CAMS · Question #954
An AML compliance officer for a large bank has recently received an internal audit report on the private banking unit. The report revealed that the unit staff were not following risk-based due…
The correct answer is B. All employees should receive refresher AML training. C. The board should review and approve a revised AML policy to change customer due diligence. When an internal audit identifies that staff are not following risk-based due diligence procedures, the compliance officer must immediately address both the workforce knowledge gap through training and the adequacy of the governing policy through board-level review.
Question
An AML compliance officer for a large bank has recently received an internal audit report on the private banking unit. The report revealed that the unit staff were not following risk-based due diligence procedures, so that the unit was not operating effectively. Which immediate actions should the AML compliance officer consider to address these findings? (Select Two.) Management Should implement a quality assurance program in the private banking unit
Options
- APrivate bankers should receive training on AML procedures.
- BAll employees should receive refresher AML training.
- CThe board should review and approve a revised AML policy to change customer due diligence
- DThe legal department should conduct a review to assess potential legal consequences.
How the community answered
(48 responses)- A6% (3)
- B81% (39)
- D13% (6)
Why each option
When an internal audit identifies that staff are not following risk-based due diligence procedures, the compliance officer must immediately address both the workforce knowledge gap through training and the adequacy of the governing policy through board-level review.
Limiting training solely to private bankers addresses only the symptom in the specific unit rather than the broader institutional gap that an all-staff refresher and policy revision would remedy.
Refresher AML training for all employees corrects the knowledge and behavioral gaps identified in the audit and ensures consistent application of risk-based due diligence procedures across the institution, not just in the affected unit.
Board review and approval of a revised AML policy elevates the remediation to the governance level, ensures the due diligence framework is formally updated to reflect current regulatory expectations, and demonstrates institutional accountability for the deficiencies found.
A legal review to assess consequences is a secondary, reactive step that does not directly remediate the procedural failures or prevent their recurrence.
Concept tested: AML corrective action and governance response to audit findings
Source: https://bsaaml.ffiec.gov/manual/BSAAMLExaminationProcedures/01
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