CAMS · Question #987
A bank is preparing for a regulatory exam after a previous regulatory exam identified weaknesses in the bank's AML program. Since the last exam, the bank has improved the written AML program, hired…
The correct answer is B. The bank may face civil or criminal penalties if it is unable to demonstrate sustained improvement C. The bank may face the risk of regulatory orders to remediate its AML program despite addressing. B: If a bank fails to demonstrate sustained improvement or cannot resolve identified deficiencies, it can face civil or even criminal penalties from regulators. Regulators expect not just policy changes, but proof of effectiveness and ongoing compliance improvements. C: Even…
Question
A bank is preparing for a regulatory exam after a previous regulatory exam identified weaknesses in the bank's AML program. Since the last exam, the bank has improved the written AML program, hired an experienced AML compliance officer, and has taken actions to demonstrate a strong culture of compliance. The bank is now focused on getting through their transaction monitoring case backlog and completing enhancements to its sanctions screening program. Which of the following are correct? (Select Two.)
Options
- AThe bank is likely to face secondary sanctions from global financial institutions despite addressing
- BThe bank may face civil or criminal penalties if it is unable to demonstrate sustained improvement
- CThe bank may face the risk of regulatory orders to remediate its AML program despite addressing
- DThe bank is protected from reputational risk arising from any regulatory action because regulatory
- EThe regulatory agency may require the bank's board of directors to publicly share the actions
How the community answered
(33 responses)- A12% (4)
- B76% (25)
- D3% (1)
- E9% (3)
Explanation
B: If a bank fails to demonstrate sustained improvement or cannot resolve identified deficiencies, it can face civil or even criminal penalties from regulators. Regulators expect not just policy changes, but proof of effectiveness and ongoing compliance improvements. C: Even after addressing many concerns, if all issues are not resolved--such as outstanding transaction monitoring backlogs--regulators may issue orders to further remediate the AML program until full compliance is achieved. CAMS 6th Edition and regulatory guidance clarify that "regulators may impose penalties, issue consent orders, or require further remediation where weaknesses persist."
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