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The manager of a bank's KYC team discovers that a high-risk customer's activity was not reviewed last quarter as required by the bank's internal compliance schedule. What should the KYC team manager do?
Correct Answer: D
Regular KYC reviews ensure that high-risk customers are monitored for potential changes in their risk profile. Option D (Correct): The KYC manager must determine why the required review was missed and implement corrective measures to prevent future failures. Option A (Incorrect): A missed review does not necessarily indicate suspicious activity, so filing a SAR at this stage is not appropriate. Option B (Incorrect): Removing a customer from the high-risk list without reassessment is a compliance violation. Option C (Incorrect): Suspending account access without due process may be legally questionable. Best Practices for KYC Compliance Management: Ensure automated KYC review tracking to avoid missed reviews. Conduct risk-based periodic reviews on high-risk customers. Implement escalation protocols for overdue KYC reviews. Reference: FATF Recommendation 10 (Customer Due Diligence) 6th EU AML Directive (6AMLD) on Periodic KYC Reviews Wolfsberg Group Guidance on KYC Risk Management