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The board of directors at a large bank wants to improve the bank's practices for managing money laundering and financial terrorism (ML/FT) risk. The risk committee of the bank meets to discuss ways to achieve this objective that conform to best practices. Which of the following actions would be most appropriate for the bank to recommend?
A
Require the bank's business units to screen potential employees as part of the first line of defense in managing ML/FT risk.
B
Establish a threshold transaction value and review all transactions above this threshold for evidence of ML/FT.
C
Exclude politically exposed persons (PEPs) from screening for ML/FT risk due to their much lower ML/FT risk.
D
Give the compliance and legal functions the primary responsibility for managing ML/FT risk.