Run audits and independent reviews
The independent AML review the law requires, an ISO internal audit or a supplier audit use the same engagement model.
- Programmes of tests imported from a workbook and copied into each engagement, so changing the library never moves work in flight.
- Each test is prepared by one person and reviewed by another; a reviewed result cannot change without being reviewed again.
- Sampling plans with an append-only log, evidence requests to colleagues, findings, and last audit’s findings closed only by a passing retest.
- A report that is final once the engagement is reported; external auditors work in the same system with a role limited to their own work.
An AML/CFT independent review in progress: tests, requests and findings
