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include sophisticated and automated controls that use the newest types of technology available (for example, artificial intelligence (Al) and machine learning).

be proportionate with regard to the size and nature of the firm, approved by senior management, and regularly reviewed

be completed by the business and validated by an external firm (for example, an auditing or consulting firm)

be created approved, and owned only by the First Line of Defense business team, and reviewed annually

Section 314(a)

Section 314(b)

Section 319(b)

Section 319(a)

Trade-based money laundering

Corruption

Illicit resource trade

Environmental crime

The principal activities of the proposed company are importing and exporting new furniture

The prospective client presents confusing details about the proposed business and has very little knowledge about the proposed business activity

The prospective client is unable to provide information about the beneficial owners

The prospective client exhibits confidence when speaking to the accountant when providing personal details

The prospective client is able to provide source of funds and source of wealth documents