Câu 9: 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. When sample testing client transaction records, the auditor finds that a client offered to sell a piece of art on a commission basis. A sale was completed and the purchase price was remitted to the client with less commission. What further investigation should the auditor undertake?

1. A. Review procedures for accepting commission sales and determining the buyer’s source of funds on a best effort basis.
2. B. Commission an external investigator to perform enhanced due diligence on the buyer.
3. C. Update the national art registry with the sale price of the art work so that art-based money laundering can be detected.
4. D. Perform enhanced due diligence on the seller and buyer and update client records with findings. — đáp án hiện tại