Cams Exam Quesiton No 6

Question No 6:

A small broker-dealer has an AML compliance program that addresses procedures for filing Suspicious Transaction Reports and includes policies, procedures and internal controls for customer identification, monitoring accounts and identifying money laundering red flags. Every employee of the broker dealer is trained via the Internet in January and in July on AML issues.
The board does not take the Internet training. Instead,
the compliance officer organizes a luncheon for them where an outsider comes in and trains them. The program provides for the appointment of a compliance officer, and once a year the compliance officer conducts an audit to test the program. In what respect does the program need improvement?

A. The AML program should be tested by an independent person, not the compliance officer.
B. The AML program should be tested more than once per year.
C. The board should receive the same training provided to the employees.
D. Employees should not be trained via the Internet, because classroom training is better.

Answer: A