Advanced CAMS-Audit Exam Set One

Cams Audit Quiz 37 Covered-
REPORTING, RECOMMENDATIONS, AND FOLLOW-UP (15%):
_How to determine the level of risk of findings,
including self-identified issues (i.e., low risk/
medium risk/high risk; severity and likelihood)
and distinguish between material and immaterial
findings to make recommendations addressing
root causes and the risk
_How to document the testing methodology
and results in the audit work papers (e.g., how
to ensure exceptions are properly identified,
retaining supporting evidence for the audit
planning and fieldwork)

By Exam Team

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Topics Covered

AML Audit and Third Line of Defense Responsibilities

  1. Roles and Responsibilities of the Third Line of Defense

    • 1.1 Understanding the roles and responsibilities of the third line of defense, including providing assurance, managing conflicts of interest in audit, and differentiating the third line from the first and second lines of defense. This includes independent testing vs. quality assurance, and the relationship with regulators, management, and the Board of Directors. Independence and factors that could jeopardize independence are also key considerations.
  2. Key International Bodies and Documents Related to AML Audit

    • 1.2 Familiarity with international bodies, organizations, and key documents related to AML audit, such as FATF, OFAC, FFIEC, European Directive on AML, UK JMLSG, and Wolfsberg Principles on Risk Assessment/Sanctions Screening.
  3. AML Program Governance Structure

    • 1.3 Understanding the governance structure of an AML program, including reporting lines, committees, training, and oversight of outsourced functions. This applies to in-house departments (e.g., Client Onboarding) as well as third-party vendors (e.g., those performing sanctions screening on behalf of the institution).
  4. Audit Triggers

    • 1.4 Identifying factors that trigger an audit, such as those mandated by legislation or regulators, cyclic audits, one-off audits, implementation of new AML systems/solutions, new legislation, and distinguishing these from factors that trigger assurance reviews.
  5. Stages of the AML Audit Process

    • 1.5 Understanding the stages of an AML audit process, which include preparation, planning/scoping, fieldwork/testing, making recommendations, reporting, and post-report tracking and validation.
  6. Internal vs. External Auditing

    • 1.6 Recognizing the differences and similarities between internal and external auditing, including the internal audit function vs. external audit firms, and the relationships between internal and external auditors and the institution.
  7. Types of Audit Approaches

    • 1.7 Familiarity with different types of audit approaches, such as risk-based, proportionate, and continuous audits, as well as the execution of horizontal, vertical, thematic, and project/program reviews.
  8. Audit Documentation Process

    • 1.8 Understanding the audit documentation process, which includes documenting an audit work program/plan, identifying relevant stakeholders, specifying audit objectives, and outlining risks and their mitigations.
  9. Emerging Risks and New Typologies

    • 1.9 Awareness of emerging risks from new typologies, such as FinTech, cyber threats, and cryptocurrencies, as well as new regulatory guidance/requirements, and technologies/practices like artificial intelligence and machine learning.
  10. Computer Assisted Audit Technologies (CAATs)

    • 1.10 Understanding the use of Computer Assisted Audit Technologies (CAATs), including data warehouses, dashboards, and management information systems (MIS), to enhance audit effectiveness.
  11. Continuous Business Monitoring

    • 1.11 Recognizing the importance of continuous business monitoring as part of the third line of defense’s assurance, which includes regular discussions with compliance on AML trends and horizon risks.

AML Audit Planning and Execution

  1. Types of Evidence Supporting the Testing Strategy

    • 2.1 Understanding the types of evidence that support an audit testing strategy, including policies, procedures, and client profile documentation (e.g., KYC/CDD/EDD). This involves identifying which units to audit, determining the audit time-scope, and employing appropriate data-gathering techniques during the audit (e.g., interviews, documentation reviews, walkthroughs, process maps, and surveys).
  2. Role of Policies and Procedures in Audit Planning

    • 2.2 Recognizing the role that an institution’s policies and procedures play in informing and guiding the audit plan, ensuring that these documents align with the objectives of the audit and regulatory requirements.
  3. Audit Risk Assessment and Types of Audits

    • 2.3 Familiarity with audit risk assessment processes and the types of audits (e.g., Front Office, Compliance, IT systems and data, Operations, Change Management). This includes understanding risk assessment methodologies, both top-down and bottom-up, and procedures for defining the audit scope.
  4. Role of AML Risk Assessment in Audit Planning

    • 2.4 Understanding the role of the AML risk assessment (conducted by the second line of defense) in shaping audit planning and scoping. This includes key considerations for AML risk assessment and evaluating its effectiveness in assessing risks and mitigating controls.
  5. Financial Crime Risks Across Sectors

    • 2.5 Assessing financial crime risks associated with different sectors/industries, products and services, policies and procedures, and customer types. This requires understanding how to evaluate and address these risks in the audit process.
  6. Components of AML Risk Mitigation

    • 2.6 Understanding the components of AML risk mitigation, which include Identification & Verification Risk, Detection & Monitoring Risk, Compliance Risk, and Regulatory/Prior Audit Risk. Each of these components must be considered when planning and executing an audit.
  7. Types of Sampling Methodology

    • 2.7 Familiarity with different types of sampling methodologies (e.g., judgmental, risk-based, quantitative) and the factors to consider when selecting a sample. This includes considerations like the size/nature of the population, the number of newly onboarded customers, PEPs, high-risk customers, degree of control, and overall risk level.

