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A U.S. bank recently received a regulatory order to remediate its AML programs, which included several violations of law. What degree of accountability is it possible for the bank's senior management and employees to face?
Correct Answer: A
Under U.S. AML laws, senior management and AML officers can face personal liability for compliance failures. Option A (Correct): If senior management was aware of violations but failed to act, they can be held personally liable under FinCEN regulations and the Bank Secrecy Act (BSA). Option B (Incorrect): Criminal prosecution depends on willful misconduct and does not apply automatically when a bank receives a regulatory order. Option C (Incorrect): Other senior executives (e.g., CEOs, compliance officers) can also be held liable, not just the AML officer. Option D (Incorrect): Criminal liability is possible for willful AML violations, not just civil penalties.