Câu 26: 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. Which conclusion should the auditor make regarding the staff attendance of the periodic AML training program organized by the financial institution?

1. A. Staff attendance is incomplete because the compliance officer or the delegates are not part of the staff facilitating the 3-hour periodic AML training.
2. B. Staff attendance is complete because the training is mandatory for staff in the business, operations, compliance and senior management whose duties involve knowledge of AML controls and processes. — đáp án hiện tại
3. C. Staff attendance is incomplete because the board of directors is not part of the staff required to attend the periodic trainings, and there is no other specially designed AML training for the board.
4. D. Staff attendance is complete because all staff in the institution are required to attend the AML training as part of the staff onboarding process.