A lender takes on 6 contract processors who completed anti-money laundering training at their previous employer 4 months ago.
Correct Answer
B) The lender may verify that training rather than repeat it in house
The rule requires ongoing training of appropriate persons, and a company may satisfy it either by training directly or by verifying that the person has completed comparable training elsewhere. Other choices: a 30-day retraining clock is not in the rule; contractors doing the work are appropriate persons, so owing them nothing is the error; and no expiry at 3 months exists, the standard being ongoing training rather than a shelf life. Source: 31 CFR 1029.210(b)(3), ongoing training
Why This Is the Correct Answer
The rule requires ongoing training of appropriate persons, and a company may satisfy it either by training directly or by verifying that the person has completed comparable training elsewhere. Other choices: a 30-day retraining clock is not in the rule; contractors doing the work are appropriate persons, so owing them nothing is the error; and no expiry at 3 months exists, the standard being ongoing training rather than a shelf life. Source: 31 CFR 1029.210(b)(3), ongoing training
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