In general, what is an element that a financial institution or business does not have to specifically address in an anti-money laundering program?

In general, what is an element that a financial institution or business does not have to specifically address in an anti-money laundering program?
A . A system of internal policies, procedures and controls
B. A designated compliance officer with day-to-day oversight over the AML program
C. An ongoing employee training program
D. A description of its OFAC program to address government watch list screening

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Answer: D