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Which level of an organization is ultimately responsible for risk oversight?
The ultimate responsibility for risk oversight lies with the Board of Directors. Senior management and the board have the fiduciary and governance duty to ensure that an effective risk management framework, including AML/CFT controls and cryptoasset-specific risks, is in place and functioning properly.
The DFSA GEN Module and AML Module explicitly allocate the highest accountability for compliance and risk oversight to the Board of Directors, while first and second lines support implementation and oversight respectively. The Chief Risk Officer (CRO) supports risk management but the board maintains ultimate accountability.
Key extracts:
GEN Module, Chapter 5: ''Responsibility for compliance lies with every member of senior management, with ultimate oversight by the Board.''
AML Module Section 1.2 & 4.1: ''Senior management and Board must ensure appropriate systems and controls for AML/CFT risk management.''
FATF Recommendation 2 underscores that senior management and boards are accountable for effective AML governanceGEN/VER64/05-24: Chapter 5; AML/VER25/05-24: Sections 1.2, 4.1.
Thus, D is the correct answer.