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).

The financial institution should freeze the funds or assets of designated persons and entities once this decision is approved by the Board. This is to comply with the obligation to implement targeted financial sanctions imposed by the United Nations Security Council (UNSC) or other relevant authorities. Freezing means preventing any access, use, transfer, or disposal of the funds or assets by the designated persons and entities or by any other person on their behalf. The financial institution should also report the freezing action to the competent authority and the relevant sanctions committee12.
Option A is not a sufficient step to comply with sanctions requirements, but rather a tool to facilitate compliance. Adopting automatic screening systems to detect designated persons and entities can help the financial institution to identify potential matches and flag them for further investigation. However, screening systems are not infallible and may generate false positives or false negatives. Therefore, the financial institution should also conduct manual checks and verification of the screening results13.
Option B is not a relevant step to comply with sanctions requirements, but rather a measure to mitigate money laundering and terrorist financing risks. Conducting enhanced due diligence for prohibited entities on the sanctions list may be useful to obtain more information about the nature and purpose of the business relationship, the source and destination of the funds, and the beneficial ownership and control structure of the entity. However, enhanced due diligence does not replace the obligation to freeze the funds or assets of the designated persons and entities14.
Option C is not an appropriate step to comply with sanctions requirements, but rather a violation of the obligation to freeze the funds or assets of the designated persons and entities. Changing the risk profile to
"high-risk" if an existing customer becomes a sanctioned entity and continuing to monitor further transactions may expose the financial institution to legal and reputational risks, as well as potential sanctions evasion or circumvention. The financial institution should terminate the business relationship with the designated person or entity and freeze their funds or assets without delay1 .
References: 1: ACAMS (2020), Study Guide for the Certification Examination, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams-certification-package-6th-edition, pp. 47-49. 2: ACAMS (2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams- certification-package-6th-edition, Module 2, Section 2.4.1. 3: ACAMS (2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams-certification-package-
6th-edition, Module 2, Section 2.4.2. 4: ACAMS (2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams-certification-package-6th-edition, Module 2, Section
2.4.3. : ACAMS (2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams-certification-package-6th-edition, Module 2, Section 2.4.4.

Banks within theEUmust comply withAML laws and data privacy regulationsbefore sharing customer data.
* Option D (Correct):Information sharing should belimited to what is necessary and proportionate, followingGDPR and AMLDregulations.
* Option A (Incorrect):AML laws allowinformation-sharing in certaincross-border investigations.
* Option B (Incorrect):Whilelegal review is necessary, aproduction order is not always requiredforAML- related information sharing.
* Option C (Incorrect):Data protection laws (e.g., GDPR) must still be respected, even in financial crime investigations.
Reference:EU General Data Protection Regulation (GDPR), 6th Anti-Money Laundering Directive (6AMLD), FATF Recommendation 40 (International Cooperation).

an employee who avoids taking periodic vacations despite having accrued vacation time may be trying to conceal fraudulent or illegal activities that would be exposed in their absence. This is a common red flag for internal fraud and money laundering, as it indicates a lack of segregation of duties, internal controls, and oversight. Employees who engage in such behavior may also exhibit other signs of stress, defensiveness, or secrecy.
Learn about red flags for internal fraud, section "An employee may be a higher internal fraud risk when a combination of the following red flags are present", bullet point 1: "Unwilling to share duties or take leave." Money Laundering Red Flags | Key Behaviours and Indicators, section "Employee Red Flags", bullet point 1:
"Avoiding taking holidays or time off work."
Top 10 AML Red Flags: Warning Signs and Financial Risks, section "AML Red Flags Categories", sub- section "Employee Red Flags", bullet point 1: "Avoiding taking vacations or sick leaves."