Discuss Acams CAMS Exam Topic 1 Question 90

Findings from a regulatory examination report states that the job descriptions of personnel outside of the

compliance department do not include references to anti-money laundering responsibilities.

Which action should the firm take?

AUpdate all job descriptions to include anti-money laundering responsibilities

BRespond that only compliance personnel have anti-money laundering responsibilities

CSend an email to all staff stating that personnel must observe the anti-money laundering policy

DReply that a description of anti-money laundering responsibilities is included in the annual training

Suggested Answer: A

According to the ACAMS Study Guide, one of the essential elements of an effective anti-money laundering (AML) program is to assign clear roles and responsibilities to all staff members, regardless of their position or department1. This ensures that everyone is aware of their obligations and expectations in relation to AML compliance, and that they receive appropriate training and guidance. Therefore, the firm should update all job descriptions to include references to AML responsibilities, such as identifying and reporting suspicious activity, conducting customer due diligence, and adhering to AML policies and procedures.

The other options are not sufficient or correct, because:

B .Responding that only compliance personnel have AML responsibilities is incorrect, because AML compliance is not only the responsibility of the compliance department, but of the entire organization1. All staff members should be involved in the AML program and contribute to its effectiveness.

C . Sending an email to all staff stating that personnel must observe the AML policy is not sufficient, because it does not specify what the AML policy entails, or how it applies to different roles and functions. An email is also not a permanent or formal way of communicating AML responsibilities, and it may not reach all staff members or be taken seriously.

D . Replying that a description of AML responsibilities is included in the annual training is not sufficient, because it does not address the issue of the job descriptions, which should reflect the AML responsibilities of each position. Moreover, annual training may not be frequent or comprehensive enough to cover all aspects of AML compliance, and it may not be tailored to the specific needs and risks of each role or department.

1: ACAMS Study Guide, 6th Edition, Chapter 2: Developing an Effective Anti-Money Laundering Program, page 49.

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33 comments · newest first

Leandro 11 months ago

Updating job descriptions is a must for compliance.

Vallie 11 months ago

But does everyone really need to know about AML?

Carmen 11 months ago

I’m surprised this wasn’t already done!

Jess 12 months ago

Totally agree, it’s essential for everyone to be aware.

Genevieve 1 year ago

All job descriptions should include AML responsibilities.

Omer 1 year ago

I recall that compliance responsibilities should be clearly defined, but I wonder if just relying on annual training is sufficient.

Charlesetta 1 year ago

This reminds me of a practice question where we had to clarify roles in compliance. I feel like option A might be the best choice here.

Norah 1 year ago

I'm not entirely sure, but I think just sending an email might not be enough to cover the regulatory requirements.

Ezekiel 1 year ago

I remember discussing the importance of clear job descriptions in compliance training. Updating them seems like the right move.

Cordie 1 year ago

Updating the job descriptions is definitely the way to go. We need to make it clear that anti-money laundering is a responsibility for everyone, not just the compliance team. That's the most direct way to address this finding.

Linsey 1 year ago

I'm a bit confused on this one. Does the annual training already cover the anti-money laundering responsibilities? If so, maybe that's the easiest fix. But updating the job descriptions seems like the safest bet.

Gayla 1 year ago

I think the key here is to make sure all staff are aware of the anti-money laundering policy, so sending an email might be a good approach. But updating the job descriptions is probably the most comprehensive solution.

Peter 1 year ago

Hmm, I'm not sure. Option B seems like it could be a valid response, since the report only mentions personnel outside of compliance. But I'm not totally confident in that.

Rodolfo 1 year ago

This seems straightforward - we need to update all job descriptions to include anti-money laundering responsibilities. That's the best way to address the finding.

Vivan 2 years ago

I think sending an email to all staff stating the policy would also be a good idea to ensure everyone is informed.

Eun 2 years ago

I agree with Derrick, it's important for all staff to be aware of their anti-money laundering responsibilities.

Eun 2 years ago

Option B? Seriously? As if only the compliance folks need to care about money laundering. Nice try.

Laurel 2 years ago

↳ replying to Eun

D) Reply that a description of anti-money laundering responsibilities is included in the annual training

Marguerita 2 years ago

↳ replying to Eun

C) Send an email to all staff stating that personnel must observe the anti-money laundering policy

Laquanda 2 years ago

↳ replying to Eun

A) Update all job descriptions to include anti-money laundering responsibilities

Derrick 2 years ago

We should update all job descriptions to include anti-money laundering responsibilities.

Omer 2 years ago

Haha, imagine sending an email to everyone about AML - like they'll actually read it, right?

Tarra 2 years ago

D sounds like the easy way out. We can't just rely on annual training, gotta make it part of everyone's job description.

Keith 2 years ago

I agree, Option A is the best choice. Clearly defining AML duties for all personnel is essential.

Cecil 2 years ago

↳ replying to Keith

Definitely. It's better to be proactive and make sure everyone is on the same page.

Freeman 2 years ago

↳ replying to Keith

Agreed. It will help ensure that all staff understand the importance of compliance.

Oliva 2 years ago

↳ replying to Keith

I think so too. It's important for everyone to be aware of their AML responsibilities.

Helene 2 years ago

↳ replying to Keith

Option A is definitely the way to go. Updating job descriptions is crucial.

Galen 2 years ago

Option A is the way to go. Updating all job descriptions to include AML responsibilities is crucial for compliance.

Nobuko 2 years ago

↳ replying to Galen

It's better to be proactive and make sure all job descriptions are up to date.

Carma 2 years ago

↳ replying to Galen

Updating job descriptions will ensure everyone knows what is expected of them.

Willodean 2 years ago

↳ replying to Galen

Yes, I agree. It's important for all staff to be aware of their AML responsibilities.

Veronika 2 years ago

↳ replying to Galen

Option A is the way to go. Updating all job descriptions to include AML responsibilities is crucial for compliance.

Acams CAMS Exam - Topic 1 Question 90 Discussion