According to the Wolfsberg Principles on Correspondent Banking1, an institution should consider the following three elements in its enhanced due diligence process for higher risk respondent bank customers:
* The quality of the respondent's AML and client identification controls: The correspondent should assess the adequacy and effectiveness of the respondent's AML policies, procedures, and systems, as well as its compliance with applicable AML laws and regulations. The correspondent should also verify that the respondent has implemented appropriate customer identification and verification measures, and that it maintains sufficient records of its customers and transactions.
* A risk-based determination as to whether or not the respondent is a shell bank: The correspondent should ensure that the respondent is not a shell bank, which is defined as a bank that has no physical presence in any country and is not affiliated with a regulated financial group. The correspondent should also avoid establishing or maintaining relationships with banks that are known to allow their accounts to be used by shell banks.
* Whether a Politically Exposed Person (PEP) has an interest or management role in the respondent: The correspondent should identify and assess the potential risks associated with any PEPs who have an ownership or management interest in the respondent, or who are customers of the respondent. The correspondent should apply enhanced scrutiny and monitoring to such relationships, and obtain senior management approval before establishing or continuing them.
Wolfsberg Correspondent Banking Principles 2022 by the Wolfsberg Group, October 2022.
Reference:http://www.fatf-gafi.org/media/fatf/documents/reports/RBA%20Guidance%20for%20Real%
20Estate%20Agents.pdf(page
20, second paragraph)

The line of business is responsible for creating, implementing and maintaining policies and procedures, as well as communicating these to all personnel. It must also establish processes for screening employees to ensure high ethical and professional standards and deliver appropriate training on AML policies and procedures based on roles and functions performed so employees aware of their responsibilities. To facilitate this, employees should be trained as soon as possible after being hired, with refresher training as appropriate.

The Office of Foreign Assets Control (OFAC), part of the U.S. Department of the Treasury, is responsible for theadministration and enforcement of economic and trade sanctions. These sanctions are based on U.S.
foreign policy and national security objectives and target:
Foreign countries and regimes
Terrorist organizations
Narcotics traffickers
Individuals and entities engaged in activities related to the proliferation of weapons of mass destruction OFAC acts under various authorities, including national emergency powers granted by the President and specific legislation. One of its primary tools is theSpecially Designated Nationals(SDN) List, which identifies individuals and entities whose assets are blocked and with whom U.S. persons are generally prohibited from dealing.
It is important to note that OFAC is not responsible for designating jurisdictions as primary money laundering concerns (a task handled by FinCEN under Section 311 of the USA PATRIOT Act), nor does it manage trade agreements.
Reference: ACAMS CAMS Study Guide - 6th Edition, Chapter: U.S. Regulatory Framework - Section:
Office of Foreign Assets Control (OFAC)

According to the CAMS manual 6th edition, the USA PATRIOT Act allows the US government to subpoena documents from foreign financial institutions (FIs) that have no presence in the US (option B). The manual states that "The USA PATRIOT Act provides US law enforcement agencies with the power to subpoena documents from foreign banks that maintain correspondent accounts with US banks or have no presence in the United States" (p. 77).

Cross-borderAML investigationsrequire cooperation throughofficial channels, such as theEgmont Group.
Option D (Correct):TheEgmont Groupis an international network ofFIUs that facilitates secure information exchangein financial crime investigations.
Option A (Incorrect):While sovereignty applies,formal international cooperation mechanisms exist.
Option B (Incorrect):AML cooperation is allowed under legal frameworks(e.g.,MLATs, Egmont Secure Web).
Option C (Incorrect):Information-sharing is restrictedtoauthorized government agencies, not all organizations.
Reference:Egmont Group of FIUs, FATF Recommendation 40 (International Cooperation), Mutual Legal Assistance Treaties (MLATs).