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An international bank is investigating a payment requested by one of its correspondent relationships that generated an alert in the automated transaction monitoring system. The payment originated from a corporation located in Hong Kong, and the final beneficiary is an individual in New York. Which steps should the bank take first to address the alert? (Select Three.)
Correct Answer: B,C,D
Correspondent banking relationships present high money laundering risks, requiring enhanced due diligence (EDD) when monitoring cross-border transactions. Option B (Correct): Verifying that neither the sender nor the receiver is on a sanctions list is a mandatory AML check. Option C (Correct): Requesting invoices and contracts helps establish the legitimacy of the transaction and ensures funds are being used for their stated purpose. Option D (Correct): Conducting adverse media checks can reveal past financial crime links or regulatory issues related to the sender or beneficiary. Why Other Options Are Incorrect: Option A (Incorrect): Calling the individual is not a standard AML procedure and may violate privacy laws. Option E (Incorrect): 314(b) information sharing applies only to U.S. financial institutions-the bank should first conduct its internal review before escalating internationally. Best Practices for Investigating Suspicious Correspondent Banking Transactions: Check for links to known money laundering typologies. Verify business relationships using supporting documentation. Ensure transaction transparency through KYC/CDD measures. Reference: FATF Recommendation 13 (Correspondent Banking AML Requirements) USA PATRIOT Act Section 314(b) on Information Sharing Wolfsberg Group Guidance on Cross-Border Transaction Monitoring