An anti-money laundering specialist has been hired by an independently-owned community bank to implement an anti-money laundering compliance program. This bank has recently seen a dramatic increase in the number of international electronic fund transfers from its commercial clients. The first thing the anti-money laundering specialist should do is
Correct Answer: B
The first thing the anti-money laundering specialist should do is to conduct a risk assessment of the bank's international electronic fund transfer activity. This is to identify and measure the potential money laundering and terrorist financing risks associated with the bank's products, services, customers, and geographic locations. A risk assessment can help the anti-money laundering specialist to:
Understand the nature and extent of the bank's exposure to money laundering and terrorist financing threats and vulnerabilities.
Establish a risk-based approach to the design and implementation of the anti-money laundering compliance program, including policies, procedures, controls, monitoring, reporting, and training.
Allocate appropriate resources and prioritize actions to mitigate the identified risks and enhance the effectiveness of the anti-money laundering compliance program.
Demonstrate to the regulators and auditors that the bank has a sound and comprehensive anti-money laundering compliance program that is commensurate with its risk profile and business activities.
Reference:
CAMS Study Guide - 6th Edition, Chapter 6, pages 167-168
CAMS Certification Exam Outline, Domain 3, Task 3.1, Skill 3.1.1
Anti-Money Laundering Bulletin November 2021 - Central Bank of Ireland, pages 4-5 Money Laundering through Money Remittance and Currency Exchange Providers, FATF, June 2010, pages 7-8 REGULATIONS - FIU, Part III, Regulation 9, pages 9-10