Which implementation measure is appropriate for concentration accounts?

Which implementation measure is appropriate for concentration accounts?

• A. Retaining appropriate transaction and customer identifying information.
• B. Prohibiting direct customer access to concentration accounts.
• C. Implementing a customer credit scoring model for loans.
• D. Publishing customer names publicly.

Answer: (A)

The key idea is that AML controls for concentration accounts must preserve detailed records that tie each transaction to the specific customer. Retaining appropriate transaction records and customer identifying information provides the essential trail needed to trace funds, verify who owns or controls the accounts, and assess whether activity appears legitimate or suspicious. This enables effective monitoring, due diligence, and, if needed, timely filing of suspicious activity reports. Other options miss the mark because they don’t directly support the monitoring and investigation needs of concentration accounts: restricting access is a helpful control but doesn’t ensure traceability; applying a loan credit scoring model addresses credit risk rather than AML monitoring; publicly publishing customer names raises privacy and regulatory concerns and isn’t an AML measure.

The key idea is that AML controls for concentration accounts must preserve detailed records that tie each transaction to the specific customer. Retaining appropriate transaction records and customer identifying information provides the essential trail needed to trace funds, verify who owns or controls the accounts, and assess whether activity appears legitimate or suspicious. This enables effective monitoring, due diligence, and, if needed, timely filing of suspicious activity reports.

Other options miss the mark because they don’t directly support the monitoring and investigation needs of concentration accounts: restricting access is a helpful control but doesn’t ensure traceability; applying a loan credit scoring model addresses credit risk rather than AML monitoring; publicly publishing customer names raises privacy and regulatory concerns and isn’t an AML measure.