Câu 25: Advanced CAMS - Audit

AML Training Policy Excerpt -All new staff joining the bank must complete the onboarding compliance orientation training which covers basics of AML compliance and the AML program of the bank. Periodic 3-hour classroom or online AML trainings are provided to the business, covering relevant AML regulatory requirements, and the bank’s internal policies, procedures, and processes. Key elements covered in the training program include:Local regulatory developments -CDD -Transaction monitoring -Compliance’s process of reporting suspicious behavior to the local financial investigation unitAll operations staff, compliance staff, and senior management whose duties require knowledge of AML controls and processes are also required to attend one of the periodic 3-hour AML trainings.Ad-hoc, abbreviated AML trainings conducted by the compliance officer or compliance team delegates are available on an as-needed basis. All staff are required to pass the exam conducted at the end of the training. Staff must receive a score of 90% or above to pass the exam. Staff who do not pass the exam must attend a follow-up training, typically scheduled in the following month. A report of staff attendance and training details are sent to the board of directors for their records. AML trainings for outsourced providers are fully managed by the service provider, due to constraints such as time-zone differences. Records of training conducted including attendees and the type of training provided must be maintained for a minimum of 5 years. Training records are maintained by the human resources department in the centralized learning management system. All AML training is made available as classroom sessions or online courses.Note: Non-attendance of mandatory AML training will impact staff performance ratings. What conclusion should the auditor make regarding AML training for outsourced AML providers?

1. A. The approach outlined by the financial institution is deficient, as the service providers are not part of the bank’s AML training during its staff onboarding.
2. B. The approach outlined by the financial institution is appropriate, as it considers practical issues such as time zone differences and availability of both classroom and online sessions.
3. C. The approach outlined by the financial institution is appropriate, as the bank can rely on a professional service provider to deliver the AML training program for the bank’s staff.
4. D. The approach outlined by the financial institution is deficient, as it does not provide controls for the bank to verify training delivered by outsourced providers to the bank’s staff is appropriate. — đáp án hiện tại