Ongoing Due Diligence: FATF emphasizes the importance of continuous monitoring of business relationships and transactions. This involves regularly assessing the risk associated with a customer and ensuring that the information remains up-to-date. It includes monitoring transactions for any suspicious activity or red flags.
Beneficial Owners: Identifying beneficial owners is crucial, but it must be done with verification of their true identity. This is part of the initial due diligence process.
Risk Assessment: Conducting risk assessments is essential, but it is not specific to customer due diligence.
Risk assessment applies broadly to anti-money laundering (AML) programs.
Products and Services Suitability: While understanding the suitability of products and services is relevant, it is not a direct measure within customer due diligence.
References:
Anti-Money Laundering Specialist (the 6th edition) resources.
FATF 40 Recommendations (Recommendation 10: Customer Due Diligence).1
CFATF Technical Articles (Customer Due Diligence Measures).2

Enhanced due diligence (EDD) is a higher level of customer due diligence that is required for customers or accounts that pose a higher risk of money laundering or terrorist financing. According to the FATF Recommendations, EDD measures may include obtaining additional information on the customer, the beneficial owner, the intended nature and purpose of the business relationship, the source and destination of funds, and the reasons for transactions. EDD is also required for customers or accounts that are from or in countries that do not have adequate AML/CFT systems or are subject to sanctions or embargoes.
Among the four categories of customers or accounts listed in the question, lawyers, foreign exchange dealers, and precious metal dealers are considered as high-risk by the FATF and other international standards, and therefore require EDD. Lawyers may be involved in transactions that conceal the origin or ownership of illicit funds, such as creating shell companies, trusts, or foundations. Foreign exchange dealers may facilitate the movement of illicit funds across borders or jurisdictions, or provide anonymous or pseudonymous services.
Precious metal dealers may deal with high-value goods that are easily convertible into cash, or may be used to launder proceeds of crime or evade sanctions.
Retail account holders, on the other hand, are generally considered as low-risk customers or accounts, unless they exhibit unusual or suspicious behavior or transactions. Therefore, they do not require EDD by default, but only when there are specific indicators of higher risk.
[ACAMS Study Guide for the CAMS Certification Examination, 6th Edition], Chapter 3: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT), pp. 75-76,
79-80.
FATF Guidance on Correspondent Banking Services, October 2016, pp. 7-8, 12-13.
Customer Due Diligence - Overview, Federal Financial Institutions Examination Council, April 2018, pp. 1-2,
5-6.
Customer due diligence, The Law Society, accessed on February 9, 2024.
Anti-Money Laundering (AML) Source Tool for Broker-Dealers, U.S. Securities and Exchange Commission, May 16, 2022, pp. 1-2, 5-6.

According to the Certified Anti-Money Laundering Specialist (CAMS) Sixth Edition manual, elements that can trigger a review of the existing relationship during the opening of a new account include recent adverse media on the client (page 60) and incoming transfers from high-risk jurisdictions (page 61). The other elements listed, such as regular checks on the flow of funds, a false positive result for name screening, and an estimated total income decrease, are not triggers for a review.

Structuring is a technique used in the placement stage of money laundering, in which the launderer deposits or withdraws cash in amounts below the reporting threshold to avoid detection or suspicion. Structuring is also known as smurfing, because it involves using multiple individuals or locations to carry out the transactions. Structuring is illegal in many jurisdictions and is a red flag for money laundering12.
Option A is not an example of structuring, but of using an alternative remittance system, which is a method of transferring money outside the formal financial sector. Hawala is a type of alternative remittance system that relies on a network of brokers who settle the transactions through trust and honor. Hawala can be used for legitimate purposes, but also poses a risk for money laundering and terrorist financing13.
Option B is not an example of structuring, but of a large cash transaction, which is a common indicator of money laundering. Large cash transactions may involve the proceeds of crime or the attempt to evade taxes or currency controls. Financial institutions are required to report large cash transactions above a certain threshold to the relevant authorities14.
Option D is not an example of structuring, but of a wire transfer, which is a method of moving funds electronically from one account to another. Wire transfers can be used for legitimate purposes, but also pose a risk for money laundering and terrorist financing, especially if they involve high-risk jurisdictions, shell companies, or complex chains of transactions1 .
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. 12-14, 18-19, 22-23, 26-27. 2:
ACAMS (2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.
acams.org/en/cams-certification-package-6th-edition, Module 1, Section 1.2.2. 3: ACAMS (2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams- certification-package-6th-edition, Module 1, Section 1.2.3. 4: ACAMS (2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams-certification-package-
6th-edition, Module 1, Section 1.2.1. : ACAMS (2020), CAMS Examination Preparation Video, 6th Edition, ACAMS, Miami, FL, USA, www.acams.org/en/cams-certification-package-6th-edition, Module 1, Section
1.2.4.

Sanctions compliance is mandatory for financial institutions (FIs) to prevent transactions with sanctioned individuals, entities, and countries.
Option A (Correct): Automatic sanctions screening is essential for detecting and blocking transactions involving sanctioned individuals or entities.
Option B (Incorrect): If a customer is sanctioned, their transactions must be frozen immediately, not just monitored.
Option C (Incorrect): EDD is not relevant for prohibited entities-sanctions require immediate asset freezing.
Option D (Incorrect): Funds must be frozen immediately, without waiting for board approval.
Best Practices for Sanctions Compliance:
Use automated screening tools to detect sanctioned entities.
Immediately block and report prohibited transactions.
Regularly update sanctions screening lists (e.g., OFAC, UN, EU).
Reference:
FATF Recommendation 6 (Targeted Financial Sanctions Compliance)
OFAC Sanctions Guidelines (U.S. Treasury)
EU Sanctions Regulation on AML Compliance