A politically exposed person (PEP) is a customer who requires the most enhanced due diligence (EDD). This is because PEPs are individuals who hold or have held prominent public positions, such as heads of state, senior politicians, judges, military officers, ordirectors of state-owned enterprises, and who may pose a higher risk of money laundering, corruption, or bribery due to their influence and access to public funds1. EDD measures for PEPs may include obtaining senior management approval, establishing the source of wealth and funds, and conducting enhanced ongoing monitoring of the business relationship2.
The other customers listed do not necessarily require the most EDD, although they may still present a higher risk of money laundering depending on the circumstances. A resident of a non-cooperative jurisdiction is a customer who lives in a country or territorythat has been identified by the Financial Action Task Force (FATF) or other international bodies as having weak or deficient anti-money laundering (AML) standards or posing a threat to the international financial system3. EDD measures for such customers may include obtaining additional information or documentation, applying extra scrutiny to transactions, or refusing to establish or continue the business relationship4. An international business corporation is a customer who operates in multiple jurisdictions and may have complex or opaque ownership structures that can conceal the identity or activity of the beneficial owners or controllers. EDD measures for such customers may include verifying the legal existence and structure of the entity, identifying the beneficial owners and controllers, and understanding the nature and purpose of the business relationship. An established customer is a customer who has a long-standing and regular business relationship with the financial institution and who may have a lower risk of money laundering due to the familiarity and trust that has been built over time. EDD measures for such customers may not be required unless there are changes in the customer's profile, behavior, or risk level.
1: Politically Exposed Persons (Recommendations 12 and 22) - FATF1 2: High-risk customers, including politically exposed persons | FCA2 3: High-Risk and Other Monitored Jurisdictions - FATF3 4: Your responsibilities under money laundering supervision | GOV.UK4 : International Business Corporations - ACAMS : Anti-Money Laundering Customer Due Diligence | Veriff.com : Customer Due Diligence - ACAMS : Anti-money laundering - a guide to customer due diligence

* D: "Cooperation and coordination between regulatory authorities, law enforcement agencies, and FIUs are essential for effective AML investigations, especially in cross-border cases. This is often accomplished through formal agreements, MOUs, and information-sharing mechanisms."(CAMS 6th Edition, International Cooperation in AML/CFT; FATF Recommendations 36-40) References:
CAMS 6th Edition, International Cooperation
FATF Recommendations 36-40

Accounts may beclosedif theypose high money laundering or sanction risks.
* Option A (Correct):MultipleSAR filingsindicatehigh risk, possibly requiringaccount closureif AML concerns persist.
* Option B (Incorrect):Tuition paymentsare alegitimate purposefor fund transfers.
* Option C (Incorrect):Indirect dealings withSDNs require compliance review, but notimmediate account closure.
* Option D (Incorrect):Civil subpoenasalone do not justifyaccount termination.
Reference:FATF Recommendation 10 (Customer Due Diligence), Wolfsberg Group Customer Exit Best Practices, FinCEN Guidance on SAR Reporting.

Lawyers and legal professionalsare frequently used inmoney laundering schemes, particularly throughtrust accountsthat offeranonymity and client privilege protections.
Option A (Correct):Repeated wire transfers from unknown sources followed by immediate outward transferssuggest that the lawyer's trust accountis being used as a pass-through account for laundering funds.
Option B (Incorrect):If legal services were actually rendered,this is a normal transactionunless other risk factors exist.
Option C (Incorrect):Receiving funds from aregulated insurance companyisnot inherently suspicious, unless the transaction isinconsistent with the lawyer's usual business activity.
Option D (Incorrect):Large transactions are normal inreal estate purchases, as long as proper documentation exists.
Red Flags in Legal Sector Money Laundering:
Use of lawyer trust accounts to move funds with no legitimate business purpose.
Frequent transactions from high-risk jurisdictions.
Transactions that are inconsistent with the lawyer's area of practice.
Clients who refuse to disclose the source of funds.
Best Practices:
Apply AML measures to law firmshandling financial transactions, as required by FATF'sDesignated Non- Financial Businesses and Professions (DNFBPs)guidelines.
Require enhanced due diligence (EDD) for high-risk clientsandunusual transactions.
Reference:
FATF Report on Legal Professionals & Money Laundering
Wolfsberg Group Legal Sector AML Guidance
6th EU Anti-Money Laundering Directive (6AMLD) on DNFBPs

According to the ACAMS CAMS Study Guide, 6th Edition, Chapter 2, Section 2.1, the AML program should be reassessed periodically or when there are significant changes in the business environment, such as:
Expansion of business to new territories: This could expose the business to new risks, regulations, and customers that require different AML policies, procedures, and controls. The AML program should be updated to reflect the new jurisdictions and their AML requirements, as well as to conduct appropriate risk assessments and due diligence on the new markets and customers.
New product offering: This could introduce new vulnerabilities, opportunities, and challenges for the AML program. The AML program should be revised to incorporate the new product features, benefits, and risks, as well as to ensure compliance with any applicable AML rules and standards for the new product.
The other options are not factors that would necessarily lead to a reassessment of the current AML program, unless they have a material impact on the AML risks, objectives, or performance of the business:
Appointment of a new Chief Financial Officer: This could affect the AML program if the new CFO has a different vision, strategy, or approach to AML than the previous one, or if the new CFO has a significant role or responsibility in the AML program. However, the appointment of a new CFO alone does not trigger a reassessment of the AML program, unless there are other changes or issues that warrant a review.
Change of company name: This could affect the AML program if the change of name reflects a change of ownership, structure, or nature of the business that could alter the AML risks, obligations, or expectations.
However, the change of name alone does not necessitate a reassessment of the AML program, unless there are other implications or consequences that affect the AML program.
Change of internal audit team members: This could affect the AML program if the new internal audit team members have different qualifications, skills, or experiences than the previous ones, or if the new internal audit team members have a different scope, methodology, or frequency of auditing the AML program.
However, the change of internal audit team members alone does not require a reassessment of the AML program, unless there are other factors or findings that indicate a need for a review.
References:
ACAMS CAMS Study Guide, 6th Edition, Chapter 2, Section 2.1
ACAMS CAMS Certification Video Training Course - Exam-Labs
Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)