In anEnterprise-Wide Risk Assessment (EWRA),residual riskis the level of risk that remains after applying mitigating controls to theinherent risk(the risk present before controls are applied).
In this scenario, theinherent risk is highdue to the nature of private banking-high net worth clients,cross- border transactions,complex ownership structures, andhigh-value financial products. However, the institution has implementedrobust CDD and EDD, as well asadvanced transaction monitoring systems.
According to the CAMS Study Guide - 6th Edition, wheneffective and properly implemented controlsare in place, they cansignificantly reducethe residual risk-even in high-risk business areas like private banking.
However, no control framework caneliminate all riskentirely.
* Option Ais correct: Controls can significantly reduce the residual risk when strong, effective systems and procedures are in place.
* Option Bis partially true but suggests inadequacy, which is not indicated here.
* Option Cincorrectly assumes residual risk cannot be lowered even with controls.
* Option Dis incorrect because residual riskcannot be eliminated entirely.
Reference: ACAMS CAMS Study Guide - 6th Edition, Chapter:Enterprise-Wide Risk Assessment (EWRA)- Section:Inherent Risk vs. Residual Risk and the Role of Controls

According to the Wolfsberg Group's Statement on the Suppression of the Financing of Terrorism1, a compliance officer should include the following three procedures in revising an institution's CTF efforts:
Consulting applicable lists and taking appropriate actions to determine if customers appear on such lists. This procedure is important to prevent terrorist organizations from accessing the financial services of the institution and to comply with the sanctions and regulations imposed by competent authorities. The compliance officer should implement procedures for checking the customers against the lists of known or suspected terrorists or terrorist organizations issued by relevant authorities and taking reasonable and practicable steps to verify the identity and status of the customers.
Reporting matches from lists of known or suspected terrorists to relevant authorities. This procedure is important to assist the authorities in their efforts to detect and disrupt terrorist financing and to fulfill the legal obligations of the institution. The compliance officer should report to the relevant authorities any matches from the lists of known or suspected terrorists or terrorist organizations consistent with the applicable laws and regulations regarding the disclosure of customer information.
Maintaining customer information to facilitate timely retrieval of such information. This procedure is important to enable the institution to respond promptly and effectively to the enquiries and requests from the authorities and to enhance the quality and accuracy of the customer data. The compliance officer should explore ways of improving the maintenance of customer information to facilitate the timely retrieval of such information.
Wolfsberg Statement on Anti-Terrorism Financing
UNUSUAL CUSTOMER IDENTIFICATION CIRCUMSTANCES
* Customer furnishes unusual or suspicious identification documents or declines to produce originals for verification."

The financial institution should perform further investigation to verify the legitimacy of the tour guide's explanation and the source of funds. If the investigation reveals any suspicious or unusual activity, such as inconsistent cash flow patterns, involvement of high-risk customers or jurisdictions, or indications of money laundering or terrorist financing, the financial institution should report the activity to the authorities and consider terminating the relationship. The financial institution should also document the investigation and its findings, and update the customer's risk profile accordingly.
CAMS Study Guide - 6th Edition, Chapter 4, page 112
CAMS Certification Exam Outline, Domain 1, Task 1.2, Skill 1.2.2
ACAMS MoneyLaundering.com, Article: "How to Conduct Effective Customer Due Diligence"

USA PATRIOT Act Section 314(b)allows financial institutions tovoluntarily share information with one another, after notifying the U.S. Treasury, toidentify and report possible money laundering or terrorist financing activities.
Key elements include:
Voluntary participation
Prior notice to FinCEN (part of the U.S. Treasury)
Protection from liability when acting in good faith
Enhanced collaborative detection across institutions
Section 314(a)refers toinformation sharing between law enforcement and financial institutions, not peer-to- peer sharing.
COSMICis an initiative in certain jurisdictions like Singapore, not U.S. regulation.
Regulation (EU) 2024/1624is part of the EU AML framework, not relevant to U.S. institutions.
Reference: ACAMS CAMS Study Guide - 6th Edition, Chapter:U.S. Regulatory Framework- Section:USA PATRIOT Act - Information Sharing under Section 314(b)

A Penza scheme, also known as a Ponzi scheme, is a form of fraud that lures investors and pays profits to earlier investors with funds from more recent investors1 The scheme relies on attracting new investors with unrealistic promises of high returns and low risk, while using their money to pay off the previous investors2 An unlicensed investment advisor who offers profits other investments cannot guarantee is likely to be involved in a Penza scheme, as this is a common way to entice unsuspecting victims3 The other options are not necessarily indicative of a Penza scheme, as they could be legitimate or involve other types of fraud.
1 Ponzi scheme - Wikipedia; 2 Ponzi Schemes: Definition, Examples, and Origins - Investopedia; 3 What is Ponzi Scheme? - Sanction Scanner