The new compliance officer has reviewed the bank's anti-money laundering training program. The program consists of online training for all new employees within
30 days of hire date and annual refresher training to all employees. In addition, there is specialized training for areas that deal with higher risk products and customers.
Over the last year, there have been no regulatory changes and no new products or services have been introduced. The compliance officer wants to propose to the board of directors that the annual refresher training is still current and can be delivered unchanged to all employees.
Which two critical pieces of information could be missed by taking this approach? (Choose two.)
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A. B. C. D.BC
The compliance officer's proposal to deliver the annual refresher training unchanged to all employees without any review could miss two critical pieces of information. The two potential critical pieces of information are:
A. Any new trends, developments, or risks: Money laundering and terrorist financing methods and trends are constantly evolving. Criminals and terrorists are constantly looking for new ways to exploit financial systems to launder money or finance their activities. The compliance officer must stay up-to-date with new trends, developments, and risks to be able to effectively train employees on how to recognize and report suspicious activities. If there have been any new trends or developments in the past year, such as changes in the modus operandi of criminal groups, or new emerging risks, the compliance officer should update the training materials accordingly.
C. Changes to internal policies, procedures, and processes: Internal policies, procedures, and processes can change for various reasons, such as changes in the organization's structure, changes in regulatory requirements, or changes in business strategies. These changes can have an impact on the bank's anti-money laundering program, and employees need to be aware of them to ensure compliance. If there have been any changes in the bank's internal policies, procedures, or processes, the compliance officer should update the training materials accordingly.
Therefore, if the compliance officer proposes to deliver the annual refresher training unchanged to all employees without reviewing the training materials, the bank's employees may miss any critical updates on new trends, developments, risks, and changes to internal policies, procedures, and processes that could impact the effectiveness of the anti-money laundering program. Thus, it is crucial to regularly review and update training materials to ensure that employees receive the most current and relevant training to prevent money laundering and terrorist financing.