A compliance officer is looking to update an institution’s 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