Evaluation of AML Program Components

  1. Design Effectiveness and Operating Effectiveness

    • 3.1 Understanding the definitions of design effectiveness (how well a control or process is designed to achieve its objectives) and operating effectiveness (how well a control or process is operating as intended in practice).
  2. Evaluating the Design of the AML Risk Assessment

    • 3.2 How to evaluate the design of an AML risk assessment, including its methodology and the outcomes. This involves assessing the alignment of the methodology with regulatory expectations and its ability to effectively identify and measure AML risks.
  3. Evaluating Design Effectiveness of AML Program Policies/Procedures

    • 3.3 Methods for evaluating the design effectiveness of AML program policies and procedures, focusing on gap analysis, the currency of the documents, and the clarity of the guidance provided.
  4. Evaluating Operating Effectiveness of AML Program Elements

    • 3.4 Techniques for evaluating the operating effectiveness of AML program components, such as Customer Identification Program (CIP), Know Your Customer (KYC)/Enhanced Due Diligence (EDD), Suspicious Activity Reporting (SAR), Currency Transaction Reporting (CTR), sanctions screening, transaction monitoring, and staff training and qualifications.
  5. Assessing Design and Operating Effectiveness of Customer Risk Rating Methodology

    • 3.5 How to assess both the design and operating effectiveness of customer risk rating methodologies, ensuring customers are accurately identified, appropriately risk-rated, and that the methodology is consistently applied.
  6. Controls Governing AML Programs

    • 3.6 Understanding the characteristics of effective AML controls, including “who” (responsible parties), “what” (specific controls), and “when” (timing and frequency). This includes procedures for testing the design of a control and reviewing control performance within the audit scope.
  7. Elements of Model Risk Management (MRM)

    • 3.7 Familiarity with the components of model risk management (e.g., screening systems, transaction monitoring models, customer risk rating models), regulatory expectations for these models, and how to assess their application within AML programs.
  8. Evaluating the Design and Development of AML Systems and Solutions

    • 3.8 Methods for evaluating the design and development of AML systems (e.g., for transaction monitoring, name/transaction screening), including assessing data quality, data lineage, and the effectiveness of the system’s design in mitigating risks.
  9. Record-Keeping and Retention

    • 3.9 Knowledge of record-keeping requirements (e.g., CDD records, transaction data) and record retention policies, including what information needs to be captured by an institution and how long it must be retained according to regulatory standards.
  10. Root Cause Analysis for Identified Issues

    • 3.10 Understanding the steps to conduct a root cause analysis for issues identified during an audit, including the investigation of repeat issues to ensure effective resolution and prevent recurrence.

Documenting and Managing Audit Results

  1. Documenting Testing Methodology and Results

    • 4.1 Proper documentation of the testing methodology and results in audit work papers involves:
      • Ensuring exceptions are properly identified: Clearly note any deviations from expected results or standards.
      • Retaining supporting evidence: Include documentation related to audit planning and fieldwork, such as data sources, testing procedures, and any evidence collected.
      • Structuring documentation: Organize information logically, with clear explanations of how conclusions were reached, and ensure that all relevant evidence is accessible.
  2. Determining the Level of Risk of Findings

    • 4.2 Assessing the level of risk associated with audit findings involves:
      • Risk classification: Categorize findings as low, medium, or high risk based on their severity and likelihood of occurrence.
      • Distinguishing material vs. immaterial findings: Identify which findings are significant enough to impact the overall risk profile or financial statements.
      • Making recommendations: Address root causes of findings and propose actionable recommendations to mitigate identified risks.
  3. Communicating Audit Results

    • 4.3 Effective communication of audit results includes:
      • Relevant stakeholders: Identify and communicate with individuals or groups impacted by the findings, such as management, the Board of Directors, and regulatory bodies.
      • Content and timing: Share findings promptly and clearly, including key issues, evidence, and recommendations.
      • Audit report elements: Include a summary of findings, detailed descriptions, risk assessments, and suggested actions in the audit report.
      • Exit/close meeting: Conduct a meeting to discuss findings, address concerns, and agree on next steps with stakeholders.
  4. Monitoring Status of Remedial Actions

    • 4.4 Monitoring and ensuring completion of remedial actions involves:
      • Tracking progress: Regularly check the status of agreed-upon actions and ensure that they are being implemented as planned.
      • Exception approval: Manage requests for extensions of target dates, ensuring that any changes are justified and approved by appropriate parties.
  5. Designing and Testing a Follow-Up Strategy

    • 4.5 Designing and testing a follow-up strategy includes:
      • Closure of actions: Verify that all committed actions from the audit findings are completed satisfactorily.
      • Follow-up procedures: Develop and implement procedures to review and validate the effectiveness of corrective actions, and ensure that issues are resolved before closing the audit.

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