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…

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.

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.

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.

Responding that AML responsibilities are covered in the firm's mandatory annual training demonstrates to the examiner that a documented, recurring mechanism already exists to ensure all personnel - regardless of department - understand their AML obligations. Regulators assess whether employees are actually informed of their duties, and a robust training program that explicitly addresses those responsibilities can satisfy the intent of the finding without requiring job description amendments as the sole remedy.