Câu 8: Advanced CAMS - Audit

An auditor completes a review of the AML and sanctions program of a high-value goods dealer that specializes in precious metals, jewelry, fine art, and antiques. In addition to retailing, the dealer can also sell on a commission basis. The scope of the review is the full client lifecycle and application of the organization’s policies and procedures. The dealer has regular clients that are typically collectors and customers for occasional transactions. Several findings were identified across the client lifecycle, including inconsistent application of client risk assessment procedures, additional due diligence measures for higher risk clients, and transactions not being evidenced. The auditor was unable to sample recent occasional transactions as the transactions were completed and files were deleted. Which should the auditor recommend to management in terms of the client’s risk rating procedures?

1. A. Remediate client files to verify their AML and sanctions risk rating and document enhanced due diligence measures, where applicable. — đáp án hiện tại
2. B. Remove enhanced due diligence requirements for long-standing clients that are art collectors and do not transact with precious metals.
3. C. Include an assessment of risk factors of channel, credit, and transaction risk to determine the client’s composite AML and sanctions risk score.
4. D. Provide staff with training on new record retention requirements for occasional transactions.