What conclusion should the auditor make regarding AML training for outsourced AML providers?
A.
The approach outlined by the Dank is deficient, as the service providers are not pan of the Dank s AML training during its staff onboarding.
B.
The approach outlined by the Dank is appropriate as the Dank can rely on a professional service provider to deliver the AML training program for the Dank s staff.
C.
The approach outlined by the Dank is deficient, as it does not provide controls for the Dank to verify training delivered by outsourced providers to the bank's staff is appropriate.
D.
The approach outlined by the bank Is appropriate as it considers practical issues such as time zone differences and availability of both classroom and online sessions.
CAMS-Audit emphasizes that institutions must ensure outsourced providers deliver training aligned with internal policies and regulatory standards.
Control Mechanisms for Outsourced AML Providers:
The bank must have controls in place to:
Review the content of training sessions.
Validate trainer qualifications.
Assess the effectiveness of training through feedback or testing.
Deficiencies in the Current Approach:
Failure to implement verification mechanisms for outsourced training compromises the consistency and quality of the AML education program.
Regulatory Requirements:
FATF and Basel guidelines mandate oversight of third-party service providers, especially for critical functions like AML compliance training.
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