CAMS: Certified Anti-Money Laundering Specialist Exam - Question Answered

Consequences for Financial Institutions in Case of Employee Involvement

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Question

A director of a financial institution was convicted of laundering money as part of a Ponzi scheme and terminated. As a result of an internal investigation evidence proved that an employee assisted in the illegal activity.

Which action should the institution take?

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Explanations

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A. B. C. D.

B

In this scenario, a director of a financial institution has been convicted of money laundering in connection with a Ponzi scheme and subsequently terminated from their position. During an internal investigation, evidence emerged that implicates another employee in assisting with the illegal activity. The question asks what action the institution should take in response to this situation.

Let's analyze each of the provided answers:

A. Discipline the employee with no further action: Disciplining the employee without taking any further action may not be appropriate in this case. Money laundering is a serious crime with potential legal and reputational consequences for the institution. Merely disciplining the employee may not adequately address the seriousness of their involvement or prevent similar incidents in the future. Therefore, this answer option seems insufficient.

B. Discipline the employee and inform local authorities: This answer option acknowledges the gravity of the situation and takes appropriate action. Disciplining the employee internally is necessary to address their involvement in the illegal activity. Additionally, informing local authorities is crucial because money laundering is a criminal offense. Reporting the employee's actions can assist the authorities in their investigation and potentially contribute to a wider understanding of the Ponzi scheme. This answer option aligns with best practices for combating money laundering and is the most appropriate course of action.

C. Since the employee was not charged, no further action is required: This answer option is incorrect. The fact that the employee was not charged does not absolve the institution from taking appropriate action. Internal investigations often precede criminal charges, and the institution should still address the employee's involvement in the illegal activity. Not taking any further action would fail to mitigate risks associated with money laundering and could lead to ongoing vulnerabilities within the institution.

D. Require all employees to complete additional anti-money laundering training: While anti-money laundering (AML) training is essential for all employees in a financial institution, it may not be the most appropriate response to this specific situation. Requiring additional AML training for all employees is a good general practice, but it does not directly address the employee's involvement in the money laundering scheme. Instead, a more focused response, such as disciplining the employee and involving local authorities, is necessary to address the specific incident and mitigate any ongoing risks.

In conclusion, the most appropriate action for the financial institution in this scenario would be to discipline the employee involved in the illegal activity and inform local authorities. This response recognizes the seriousness of the offense, takes steps to address the employee's involvement, and cooperates with law enforcement to combat money laundering effectively.