A politically exposed person (PEP) is a customer who requires the most enhanced due diligence (EDD). This is because PEPs are individuals who hold or have held prominent public positions, such as heads of state, senior politicians, judges, military officers, ordirectors of state-owned enterprises, and who may pose a higher risk of money laundering, corruption, or bribery due to their influence and access to public funds1. EDD measures for PEPs may include obtaining senior management approval, establishing the source of wealth and funds, and conducting enhanced ongoing monitoring of the business relationship2.
The other customers listed do not necessarily require the most EDD, although they may still present a higher risk of money laundering depending on the circumstances. A resident of a non-cooperative jurisdiction is a customer who lives in a country or territorythat has been identified by the Financial Action Task Force (FATF) or other international bodies as having weak or deficient anti-money laundering (AML) standards or posing a threat to the international financial system3. EDD measures for such customers may include obtaining additional information or documentation, applying extra scrutiny to transactions, or refusing to establish or continue the business relationship4. An international business corporation is a customer who operates in multiple jurisdictions and may have complex or opaque ownership structures that can conceal the identity or activity of the beneficial owners or controllers. EDD measures for such customers may include verifying the legal existence and structure of the entity, identifying the beneficial owners and controllers, and understanding the nature and purpose of the business relationship. An established customer is a customer who has a long-standing and regular business relationship with the financial institution and who may have a lower risk of money laundering due to the familiarity and trust that has been built over time. EDD measures for such customers may not be required unless there are changes in the customer's profile, behavior, or risk level.
1: Politically Exposed Persons (Recommendations 12 and 22) - FATF1 2: High-risk customers, including politically exposed persons | FCA2 3: High-Risk and Other Monitored Jurisdictions - FATF3 4: Your responsibilities under money laundering supervision | GOV.UK4 : International Business Corporations - ACAMS : Anti-Money Laundering Customer Due Diligence | Veriff.com : Customer Due Diligence - ACAMS : Anti-money laundering - a guide to customer due diligence

According to the Anti-Money Laundering Specialist (the 6th edition) resources, one of the essential elements of an effective AML program is the establishment of a written AML policy that sets out the bank's commitment to comply with the applicable AML laws and regulations, as well asthe roles and responsibilities of the board of directors, senior management, and staff in implementing the AML program. The AML policy should also include the bank's risk assessment, customer due diligence, transaction monitoring, record keeping, reporting, training, and audit procedures. The AML policy should be approved by the board of directors and communicated to all staff from the top down. The other options are not incorrect, but they are not the primary responsibility of the board of directors in demonstrating commitment to AML compliance.
References:
1: ACAMS Study Guide for the Certified Anti-Money Laundering Specialist (the 6th edition), Chapter 8: Anti- Money Laundering Programs, page 221.
2: ACAMS Study Guide for the Certified Anti-Money Laundering Specialist (the 6th edition), Chapter 8: Anti- Money Laundering Programs, page 224.

Structured transactions are a common method of money laundering, where large amounts of cash are broken down into smaller deposits or withdrawals to avoid reporting thresholds or detection. The most effective tool to detect such transactions is a software program that can link apparently unrelated transactions by using various criteria, such as customer name, address, account number, identification number, transaction amount, date, time, location, etc. Such a program can help identify patterns, trends, and anomalies that may indicate money laundering activity.
ACAMS CAMS Certification Study Guide1, Chapter 2: Money Laundering Risks and Methods, Section 2.2:
Common Money Laundering Methods, pp. 51-52
ACAMS CAMS Certification Video Training Course2, Module 2: Money Laundering Risks and Methods, Lesson 2.2: Common Money Laundering Methods ACAMS CAMS Certification Exam Outline3, Domain 2: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), Task 2.2: Implement risk-based CDD, EDD and ongoing due diligence policies, procedures and processes, p. 13

A startup virtual currency exchange that operates as a money services business (MSB) must comply with the anti-money laundering (AML) regulations and standards applicable to MSBs, such as the Bank Secrecy Act (BSA) in the United States. One of the key requirements for MSBs is to develop and implement an effective AML compliance program that covers the following four pillars: internal controls, independent testing, designated compliance officer, and training12.
Before launching its operations, the startup should consider the following two AML responsibilities that are essential for its compliance program:
A customer onboarding process: The startup should establish a customer identification program (CIP) that verifies the identity of its customers and collects relevant information, such as name, address, date of birth, and identification number12. The startup should also perform customer due diligence (CDD) and enhanced due diligence (EDD) for higher-risk customers, such as those who engage in large or frequent transactions, use anonymous or pseudonymous digital wallets, or originate from high-risk jurisdictions34. The startup should also screen its customers against sanctions lists and other watchlists to prevent dealing with prohibited or suspicious entities12.
Transaction limits consistent with risk appetite: The startup should set appropriate transaction limits for its customers based on its risk assessment and risk appetite. Transaction limits can help mitigate the exposure to money laundering and terrorist financing risks, as well as comply with the reporting and recordkeeping obligations under the BSA. For example, the startup should report any cash transactions over $10,000 or any suspicious transactions over$2,000 to the Financial Crimes Enforcement Network (FinCEN)12. The startup should also monitor its customers' transactions for any unusual or inconsistent patterns or behaviors that may indicate money laundering or other illicit activities34.
1: ACAMS CAMS Certification Package - 6th Edition, Chapter 6: AML Compliance Program, pp. 139-1461
2: ACAMS CAMS Certification Video Training Course, Module 6: AML Compliance Program, Lesson 6.1:
The Four Pillars of an AML Compliance Program3
3: ACAMS CAMS Certification Package - 6th Edition, Chapter 4: Customer Due Diligence, pp. 87-1061
4: ACAMS CAMS Certification Video Training Course, Module 4: Customer Due Diligence, Lesson 4.1:
CustomerIdentification Program and Lesson 4.3: Enhanced Due Diligence3

This potential action is authorized by Section 319 of the USA PATRIOT ACT, which allows the U.S.
government to seize funds from a foreign bank's correspondent account in the U.S. if the foreign bank refuses to cooperate with a request for records relating to an investigation of money laundering or terrorist financing.
The U.S. government can seize an amount equal to the funds in the account of the target of the investigation, regardless of whether those funds are actually in the correspondent account. In this case, the U.S. government can seize $1 million from Bank A's correspondent account in the U.S. because Bank A holds $1 million in the account of the WTS, which is the target of the forfeiture action.
The other potential actions are not authorized by the USA PATRIOT ACT or other U.S. laws. The U.S.
government cannot seize Bank A's entire $5 million correspondent account in the U.S. because that would exceed the amount in the WTS's account andwould violate the principle of proportionality. The U.S.
government cannot seize the WTS's $1 million account at the non-U.S. branch of Bank A because that would require the cooperation of the foreign jurisdiction where the branch is located, which may not be forthcoming.
The U.S. government cannot seize $5 million from the non-U.S. branch of Bank A where the WTS's account is located because that would also require the cooperation of the foreign jurisdiction and would exceed the amount in the WTS's account.
CAMS Certification Package - 6th Edition | ACAMS, Chapter 3: International Standards and Global Initiatives, pp. 67-68 CAMS Certifications: How to Get CAMS Certified | ACAMS, CAMS Study Guide, pp. 54-55 How Does the Patriot Act Affect Criminal Investigations? | Nolo, Section 319: Forfeiture of Funds in United States Interbank Accounts The USA PATRIOT Act at 20: Sneak and Peek Searches - CRS Reports, Section 319: Forfeiture of Funds in United States Interbank Accounts