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CAMS · Question #283

CAMS Question #283: Real Exam Question with Answer & Explanation

The correct answer is B. MLROs can be held to an individual accountability standard and face potential penalties for. MLROs are responsible for implementing and enforcing an appropriate risk-based approach for their firm, ensuring compliance with the relevant laws and regulations, and reporting any suspicious activities to the authorities. If they fail to discharge their duties, they may face pe

Question

A Money Laundering Reporting Officer's (MLRO) lack of action led to deficiencies in the bank's AML program and a civil monetary penalty being levied against the MLRO. Why was this direct action taken against the MLRO?

Options

  • AThe MLRO is the only individual that can be held responsible for AML program deficiencies.
  • BMLROs can be held to an individual accountability standard and face potential penalties for
  • CThe MLRO agreed to the civil penalty so that the bank would not be found liable for the AML
  • DAction was brought against the MLRO because banks cannot be found liable for AML program

Explanation

MLROs are responsible for implementing and enforcing an appropriate risk-based approach for their firm, ensuring compliance with the relevant laws and regulations, and reporting any suspicious activities to the authorities. If they fail to discharge their duties, they may face personal liability and civil or criminal sanctions. MLROs are not the only individuals that can be held responsible for AML program deficiencies, as other senior managers, directors, or partners may also be liable depending on their role and involvement. However, MLROs are often the primary focus of enforcement actions due to their specific responsibilities and obligations. MLROs cannot avoid liability by agreeing to a civil penalty, as this does not absolve them from their legal duties or potential criminal prosecution. Banks can also be found liable for AML program deficiencies and face fines, penalties, or other sanctions.

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