A compliance officer is looking to update an institutions private bank procedures. What should be included as recommended by the Wolfsberg AML Principles on
Private Banking?
A.
Approval of Politically Exposed Persons (PEPs) by at least one person other than the relationship manager
B.
Dedicated automated AML monitoring of client activity
C.
Review of client files annually if there are unusual transactions
D.
The institution’s senior management has primary responsibility for the relationship
The bank's internal policies should indicate whether, for any one or more among these categories, Senior
Management must approve entering into new relationships.
Relationships with Politically Exposed Persons may only be entered into with the approval of Senior Management.
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