By delivering the same annual refresher training to all employees, the compliance officer could miss the opportunity to update the staff on any new trends, developments, or risks that have emerged in the anti-money laundering field. For example, new typologies, indicators, technologies, or best practices could be relevant for the staff to be aware of and apply in their daily work. Moreover, the compliance officer could also miss the chance to share any links to enforcement actions identifying violations in other financial institutions that could serve as lessons learned or case studies for the staff to avoid similar mistakes or gaps in their compliance program.
ACAMS CAMS Certification Video Training Course, Module 5: Risk Management, Lesson 5.4: Training1 ACAMS CAMS Certification Study Guide, 6th Edition, Chapter 5: Risk Management, Section 5.4: Training2

Thetimely filing of SARs is legally mandated, and financial institutions mustfollow jurisdiction-specific reporting deadlines.
Option A (Correct):Regulatory requirements dictate SAR filing deadlines(e.g., in the U.S., SARs must be filed within30 calendar daysof detecting suspicious activity).
Option B (Incorrect):30 days is the U.S. standard, but different jurisdictions may havedifferent SAR deadlines (e.g.,EU AMLD mandates prompt reporting).
Option C (Incorrect):Complexity-based reporting delaysare not permitted if theyexceed regulatory timelines.
Option D (Incorrect):Relying solely on professional judgmentrather than regulatory rules can lead tonon- compliance.
SAR Filing Deadlines in Different Jurisdictions:
Jurisdiction
SAR Filing Deadline
United States (FinCEN)
30 calendar days(60 days if no suspect is identified)
United Kingdom (FCA/NCA)
As soon as practicable
European Union (6AMLD)
"Promptly" (no fixed number of days)
Australia (AUSTRAC)
3 business daysfor terrorism financing,14 business daysfor other cases
Why Timely SAR Filing Matters:
Delays in reporting can result in regulatory penalties.
Early SAR filing enables FIUs to take swift action against financial crime.
Non-compliance can lead to fines, criminal charges, and reputational damage.
Reference:
FATF Recommendation 20 (Reporting Suspicious Transactions)
FinCEN SAR Filing Requirements
6th EU Anti-Money Laundering Directive (6AMLD)

* Governance arrangements (A):"Sound governance and risk management arrangements are fundamental to assessing and managing ML/TF risk in products and services."(CAMS 6th Edition, Risk-Based Approach for Products and Services)
* Complexity of the products (B):"Complexity increases risk-products that are highly complex, opaque, or allow for multiple layers or jurisdictions are more vulnerable to misuse for ML/TF."( CAMS 6th Edition, Product Risk Assessment) Incorrect Options:
* C: Last audit results inform program effectiveness, not inherent product risk.
* D: Business financial status is considered in customer risk assessment, not product risk.
References:
CAMS 6th Edition, Product and Service Risk Assessment
FATF Guidance on Risk-Based Approach for Financial Institutions

Private investment companies (PICs) are potentially vulnerable to money laundering due to the difficulty in identifying the ultimate beneficial owners. PICs are often used to hold and manage private wealth, making them attractive targets for money launderers. Since these entities are privately held and not publicly traded, it can be challenging to identify the individuals who ultimately control or benefit from them. This makes it easier for money launderers to use them to disguise the origins of illicit funds.