaluations.html

Effective oversight of transaction monitoring includes:
* Periodic review of client profiles to ensure up-to-date information for high-risk clients (B):
"Reviewing and updating customer profiles is essential to ensure that monitoring scenarios are based on current risk data."(CAMS 6th Edition, Transaction Monitoring and Customer Due Diligence)
* Periodic review of transaction monitoring scenarios and productivity to ensure appropriate AML typologies are reflected (D):"Firms should periodically review the parameters and output of transaction monitoring systems to ensure they continue to identify relevant ML/TF risks and typologies."(CAMS 6th Edition, Monitoring and Surveillance) Incorrect Options:
* A: Cooperation with the legal team is important, but not a core strategy for monitoring governance.
* C: SARs filed with FinCEN should not be withdrawn unless new evidence requires it; review should focus on process, not withdrawal.
References:
CAMS 6th Edition, Transaction Monitoring
FFIEC BSA/AML Manual, Transaction Monitoring Section

Wire stripping is the process of removing or altering the identifying information associated with a wire transfer to make it difficult to trace the origin or destination of the funds. This technique is commonly used in money laundering schemes to conceal the illicit source of funds and avoid detection by authorities or sanctions screening systems. In this case, the bank's operations team deliberately removed the reference to the sanctioned company from the wire transfer message, thus violating the FinCEN "Travel Rule" and facilitating the evasion of sanctions.
Wire Stripping in Anti Money Laundering Parlance
Wire Transfer Red Flags: Understanding Money Laundering and Fraud Risks Wire Stripping