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In order to prevent financial crime risk, the implemented policies, controls, and procedures must:

In order to prevent financial crime risk, the implemented policies, controls, and procedures must:

A.

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

B.

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

C.

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

D.

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

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