A financial institution's (Fl's) policy is to apply enhanced due diligence (EDD) for every new client to ensure the effectiveness of the program. How should a consultant advise the Fl's management team?
Correct Answer: D
According to the Anti-Money Laundering Specialist (the 6th edition) study guide, a risk-based approach for EDD means that the FI applies more or less stringent measures depending on the level of risk posed by each client1. This allows the FI to allocate its resources more efficiently and effectively, and to focus on the clients that pose the highest risk of money laundering or terrorist financing2. Applying EDD for every new client, regardless of their risk profile, may not be the best use of the FI's resources, and may not reflect the proportionality and relevance of the EDD measures3.
References:
1: CAMS Study Guide, 6th Edition, Chapter 3, Section 3.2, page 69
2: CAMS Study Guide, 6th Edition, Chapter 3, Section 3.3, page 70
3: CAMS Study Guide, 6th Edition, Chapter 3, Section 3.4, page 71