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CAMS · Question #80

CAMS Question #80: Real Exam Question with Answer & Explanation

The correct answer is D. Reply that a description of anti-money laundering responsibilities is included in the annual training. When a regulatory examination finding states that non-compliance job descriptions lack AML references, the appropriate response is to demonstrate that AML responsibilities are already formally communicated through the annual training program.

Question

Findings from a regulatory examination report states that the job descriptions of personnel outside of the compliance department do not include references to anti-money laundering responsibilities. Which action should the firm take?

Options

  • AUpdate all job descriptions to include anti-money laundering responsibilities
  • BRespond that only compliance personnel have anti-money laundering responsibilities
  • CSend an email to all staff stating that personnel must observe the anti-money laundering policy
  • DReply that a description of anti-money laundering responsibilities is included in the annual training

Explanation

When a regulatory examination finding states that non-compliance job descriptions lack AML references, the appropriate response is to demonstrate that AML responsibilities are already formally communicated through the annual training program.

Common mistakes.

  • A. Updating all job descriptions addresses the symptom of the finding but does not demonstrate to the examiner that the firm already has effective controls communicating AML responsibilities, which is the core regulatory concern.
  • B. Asserting that only compliance personnel hold AML responsibilities directly contradicts the foundational AML principle that all employees share an obligation to identify and escalate suspicious activity, making this response factually incorrect and potentially damaging.
  • C. A one-time informal email is not a systematic or documented compliance control, and regulators expect recurring, auditable training programs rather than ad hoc communications as evidence of AML responsibility awareness.

Concept tested. AML responsibility communication to all firm personnel

Reference. https://www.fatf-gafi.org/content/dam/fatf-gafi/guidance/Guidance-AML-CFT-Measures-and-Financial-Inclusion-2013.pdf

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