Using self-hosted wallets, or wallets that are stored on the user's computer, is one of the tactics that may be used to finance terrorism with virtual assets such as Bitcoin. By creating many different donation addresses that are updated continuously, law enforcement will have a harder time tracing transactions. It is also important to note that using the same donation address across multiple donation campaigns and media types, as well as forming relationships with virtual asset service providers that have strong KYC processes in place, can draw attention from law enforcement and should be avoided.

When onboarding a corporate customer, financial institutions must conduct due diligence to assess potential AML risks.
Option A (Correct): Understanding the nature of the business helps identify higher-risk industries (e.g., casinos, cryptocurrency exchanges, cash-intensive businesses).
Option D (Correct): Identifying senior managing officials and account signatories helps verify the true control and ownership of the company.
Option E (Correct): Jurisdictional risk assessment is key, especially if the company is from a FATF-listed high-risk country.
Why Other Options Are Incorrect:
Option B (Incorrect): The employment profiles of all employees are not relevant unless they have a direct role in financial transactions.
Option C (Incorrect): A company's banking history is not always relevant, unless there are red flags of prior financial crime involvement.
Best Practices for Corporate Customer Onboarding:
Verify beneficial ownership structures to detect potential shell companies.
Conduct enhanced due diligence (EDD) for high-risk industries and jurisdictions.
Ensure ongoing monitoring of corporate customers.
Reference:
FATF Recommendation 10 (Customer Due Diligence)
6th EU AML Directive (6AMLD) on Corporate Due Diligence
Wolfsberg Group Guidance on Corporate Customer AML Risk Management

A money laundering risk assessment is a crucial component of an effective anti-money laundering (AML) program. It involves identifying, assessing, and understanding the specific risks related to money laundering and terrorist financing that the institutionmay face. A risk assessment helps the institution to design and implement appropriate controls, policies, procedures, and training to mitigate the risks. A risk assessment should be updated regularly and whenever there are significant changes in the institution's business activities, products, services, customers, or geographic locations. In this scenario, the financial institution has experienced significant deficiencies in its AML program during a recent regulatory examination. The deficiencies were primarily attributed to the lack of oversight by the institution's leadership in implementing adequate controls over the new products and services that were added as part of the institution's aggressive growth strategy. To correct these weaknesses in the AML program, the leadership should first address the area of international control known as "Money laundering risk assessment" (Option C). By conducting a new and comprehensive risk assessment, the leadership can identify the potential vulnerabilities and gaps in the AML program that may arise from the new products and services. The risk assessment can also help the leadership to prioritize the actions and resources needed to address the deficiencies and enhance the AML program.
Once the risk assessment is completed, the leadership can then work on updating the AML policy, providing adequate training, and ensuring sufficient compliance staff to implement and monitor the controls.
1, Chapter 2: Risk Assessments
2, Section 2: Anti-Money Laundering Compliance Program
3, Question 145

According to the AML Directive of the EU, obliged entities, such as banks and other financial institutions, are required to apply enhanced vigilance in business relationships and transactions involving high-risk third countries, which are those identified by the Commission as having strategic deficiencies in their anti-money laundering and countering the financing of terrorism regimes1. The types of enhanced vigilance requirements are basically extra checks and control measures which are defined in article 18a of the Directive1. However, these requirements are not exhaustive, and obliged entities should also implement additional mitigating measures that are complementary to the enhanced customer due diligence procedures, in accordance with a risk based approach1. This means that obliged entities should assess the level of risk posed by each customer, product, service, transaction, or delivery channel, and apply appropriate measures to mitigate those risks2. The additional mitigating measures may include, for example, obtaining additional information on the customer and the beneficial owner, applying additional elements of enhanced monitoring, increasing the frequency and intensity of transaction testing, or requiring the first payment to be carried out through an account in the customer's name with a bank subject to similar customer due diligence standards1.
1: Directive (EU) 2018/843 of the European Parliament and of the Council of 30 May 2018 amending Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, and amending Directives 2009/138/EC and 2013/36/EU (Text with EEA relevance)
2: Guidance on Risk Factors, EBA, 2021
Reference: https://www.nortonrosefulbright.com/en/knowledge/publications/8f84c163/the-eus-fifth-anti- money-laundering-directive-a-regulatory-compliance-perspective

An internal investigation log is primarily intended to track the status of investigations into unusual activity. This is to ensure that the investigations are conducted in a timely, thorough, and consistent manner, and that the results and recommendations are documented and communicated to the relevant parties12. An internal investigation log can also help the organization to identify any trends, patterns, or gaps in its anti- money laundering (AML) compliance program, and to measure its effectiveness and efficiency3.
An internal investigation log is not intended to provide training on investigations to the anti-money laundering officer and Financial Intelligence Unit (FIU), report status of investigations to the Board of Directors, or detect and monitor possible suspicious activity. These are separate functions that may involve the use of the internal investigation log, but are not its primary purpose.
1: How to Conduct Effective AML Investigations - Blog | Unit211 2: BSA/AML Internal Audit: PwC2 3:
Anti-Money Laundering: 5 Steps to Conduct an Audit3