Who of the following should be screened periodically?

An effective AML/CFT program relies on robust internal controls, which include measures to mitigate risks posed by internal actors. Employees, particularly those in sensitive or high-risk roles, should be screened not only upon hiring but also periodically throughout their employment. This ongoing screening helps to identify any changes in an employee's circumstances (e.g., new criminal convictions, financial distress, or inclusion on a sanctions list) that could make them a higher risk to the institution. This practice is a critical safeguard against internal fraud, collusion, and other insider threats that could compromise the AML/CFT program.

B. While all customers are subject to ongoing monitoring, the term "loyal" is irrelevant, and periodic screening is a distinct internal control process most critically applied to employees.

C. The Board of Directors is screened, typically at appointment and upon changes, but the routine, periodic screening of the broader employee base is a more standard operational control.

D. The CEO and Directors are a subset of the Board of Directors and senior management; "Employees" is a broader and more fundamental group requiring periodic screening.

1. ACAMS CAMS6 - Certified Anti-Money Laundering Specialist Study Guide, 6th Edition, (2020). Chapter 4, "Designing a Comprehensive AML/CTF Program," pp. 132-134. The guide discusses employee conduct and the importance of screening as a key internal control.

2. Wolfsberg Group. (2017). Anti-Bribery and Corruption Compliance Programme Guidance. Section 3.2 "Risk-based Human Resources Processes," p. 10. This guidance recommends screening of employees in relevant roles on a periodic basis.

3. Financial Action Task Force (FATF). (2012-2023). International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation. Recommendation 18. This recommendation covers internal controls, including screening procedures to ensure high standards when hiring employees.