CAMS · Question #659
To ensure the independence of an audit for an AML program those involved in the audit would best be described as being:
The correct answer is A. not Involved in the organizations AML compliance program and having a reporting line to the. AML audit independence requires auditors to be fully separated from the entire AML compliance program - not just one component of it - and to report to a governance body independent of AML management.
Question
To ensure the independence of an audit for an AML program those involved in the audit would best be described as being:
Options
- Anot Involved in the organizations AML compliance program and having a reporting line to the
- Bnot involved in the organizations AML compliance program and having a reporting line to the
- Cnot involved in the organization's suspicious activity report filing process and having a reporting
- Dnot involved in the organization's suspicious activity report filing process and having a reporting
How the community answered
(45 responses)- A78% (35)
- B4% (2)
- C11% (5)
- D7% (3)
Why each option
AML audit independence requires auditors to be fully separated from the entire AML compliance program - not just one component of it - and to report to a governance body independent of AML management.
True audit independence requires that auditors have no involvement in any part of the AML compliance program they are reviewing, eliminating self-review bias across all program components. The reporting line must lead to a sufficiently senior and independent body - such as the board audit committee - so that findings cannot be influenced or suppressed by AML management. This dual criterion of complete functional separation and an independent reporting line is the recognized standard for objective AML audit governance.
While this choice appears nearly identical in the visible truncated text, the answer key designates A as correct, indicating the untruncated version of B contains a qualification or reporting-line destination that falls short of the full independence standard required.
Restricting auditor exclusion only to the SAR filing process still permits involvement in other AML compliance program areas, leaving auditors susceptible to self-review conflicts when those areas are assessed.
Limiting the exclusion requirement to the SAR filing process rather than the entire AML compliance program is an insufficiently broad independence standard and exposes the audit to conflicts of interest across the remaining program components.
Concept tested: Independence requirements for AML program audit function
Source: https://www.fatf-gafi.org/en/recommendations/gafi-recommendations.html
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