AML audit findings must be analyzed and addressed through remedial actions based on root cause analysis.
Option D (Correct): Root cause analysis helps develop effective corrective measures to prevent recurring AML deficiencies.
Option A (Incorrect): Retesting controls may be useful, but addressing deficiencies is more critical.
Option B (Incorrect): While the board oversees compliance, the responsibility for implementing fixes lies with AML teams.
Option C (Incorrect): Audit teams provide findings but do not execute corrective actions.
Best Practices for Addressing AML Audit Findings:
Identify the root cause of AML control failures.
Develop risk-based remediation plans.
Implement and monitor corrective actions.
Reference:
FATF Recommendation 18 (AML Internal Controls & Audit)
Basel Committee's Guidelines on AML Audits
Wolfsberg Group Principles for AML Risk Management
Final Thoughts:
Suspicious stock price movements can indicate market manipulation linked to money laundering.
EU AML and GDPR regulations enforce strict data minimization and AI compliance requirements.
Bearer shares, nominee directors, and tax-haven corporations increase money laundering risks.
AML audit findings should be addressed through root cause analysis and corrective actions.

TheFATF 40 Recommendationsprovide aglobal AML/CFT framework, and theImmediate Outcomesassess effectiveness.
Option A (Correct):Therisk-based approach (RBA)is the foundation ofmodern AML complianceand is mandated byFATF Recommendation 1.
Option B (Incorrect):Interpretive notes are public documentsavailable to all jurisdictions, not private.
Option C (Incorrect):The40 Recommendations are regularly updated, incorporating new technology (e.g., virtual assets in 2019).
Option D (Incorrect):The11 Immediate Outcomesassess theeffectiveness of AML systems globally, not just for high-risk countries.
Reference:FATF 40 Recommendations (2012, Updated 2023), FATF Immediate Outcomes, FATF Risk- Based Approach Guidance.

The customer activity that should trigger a suspicious transaction report is purchasing travelers checks (cheques) for trips to a Non-Cooperative Countries and Territories (NCCTs). This could indicate an attempt to evade currency reporting requirements, avoid sanctions or embargoes, or facilitate money laundering or terrorist financingthrough high-risk jurisdictions12. NCCTs are countries or territories that have been identified by the Financial Action Task Force (FATF) as having serious deficiencies in their anti-money laundering and counter-terrorist financing regimes, and that pose a threat to the international financial system3.
The other options are not necessarily grounds for a suspicious transaction report, although they may require further due diligence or monitoring depending on the customer profile and the nature of the transaction. For example:
* The increased activity is due to money order deposits. This could be a legitimate source of income for the customer's export business, or it could be a way of disguising the origin or destination of the funds. The anti-money laundering specialist should verify the identity and background of the customer and the issuers of the money orders, and check for any red flags or suspicious indicators4.
* Wire transfers are coming from a Financial Action Task Force member country. This could be a normal business practice, or it could be a sign of involvement in trade-based money laundering or other illicit activities. The anti-money laundering specialist should assess the customer's source of funds, business rationale, and market conditions, and monitor for any changes or inconsistencies.
* The client changed his address without advising the institution. This could be a simple oversight, or it could be a way of concealing the customer's true location or identity. The anti-money laundering specialist should update the customer's information, verify the new address, and check for any adverse media or sanctions.
:
ACAMS CAMS Certification Video Training Course - Exam-Labs3
Exam CAMS: Certified Anti-Money Laundering Specialist (the 6th edition)4 ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 1, page 11: https://www.acams.
org/wp-content/uploads/2019/08/ACAMS-Study-Guide-6th-Edition-Chapter-1.pdf ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 2, page 29: https://www.acams.
org/wp-content/uploads/2019/08/ACAMS-Study-Guide-6th-Edition-Chapter-2.pdf ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 4, page 77: https://www.acams.
org/wp-content/uploads/2019/08/ACAMS-Study-Guide-6th-Edition-Chapter-4.pdf ACAMS Study Guide for the Certification Examination, 6th Edition, Chapter 5, page 97: https://www.acams.
org/wp-content/uploads/2019/08/ACAMS-Study-Guide-6th-Edition-Chapter-5.pdf

The best option for the compliance officer is to follow the financial institution's established STR reporting policy, which should include procedures for reporting suspicious activity involving senior management or board members. This would ensure that the compliance officer acts in accordance with the bank's internal controls and governance, and avoids any potential conflicts of interest or breaches of confidentiality. The other options are not advisable because they could either compromise the integrity of the STR filing, expose the compliance officer to legal or reputational risks, or alert the subject of the investigation.
:
ACAMS Study Guide for the CAMS Certification Examination, 6th Edition, Chapter 4, page 1401 ACAMS CAMS Certification Video Training Course, Module 4, Lesson 22 ACAMS CAMS Certification Practice Exam, Question 843

Money laundering can have negative effects on a country's currencies and interest rates, as it distorts the allocation of resources and the demand and supply ofmoney. According to the IMF1, money laundering can also adversely affect currencies and interest rates as launderers reinvest funds where their schemes are less likely to be detected, rather than where rates of return are higher. This can create artificial fluctuations and imbalances in the exchange and interest rates, and undermine the effectiveness of monetary policy. For example, if launderers invest in low-yield assets such as government bonds or real estate, they may drive up the prices and lower the yields of these assets, while reducing the availability of funds for more productive investments. This can also affect the inflation and growth prospects of the country.
:
1: Macroeconomic Implications of Money Laundering by Peter J. Quirk, IMF Working Paper, 1996
2: Understanding Money Laundering: How It Impacts the Global Economy by Tookitaki, 2019
3: Money Laundering by U.S. Department of the Treasury, 2021
4: The Consequences of Money Laundering and Financial Crime by John McDowell and Gary Novis, U.S.
Department of State, 2001