ACAMS
CAMS · Question #951
CAMS Question #951: Real Exam Question with Answer & Explanation
The correct answer is B. The company is merging with or acquiring another entity. A merger or acquisition is the most critical trigger for a full AML program review because it fundamentally changes the company's risk profile, customer base, and business lines.
Question
In which of the following situations would it be most crucial for the designated AML compliance officer of a company to perform a complete review of the company's AML program, including identifying the risks and commensurate controls?
Options
- AAn external audit highlights several deficiencies
- BThe company is merging with or acquiring another entity
- CExtensive AML legislation is proposed by a legislative body in the company's jurisdiction
- DA high-profile money laundering case involving another industry is publicized
Explanation
A merger or acquisition is the most critical trigger for a full AML program review because it fundamentally changes the company's risk profile, customer base, and business lines.
Common mistakes.
- A. An external audit highlighting deficiencies would typically trigger targeted remediation of those specific gaps rather than requiring a full top-to-bottom program review.
- C. Proposed legislation has not been enacted and does not impose legal obligations; a full program review would be required only once the law is passed and effective, not during the proposal stage.
- D. A high-profile money laundering case in another industry may serve as a learning prompt but does not create a direct obligation or operational necessity to conduct a full internal AML program review.
Concept tested. AML program review triggers during mergers and acquisitions
Reference. https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html
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