Acams Advanced-CAMS-Audit Exam - Topic 2 Question 31 Discussion
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.
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.
Myra
1 month ago