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All of the following are requirements for a broker-dealer's AML program EXCEPT: A the designation of a AML person who is responsible for creating and enforcing written AML procedures B annual independent compliance testing of the firm's AML procedures C ongoing training of personnel in the firm's AML procedures D annual background checks of all employees, both registered and unregistered

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Answer:

D annual background checks of all employees, both registered and unregistered

Explanation:

Anti Money Laundering programmes are put in place to prevent illegal transfer of funds that are usually sourced from criminal activities like illegal drug trade, human trafficking, robbery, and so on.

Financial institutions and brokers are required to adeher to AML programmes. The various requirements are:

- internal controls, policies, and procedures put in place for enforcing AML strategies

- policies designed to detect transactions in violation of AML guidelines

- AML compliance officer is to be appointed to enforce AML policies

- continuous AML training

- independent assessment of the company's AML programme

- ongoing due diligence on customers and their transactions including a Know Your Customer (KYC) framework.

It is not required to do a annual background checks of all employees, both registered and unregistered.

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