A retail bank has just acquired a credit card business. The bank's anti-money laundering policy requires that new employees are trained within 30 days of their hire date and refresher training is delivered to all employees on an annual basis.
Is the bank's existing anti-money laundering training adequate to be delivered to employees of the newly acquired credit card business?
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A. B. C. D.D
The answer to this question is C. No, anti-money laundering training needs to be tailored and focused on the risks specific to the business.
The rationale for this answer is as follows:
While it is true that the bank's anti-money laundering policy requires new employees to be trained within 30 days of their hire date and refresher training is delivered on an annual basis, this policy alone does not guarantee that the training is sufficient for the newly acquired credit card business.
Anti-money laundering training should be tailored to the specific risks of the business in question. Credit card businesses, in particular, have unique money laundering risks that may not be adequately addressed in a generic training program. For example, credit card businesses may be vulnerable to schemes involving fraudulent credit card applications, account takeovers, and money laundering through the purchase and resale of goods and services.
Furthermore, the acquisition of a new business often results in changes to the bank's risk profile and overall risk management strategy. These changes may necessitate updates to the bank's anti-money laundering policies and procedures, which would need to be reflected in the training provided to employees of the newly acquired credit card business.
Therefore, the bank should ensure that its anti-money laundering training for the newly acquired credit card business is tailored to address the specific risks of that business and that it reflects any changes to the bank's overall risk management strategy resulting from the acquisition.