What conclusion should the auditor make regarding AML training for outsourced AML providers?
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 Danks 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.
Answer: C
Explanation:
Outsourced Training Oversight Requirements:
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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