Which actions are part of the PLM's AML responsibilities?

• A. Only file SARs when there is a confirmed crime
• B. AML is the responsibility of the compliance officer only
• C. Establish AML programs, train staff, monitor for suspicious activity, and file SARs as required
• D. Do not monitor for suspicious activity to avoid false alarms

Answer: (C)

Anti-money laundering obligations for a PLM require implementing a formal AML program, training staff, continuously monitoring for suspicious activity, and filing Suspicious Activity Reports when warranted. This reflects a risk-based, enterprise-wide duty under the Bank Secrecy Act, not a task for one person alone. Establishing the program includes policies, customer due diligence, transaction monitoring, and proper recordkeeping. Training helps staff recognize red flags such as unusual cash deposits, structuring, funds from unknown or high-risk sources, or complex corporate arrangements. Ongoing monitoring uses systems to detect unusual loan activity and fund movements, and when a red flag appears, a SAR must be filed with FinCEN as required, even without a confirmed crime. Limiting AML to filing only after a crime or assigning it solely to the compliance officer, or skipping monitoring, would miss regulatory requirements and expose the institution to risk.