The6th AML Directive (6AMLD)introducedtighter rulesto combat financial crime, particularly aroundbeneficial ownership transparency.
* Option D (Correct):6AMLD enhances transparencyby requiring accurate and verified datain central beneficial ownership registries, making it harder to hide illicit funds behind shell companies.
* Option A (Incorrect):While some entities face increased scrutiny,crowdfunding platforms and football clubs were not the primary focusof 6AMLD.
* Option B (Incorrect):6AMLD does not remove the EU's obligation to conduct risk assessments;risk- based approaches remain centralto AML efforts.
* Option C (Incorrect):TheEU AML Authority (AMLA), planned for2024, will centralize enforcement, but6AMLD did not createthis entity.
Reference:6AMLD (Directive (EU) 2018/1673), EU AML Framework, FATF Recommendations.

A customer visiting multiple branches of the MSB on the same day in order to transfer funds internationally is a potential indicator of structuring, which is a technique used by money launderers to avoid reporting thresholds or detection by authorities. A customer attempting to buy money orders under $3,000 USD in cash multiple times a day is also apossible sign of structuring, as well as an attempt to evade the identification and recordkeeping requirements for MSBs. Both scenarios should be included in the procedures for further review by the AML Officer.
BSA/AML Risk Assessment for Money Services Businesses (MSBs), section "Risk Factors", sub-section
"Structuring": "Structuring is the practice of conducting financial transactions in a specific pattern calculated to avoid the creation of certain records and reports required by the BSA and/or 31 CFR Chapter X.
Structuring is illegal and is often indicative of money laundering or other illicit activity." Money Services Business (MSB) - AML Compliance Guide, section "AML Compliance Requirements for MSBs", sub-section "Identification and Recordkeeping": "MSBs must verify the identity of any person who conducts a transaction of $3,000 or more. They must also keep records of the transaction, including the name, address, date of birth, and identification number of the customer, as well as the amount, date, and method of payment."

A deferred prosecution agreement (DPA) is a type of enforcement action that allows a financial institution to avoid criminal prosecution if it admits to wrongdoing, pays a fine, and agrees to remediate its AML program deficiencies within a specified period of time1. A cease and desist order (C&D) is another type of enforcement action that requires a financial institution to stop engaging in unsafe or unsound practices or violations of law, and to take corrective actions to address its AML program weaknesses2. Both of these actions are commonly used by regulators to address serious or systemic AML program failures by financial institutions, as evidenced by recent cases345.
References:
1: Deferred Prosecution Agreement - Wikipedia
2: FFIEC BSA/AML Appendices - Appendix R - Enforcement Guidance
3: FinCEN Announces $15 Million Civil Money Penalty against Bancredito International Bank for Willful Violations of the Bank Secrecy Act
4: Lessons From The Seven Largest AML Bank Fines In 2021
5: Fines for AML Compliance Failures - ACAMS Today

Under USA PATRIOT Act Section 311, the U.S. government can impose special measures against a foreign jurisdiction, institution, or transaction that is of primary money laundering concern1. These measures can range from requiring additional recordkeeping and reporting to prohibiting or restricting the opening or maintaining of correspondent or payable-through accounts for the designated entity2. A payable-through account is a type of correspondent account that allows customers of a foreign bank to access the U.S. financial system by writing checks or making wire transfers from the foreign bank's account at a U.S. bank3.
In this case, the U.S. government has enacted special measures against a designated entity that has a payable- through account with an EU bank, which in turn has a correspondent banking relationship with a U.S. bank.
One of the possible actions that the U.S. bank might be required to take regarding the EU bank's services for the designated entity is to obtain additional information about customers permitted to use this account. This is to ensure that the U.S. bank can identify and monitor the transactions and activities of the designated entity and its customers, and to prevent any money laundering or terrorist financing risks4.
The other actions listed are not likely to be required by the U.S. government under Section 311. Ensuring the designated entity's confidential information is not shared with other entities is not a special measure, but a general obligation of any financial institution under privacy laws. Verifying that the EU bank serves the designated entity is not a relevant action, since the U.S. government has already designated the entity as a primary money laundering concern. Performing enhanced due diligence on the EU bank is not a specific action related to the payable-through account, but a broader requirement for any correspondent account under Section 312 of the USA PATRIOT Act5.
1: USA PATRIOT Act | FinCEN.gov1 2: 311 Actions | U.S. Department of the Treasury2 3: Overview of Correspondent Banking and "De Risking" Issues - CRS Reports3 4: U.S. TREASURY DEPARTMENT OFFICE OF PUBLIC AFFAIRS4 5: Fact Sheet: Overview of Section 311 of the USA PATRIOT Act5