CAMS · Question #941
Which of the options below is an indicator of potential insider activity that may warrant escalation For further investigation?
The correct answer is A. A relationship manager advocates for overriding the results of the company's client risk rating. A relationship manager pushing to override the institution's client risk rating is a direct red flag for insider activity, as it indicates an attempt to circumvent established AML controls.
Question
Which of the options below is an indicator of potential insider activity that may warrant escalation For further investigation?
Options
- AA relationship manager advocates for overriding the results of the company's client risk rating
- BAn If employee shares information about a firm's risk management framework with employees of
- CAn investigator does not complete the automated transaction monitoring system alerts assigned
- DA relationship manager makes an exception to company policy and proceeds with onboarding a
How the community answered
(26 responses)- A73% (19)
- B4% (1)
- C15% (4)
- D8% (2)
Why each option
A relationship manager pushing to override the institution's client risk rating is a direct red flag for insider activity, as it indicates an attempt to circumvent established AML controls.
Advocating to override the results of an automated client risk rating system is a hallmark insider threat indicator because it represents a deliberate attempt to circumvent the institution's risk management controls for a specific client. This behavior suggests the employee may be acting in the interest of a high-risk client rather than the institution, which warrants escalation and further investigation under AML insider threat frameworks.
Sharing information about the firm's risk management framework with other employees is a routine internal activity and does not by itself constitute suspicious insider behavior without evidence of unauthorized or malicious disclosure.
Failing to complete assigned transaction monitoring alerts reflects a performance or compliance deficiency - such as workload issues or negligence - rather than an intentional act indicative of insider facilitation of financial crime.
While making policy exceptions during onboarding can be a compliance concern, authorized exception-handling procedures exist at many institutions, making this less definitive as an insider activity indicator compared to directly overriding risk rating outcomes.
Concept tested: Insider threat indicators in AML compliance programs
Source: https://www.fatf-gafi.org/en/publications/Methodsandtrends/Ml-tf-vulnerabilities-professional-money-laundering.html
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