GTB CCP Assessment (M5)

GTB CCP TEST.

Module 5

Number of Questions: 10

Time Allowed: 15 minutes.

You are allowed only one (1) attempt.

Name

Organisation

To ensure proper rule of engagement in AML/CFT compliance, an FI or DNFBP should also ensure practices which of the following;

There should be policy to protect employees when they report suspicious transactions in good faith

There should be policy on the imposition of sanctions on employees that do not adhere to the monitoring and reporting policies and procedures of the FI or DNFBP

The FI or DNFBP should make sure that the Internal Audit Dept. have the competency to conduct oversight on AML/CFT compliance function

There should be independent audit of compliance by external consultant every 3 years

All of the above

Training is a core pillar of compliance. Since compliance is driven by humans. Knowledge gaps may pose a serious challenge to achieving compliance goals. Consequently, there is a need for training and retraining of compliance personnel and all the critical stakeholders within an organisation in the art of compliance. To achieve this, there is a need to set the following six (6) rules except;

Implement an approved annual training plan for all employees and directors

Drive compliance training for only back office staff as marketers or relationship officers/managers are always in marketplace

Send quarterly returns on training programs execution to both the CBN and the NFIU

Conduct at least an annual AML/CFT compliance training for Board and Management

Send CCOs and Compliance Staff to Professional Certification Programs

Which of the following is part of the 10 Pillars of AML/CFT Compliance;

Corporate Governance, Conduct & Culture

Compliance Management & Internal Sanctions

Enterprise-wide ML, TF & PF Risk Assessment

Customer Due Diligence, EDD, UBO

All of the above

In the Rules of Engagement in AML/CFT Compliance, the following are important part of it except;

The FI or DNFBP should establish written AML/CFT policies and procedures

The Board should approve the AML/CFT policies and procedures of the FI or DNFBP

The FI or DNFBP should review/update the AML/CFT policies and procedures at least every 3 years

The FI or DNFBP should communicate the AML/CFT program to all employees and directors

The FI or DNFBP should engage the entertainment industry to organize social events every month-end.

The following are components of the 10 Pillars of AML/CFT except;

Record Keeping & Retention

Attending Campaign rallies of the ruling party

Online, Real-time Transaction Monitoring

Internal Control & Audit

Training & Awareness Program

The safeguards of both control and audit functions are necessary to ensure that compliance programs, processes, procedures, policies put in place by management are adequate, effective and efficient. To achieve this, a financial institution should put in place the following rules except;

Train Internal Audit in AML/CFT Compliance to be able to perform statutory function of independent testing

Internal Audit should conduct independent audit and testing of compliance annually and a review of AML/CFT programme done every 3 years by external AML/CFT Compliance Consultants

External Audit of the institution is sufficient hence no other independent review, audit or testing of compliance function by AML/CFT Compliance consultant is necessary

The Compliance Audit Report should be submitted to the Board (Board Audit Committee) for review

The Internal Audit of Compliance should be dependent on the Risked Based Approach (RBA) by qualified and experienced Audit Staff

he level of understanding, capacity, maturity and management support of these human elements determine to a reasonable extent the success of compliance in any organization. Management of compliance given the human needs will fully be achieved by setting the following four (4) rules except;

Appointment of CCO with required experience, authority, power, influence and responsibilities

Compliance can be subsumed into Marketing to have closer interaction with customers for easier information gathering

Compliance budget and adequate staffing to meet all obligations and function

Appointment of compliance officers in every branch/subsidiary or cluster as approved by the CBN

Synergy between Group Compliance and subsidiaries

Customer Due Diligence is a process of establishing that the;

customer is who he/she claims he/she is

Customer is a criminal

Customer is living alone

Customer is hot tempered

Customer is a socialite

The following is one of the elements of a CDD;

Customer’s Information procedure

Monitoring of customer’s movement

Customer acceptance policy

Risk management of how customer drives car

Assessment of customer’s mood

As a proper guide to implementation of rule of engagement under Governance, an FI or DNFBP should ensure the following except;

Consider the provisions the minimum standard and set higher expectations in your FI

Conduct risk assessment to ML & TF before manual compilation

Consult Black market operators for guidance because of the understanding of underground banking system

Seek Board Approval for all Manuals and document the approval for sighting by examiners

Make provision for Renewal Page in the Manual. Set a higher standard for manual update (i.e at least once a year)

1 out of 10

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GTB CCP Assessment (M5)

GTB CCP TEST.

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