What is involved in an AML performance audit?
AML performance audit involves the following steps: • Examination of a firm’s AML Policy & Procedures Statement • Examination of a firm’s AML internal controls • Examination of a firm’s AML program and procedures for the various components within the firm’s AML program • Examination of the firm’s CIP (Client Identification Program) including a test of new clients against lists published by the US Treasury related to SDNs (Specially Designated Nationals), blocked persons and non-cooperative countries and territories • An exist meeting with the firm’s compliance officer(s) to discuss various aspects concerning the firm and its AML program.