* A: "Hawala and similar informal value transfer systems are difficult to monitor, making it challenging to identify the originator, recipient, and source of funds."
* D: "Hawala operates through informal networks for cross-border transfers, often outside the formal banking system, increasing AML/CFT risk."(CAMS 6th Edition, Alternative Remittance Systems; FATF, Guidance on Money Transfer Services) References:
CAMS 6th Edition, Money Transfer and Informal Value Transfer Systems
FATF, Alternative Remittance Systems Guidance

Screening customers at onboarding and quarterly thereafter is not sufficient to ensure compliance with economic sanctions, as sanctions lists may change frequently and the financial institution may not be aware of the latest updates. Screening should occur promptly after list updates to ensure that the financial institution is not dealing with a sanctioned individual or entity, or facilitating a prohibited transaction. This is recommended by the international guidance from the Financial Action Task Force (FATF) and the Wolfsberg Group12. Screening and performing enhanced due diligence on new relationships is also important, but not the only step to ensure compliance.
CAMS Certification Package - 6th Edition | ACAMS, Chapter 3: Sanctions, page 86 The Wolfsberg Group Correspondent Banking Due Diligence Questionnaire 2014, Section 5: Sanctions Policy, page 12 ACAMS CAMS Certification Video Training Course - Exam-Labs, Video 3.1: Sanctions Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition), Question 109 The European Union Fourth Anti-Money Laundering Directive (4th AMLD) is a legal framework that aims to prevent the use of the Union's financial system for the purposes of money laundering and terrorist financing.
One of the provisions of the 4th AMLD is to lower the currency threshold for cash payments from €15,000 to
€10,000. This means that any person who makes or receives cash payments of €10,000 or more, whether in a single transaction or in several linked transactions, is subject to customer due diligence and record-keeping obligations. The 4th AMLD also extends its applicability to providers of gambling services, which are now listed as 'obliged entities'.
References:
Directive - 2015/849 - EN - Fourth Anti-Money Laundering Directive - EUR-Lex, Article 11 and Recital 23.
EUR-Lex - 02015L0849-20210630 - EN - EUR-Lex, Article 11 and Recital 23.
Key elements of the 4th EU Anti-Money Laundering Directive, Section: Cash payments.
Anti-money laundering and countering the financing of terrorism legislative package, Section: New EU AML
/CFT Regulation.

According to the Financial Action Task Force (FATF), a financial institution must take certain steps to fulfill its customer due diligence (CDD) obligations [1][2]. These steps include verifying the customer's identity, understanding the customer's business, and assessing the customer's risk profile. Additionally, the financial institution must verify that the customer is not on any sanction lists, such as the OFAC Specially Designated Nationals list. This step is important to ensure that the financial institution is not doing business with any individuals or entities that are subject to economic sanctions. Other steps include obtaining information on the intended nature of the banking relationship, securing a written declaration from the customer confirming the source of the funds, and identifying shareholders listed on the stock exchange of corporate entities holding fifty percent of the shares.

shell banks are banks that have no physical presence in any country and are not affiliated with any regulated financial institution. They are often used by money launderers and terrorist financiers to hide their illicit activities and evade regulatory oversight. The USA PATRIOT Act prohibits US financial institutions from opening or maintaining correspondent accounts with shell banks, and requires them to take reasonable steps to ensure that their foreign correspondent banks do not provide services to shell banks12. Therefore, the US does not have jurisdiction over shell banks operating in foreign jurisdictions, unless they are involved in transactions that violate US laws or sanctions.
USA PATRIOT Act Section 313: Prohibition on U.S. Correspondent Accounts with Foreign Shell Banks1 Fact Sheet Regarding the Treasury Department's Use of Sanctions Authorities to Combat Money Laundering and Terrorist Financing3 Reference: https://www.congress.gov/107/plaws/publ56/PLAW-107publ56.htm

Economic sanctionsare used as anon-military toolto enforceforeign policy and national security objectives.
Option D (Correct):Sanctions aim tochange the behaviorof entities engaged inmoney laundering, terrorist financing, or other illicit activities.
Option A (Incorrect):Sanctions do not necessarily indicatemilitary action.
Option B (Incorrect):NGOs may be exempt from sanctions, but this is not their primary purpose.
Option C (Incorrect):Whilehuman rights concernscan lead to sanctions, they are primarily imposed tochange behavior.
Reference:OFAC Sanctions Guidance, UN Security Council Sanctions List, EU Sanctions Regulations.