The susceptibility of a company or jurisdiction to ML/TF abuse is significantly increased by:
* Permissibility of bearer shares (B):"Bearer shares make it easy to hide ownership and control, presenting a major risk for misuse by criminals."(CAMS 6th Edition, Beneficial Ownership and Company Transparency)
* Rules governing the disclosure of beneficial ownership by the jurisdiction (C):"Weak requirements or loopholes in beneficial ownership disclosure are frequently exploited to conceal criminal involvement in corporate structures."(CAMS 6th Edition, Chapter: Legal Persons and Arrangements) Incorrect Options:
* A: High or low fees are not a significant ML/TF risk driver.
* D: Ease of travel is unrelated to ML/TF risk related to company structures.
References:
CAMS 6th Edition, Beneficial Ownership and Transparency
FATF Recommendations 24, 25

Submitting the concern anonymously to the bank's internal Compliance Hotline is the most appropriate action that a bank CEO's assistant should take when the bank CEO expenses large sums of money to a charitable organization run by the bank CEO's direct family member. This is because this action would allow the assistant to report a potential case of fraud, conflict of interest, or misuse of funds without fear of retaliation or reprisal from the bank CEO. The Compliance Hotline is a confidential and secure channel for employees to raise any concerns or suspicions about unethical or illegal activities within the bank. The Compliance Hotline would then forward the concern to the relevant authorities or departments for further investigation and action.
= The main references for this question are the following sources:
The document titled "Anti-Fraud Policy" published by the World Bank Group. You can access it by clicking here. This document states that "The World Bank Group has established a Compliance Hotline to receive reports of suspected fraud or corruption in World Bank Group-financed projects or activities, or in the World Bank Group's corporate procurement or administrative activities. The Compliance Hotline is available to all staff and external parties, such ascontractors, consultants, beneficiaries of World Bank Group-financed projects, and the general public.

An enterprise-wide compliance culture is a centralized, coordinated approach to ethics and compliance program design and assessment that cuts across multiple business units within an organization1. One key aspect of promoting such a culture is that the relevant information should be shared throughout the organization, so that all employees are aware of the compliance risks, policies, procedures, and expectations, and can act accordingly2. Sharing information also facilitates collaboration, communication, and feedback among different functions and levels of the organization, and helps identify and address any gaps or issues in the compliance program3. By contrast, the other options are not conducive to an enterprise-wide compliance culture, as they either create silos, conflicts, or inefficiencies in the compliance function.
1: Enterprise Compliance Risk Management Services | Deloitte US
2: Enterprise Risk Management and Risk Culture - McKinsey & Company
3: FRB: Speech, Bies-Enterprise-wide Compliance Programs-February 4, 2004 Reference: https://www.ifc.org/wps/wcm/connect/e7e10e94-3cd8-4f4c-b6f8-1e14ea9eff80
/45464_IFC_AML_Report.pdf?MOD=AJPERES&CVID=mKKNshy (51)

According to the Basel guidelines on customer due diligence for banks, a trust is a legal arrangement whereby a person (the settlor or grantor) transfers the legal ownership of specific assets to another person or entity (the trustee) to hold for the benefit of a third person or persons (the beneficiaries)1. The Basel guidelines recommend that banks should identify and verify the identity of the following parties to determine the true nature of the trust relationship:
The trustee, who is the person or entity that has the legal authority and duty to manage the trust assets and distribute them to the beneficiaries according to the trust deed2. The trustee may also be the settlor, the beneficiary, or both, depending on the type and structure of the trust3.
The beneficiaries, who are the persons or entities that have a beneficial interest in the trust assets or income, either presently or in the future4. The beneficiaries may be named individuals, classes of persons, or charitable causes.
The settlor or grantor, who is the person or entity that creates the trust and transfers the legal ownership of the assets to the trustee. The settlor or grantor may also retain some rights or powers over the trust, such as the ability to appoint or remove trustees, beneficiaries, or protectors.
The other three options are incorrect because:
Respondents are not trust parties, but rather financial institutions that maintain correspondent banking relationships with other financial institutions. Respondents are not relevant for the identification of the trust relationship, but rather for the due diligence of the correspondent banking relationship.
Payees are not trust parties, but rather persons or entities that receive payments from the trust or other sources.
Payees are not relevant for the identification of the trust relationship, but rather for the monitoring of the transactions and activities of the trust.
Trust administrators are not trust parties, but rather persons or entities that provide administrative services to the trust, such as accounting, record-keeping, or tax compliance. Trust administrators are not relevant for the identification of the trust relationship, but rather for the assessment of the risk and complexity of the trust.
1: Basel Committee on Banking Supervision, Customer due diligence for banks, October 2001, 4, p. 17 2:
Basel Committee on Banking Supervision, Customer due diligence for banks, October 2001, 4, p. 17 3:
ACAMS, CAMS Study Guide, 6th Edition, Chapter 5,p. 111 4: Basel Committee on Banking Supervision, Customer due diligence for banks, October 2001, 4, p. 17 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 5, p. 111 : Basel Committee on Banking Supervision, Customer due diligence for banks, October
2001, 4, p. 17 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 5, p. 111 : Basel Committee on Banking Supervision, Customer due diligence for banks, October 2001, 4, p. 10 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 5, p. 112 : ACAMS, CAMS Study Guide, 6th Edition, Chapter 5, p. 112

Anenterprise-wide risk assessment (EWRA)must beupdated when major changesoccur thatimpact AML risk exposure.
Option A (Correct):New products and services(e.g., cryptocurrency trading, private banking)can introduce new money laundering risks.
Option B (Correct):Restructuring compliance teams can impact AML oversightand risk assessment effectiveness.
Option E (Correct):Mergers and acquisitionsmay bringlegacy compliance issues and different risk cultures.
Why Other Options Are Incorrect:
Option C (Incorrect):Changes in product leadership do not automatically change risk exposureunless the product itself changes.
Option D (Incorrect):Using new technology for existing products does not inherently change AML risks, thoughnew digital products might.
Best Practices for Enterprise-Wide AML Risk Assessment Updates:
Review AML program effectiveness before launching new services.
Assess legacy compliance issues when acquiring or merging with another entity.
Align risk frameworks with regulatory changes.
Reference:
FATF Recommendation 1 (Risk-Based Approach to AML)
Wolfsberg Group Enterprise-Wide Risk Assessment Guidelines
6th EU AML Directive (6AMLD) on Financial Institution Risk Management