An AML audit or independent effectiveness review is different from a financial statement audit,It is not the same as rewriting an AML system.。Review aims to examine governance using a risk-based approach、risk assessment、Customer due diligence、sanctions、Transaction monitoring、suspicious transaction report、Record、Whether the training and rectification are actually implemented according to the system。
The scope of the review should be determined by the business、client、product、channel、area、trading volume、Regulatory history and last discovery decision,and specify the sampling period、sample method、System and outsourcing boundaries。Examiners must have appropriate competencies,and remain sufficiently independent from the control being reviewed。