Which conclusion should the auditor make regarding the staff attendance of the periodic AML training program organized by the bank?
Which conclusion should the auditor make regarding the staff attendance of the periodic AML training program organized by the bank?
A . Staff attendance is complete because the training is mandatory for staff in the business, operations compliance and senior management whose duties involve knowledge of AML controls and processes.
B . Staff attendance is complete because all staff in the institution are required to attend the AML training as part of the staff onboarding process.
C . Staff attendance is incomplete because the board of directors is not part of the staff required to attend the periodic trainings, and there is no other specially designed AML training for the board.
D . Staff attendance is incomplete because the compliance officer or the delegates are not part of the staff facilitating the 3-hour periodic AML training.
Answer: C
Explanation:
Importance of AML Training for All Levels of an Institution:
Advanced CAMS-Audit and FATF emphasize that AML training programs should be inclusive of all
stakeholders, including senior management and board members, as they are integral to establishing
an effective AML/CFT compliance culture.
Board-Level Training Specifics:
Directors require tailored AML training to address strategic oversight responsibilities rather than operational controls. Periodic training is mandatory to keep the board updated on regulatory changes and institutional risk profile adjustments. Audit Observation:
Exclusion of the board from AML training reflects a gap in the institution’s AML framework,
potentially exposing it to regulatory scrutiny.
Reference to AML/CFT Standards:
FATF Recommendations mandate training for all levels of an institution, explicitly highlighting senior management and governance roles in compliance efforts.
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