Services > AML Audits

AML/CFT Supervisors Guidance

The AML/CFT Supervisors have stated that they cannot recommend auditors as this is an independent appointment made by the Reporting Entity. The Supervisors guidance states:

• We consider “independent” to mean that the person must not have been involved in the undertaking of your risk assessment or the creation or operation of your AML/CFT programme. You should also consider any other potential conflicts of interest that may call into question their independence.
• We consider “appropriately qualified” to mean the person must have relevant skills or experience to conduct the assurance engagement. Reporting entities may have to explain to their supervisor how they have considered the qualifications of their selected auditor to be appropriate. This includes having knowledge of the Act, and its supporting regulations, as well as audit experience or sufficient knowledge of audit processes.
• The supervisors expect reporting entities to have documented what they have considered when assessing the auditor’s independence and relevant experience to perform the audit.

Meaning of "appropriately qualified"

The AML/CFT Supervisors have stated you should consider the following in order to assess how "appropriatley qualified" your auditor is:

• What level of knowledge do they have about AML/CFT? Do they understand the Act and its supporting regulations? Do they know the Codes of Practice and guidelines? If they haven’t had direct experience developing or implementing a risk assessment and AML/CFT programme, how can they then demonstrate the level of knowledge required in order to effectively audit these documents and their implementation?
• Do they have audit experience? Ideally your auditor should have experience conducting an audit, if they don’t, they should demonstrate how they have sufficient knowledge of audit processes in order to effectively undertake your audit.
• How much knowledge do they have of your industry, and how can they demonstrate this?

AML Partners point of difference

You can be rest assured that when you appoint AML Partners as your auditor that we meet the definition of being appropriately qualified to conduct your audit.

Remember the onus is on you to make sure the auditor you appoint is suitably qualified by having demonstrated auditing skills, is well versed in AML/CFT and knows your industry. The AML/CFT Supervisors may ask you to demonstrate this.

What is involved in an Audit?

The audit covers a review of your Risk Assessment and AML/CFT Programme to ascertain that it meets the requirements of the AML/CFT Act and Codes of Practice issued by the AML/CFT Supervisors. Following this review we will test that your AML/CFT Programme is functioning as intended.

Independant

The AML/CFT Act states that the person who conducts the audit must be independent, and not involved in the development of your Risk Assessment, or the establishment, implementation or maintenance of your AML/CFT Programme.

Our approach

When you engage us we will provide an Engagement Letter which will detail the “Agreed upon Procedures” that will form the basis of our audit report. The Agreed upon Procedures provides you with transparency as to what we will be reviewing and testing from the outset. This will enable you to test your own compliance during the reporting period to ensure that you continue to meet your obligations. This is important as your AML/CFT Supervisor could conduct their own audit at any time, and this will aid you in being prepared.

Audit report

We will issue you with a draft report that gives you the opportunity to correct anything that we may have misinterpreted. After this process has been finalised we will issue you with our Independent Audit Report.