Which should the external auditor recommend to ensure that the institution did not facilitate transactions involving a sanctioned person?

Which should the external auditor recommend to ensure that the institution did not facilitate transactions involving a sanctioned person?
A . Re-screen all transactions over the period of time when the updated sanction lists were not uploaded against the current sanctions lists.
B . Perform a security risk and access assessment on the sanction screening tool to ensure more timely sanctions lists are uploaded.
C . Re-screen all transactions based on the sanctions lists that were active at that time but not uploaded.
D . Periodically monitor the sanctions lists uploaded by the screening tool to ensure the most up-to-date lists are in the system.

Answer: A

Explanation:

Recommended Action:

Re-screening ensures compliance with sanctions and identifies potential violations retrospectively.

This is a critical regulatory requirement for addressing gaps in screening coverage.

FATF and Basel Guidelines:

Emphasize retrospective reviews in cases of system lapses to maintain the integrity of the sanctions compliance program.