PEPs are recognized by CAMS 6th Edition and FATF as posing elevated risk due to:

A. The family members and close associates of PEPs may be involved in illicit activities:“The risks extend beyond the PEP to family members and close associates, who may be used to conceal the movement of illicit funds.”(CAMS 6th Edition, PEP Risk Factors; FATF Guidance)

C. PEPs may exploit embassy activities to conceal bribery and corruption transactions:“PEPs may use their position or diplomatic privileges, such as embassy operations, to disguise or facilitate the movement of illicit funds.”(CAMS 6th Edition, Corruption and PEP Risks)

Incorrect Options:

B: There is no such legal provision granting PEPs financial immunity or unlimited credit.

D: Banks may (and often must) exit PEP relationships not in line with their risk appetite.

The First Line of Defense (1LoD) consists of customer-facing business units (e.g., relationship managers, front-office staff, and operational teams). Their primary responsibility in financial crime risk management is to implement AML/CFT controls as part of daily operations. This includes Collecting complete customer information.

The First Line of Defense is responsible for conducting Know Your Customer (KYC) and Customer Due Diligence (CDD) during onboarding and throughout the customer relationship. Ensuring that all relevant customer details (e.g., identity, business purpose, ownership structure) are accurately collected and documented is crucial for mitigating financial crime risks.

One of the central pillars of the EU AML Package adopted in June 2024 is theEU AML Regulation. This regulation introduces directly applicable AML/CFT rules across all EU member states, replacing the previous approach where AML directives were transposed into national laws. This shift addresses regulatory fragmentation and strengthens enforcement across borders.

The complete AML Package includes the following four pillars:

EU AML Regulation (directly applicable rulebook)

6th AML Directive (not the 7th)

Establishment of a new EU Anti-Money Laundering Authority (AMLA)

Revised Transfer of Funds Regulation, especially concerning crypto-asset service providers

The EU AML Regulation aims to unify and streamline the application of AML/CFT measures across the EU, ensuring a consistent and effective framework.

Paying premium several years in advance and terminating early for a refund (A):“A typical red flag is when a policyholder pays large premiums up front and then seeks early termination to receive a refund. This can be used to launder illicit funds by integrating them into the financial system and then retrieving ‘clean’ money.”(CAMS 6th Edition, Life Insurance ML/TF Risks; FATF Guidance for a Risk-Based Approach for the Life Insurance Sector)

Regularly switching policies and accepting penalties (D):“Frequent changes in insurance policies or products, even at a financial loss, are considered suspicious. This may indicate an attempt to obscure the money trail or integrate illicit proceeds.”(CAMS 6th Edition, ML/TF Red Flags in Life Insurance)

Incorrect Options:

B: Having multiple policies is common and not itself a red flag.

C: High premiums/payouts are not inherently suspicious.

E: Beneficiary payouts to elderly people are not ML/TF red flags.

The vulnerability of insurance products to money laundering is typically assessed based on purpose and intended use, liquidity (how easily funds can be accessed or moved), and customer anonymity or use of third-party transactions, as these factors can be exploited to disguise illicit funds.