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CAMS · Question #577

A financial institution in a jurisdiction with currency reporting thresholds is undergoing a branch office compliance review. A large number of currency transactions in amounts exceeding a reporting…

The correct answer is B. An audit should be conducted for cash transactions since the last compliance review. The compliance officer should recommend an audit for cash transactions since the last compliance review, as this would help to identify the extent of the problem, the root causes, and the potential risks involved. The audit would also provide evidence for corrective actions and…

Conducting and Responding to Investigations

Question

A financial institution in a jurisdiction with currency reporting thresholds is undergoing a branch office compliance review. A large number of currency transactions in amounts exceeding a reporting threshold were discovered without a currency transaction report (CTR) being filed. The transactions were handled by the same teller (cashier). This teller (cashier) was recently hired and had not received anti-money laundering training yet. The branch manager received daily exception reports of all large currency transactions as well as a report of all CTR filings. Which of the following should the compliance officer recommend as the initial action?

Options

  • ATerminate the teller's (cashier's) employment prior to the expiration of the probation peri-od.
  • BAn audit should be conducted for cash transactions since the last compliance review.
  • CThe branch manager should be formally reprimanded for failing to ensure proper instruc-tion was
  • DThe teller's (cashier's) employment should be suspended with pay pending appropriate training.

How the community answered

(70 responses)
  • A
    10% (7)
  • B
    83% (58)
  • C
    4% (3)
  • D
    3% (2)

Explanation

The compliance officer should recommend an audit for cash transactions since the last compliance review, as this would help to identify the extent of the problem, the root causes, and the potential risks involved. The audit would also provide evidence for corrective actions and remedial measures to prevent future occurrences of non-compliance. The compliance officer should not recommend terminating or suspending the teller's employment, as this would be premature and disproportionate without a thorough investigation and due process. The compliance officer should not recommend formally reprimanding the branch manager, as this would not address the underlying issues and could create a hostile work environment.

Topics

#currency transaction report#compliance review#internal audit#unreported transactions

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