nerdexam
ACAMS

CAMS · Question #659

To ensure the independence of an audit for an AML program those involved in the audit would best be described as being:

The correct answer is A. not Involved in the organizations AML compliance program and having a reporting line to the. AML audit independence requires auditors to be fully separated from the entire AML compliance program - not just one component of it - and to report to a governance body independent of AML management.

AML/CFT Compliance Programs

Question

To ensure the independence of an audit for an AML program those involved in the audit would best be described as being:

Options

  • Anot Involved in the organizations AML compliance program and having a reporting line to the
  • Bnot involved in the organizations AML compliance program and having a reporting line to the
  • Cnot involved in the organization's suspicious activity report filing process and having a reporting
  • Dnot involved in the organization's suspicious activity report filing process and having a reporting

How the community answered

(45 responses)
  • A
    78% (35)
  • B
    4% (2)
  • C
    11% (5)
  • D
    7% (3)

Why each option

AML audit independence requires auditors to be fully separated from the entire AML compliance program - not just one component of it - and to report to a governance body independent of AML management.

Anot Involved in the organizations AML compliance program and having a reporting line to theCorrect

True audit independence requires that auditors have no involvement in any part of the AML compliance program they are reviewing, eliminating self-review bias across all program components. The reporting line must lead to a sufficiently senior and independent body - such as the board audit committee - so that findings cannot be influenced or suppressed by AML management. This dual criterion of complete functional separation and an independent reporting line is the recognized standard for objective AML audit governance.

Bnot involved in the organizations AML compliance program and having a reporting line to the

While this choice appears nearly identical in the visible truncated text, the answer key designates A as correct, indicating the untruncated version of B contains a qualification or reporting-line destination that falls short of the full independence standard required.

Cnot involved in the organization's suspicious activity report filing process and having a reporting

Restricting auditor exclusion only to the SAR filing process still permits involvement in other AML compliance program areas, leaving auditors susceptible to self-review conflicts when those areas are assessed.

Dnot involved in the organization's suspicious activity report filing process and having a reporting

Limiting the exclusion requirement to the SAR filing process rather than the entire AML compliance program is an insufficiently broad independence standard and exposes the audit to conflicts of interest across the remaining program components.

Concept tested: Independence requirements for AML program audit function

Source: https://www.fatf-gafi.org/en/recommendations/gafi-recommendations.html

Topics

#AML audit#audit independence#reporting structure#compliance program

Community Discussion

No community discussion yet for this question.

Full CAMS Practice