A key factor in the independence of an AML audit is that the auditor should.

Prior experience working in AML or CFT departments does not disqualify an auditor; in fact, domain expertise strengthens the quality of the audit, and independence is achieved through organizational reporting lines and objectivity - not by excluding experienced professionals.

Requiring zero involvement with compliance staff is neither practical nor a standard for independence - auditors must engage with compliance personnel to gather evidence and conduct interviews; independence means freedom from bias, not isolation from those being audited.

Board screening of the auditor before an audit begins is not a recognized standard for establishing AML audit independence; independence is defined by the auditor's reporting structure, objectivity, and competence, not a pre-audit approval process by governance bodies.

True audit independence in the AML context is predicated on both objectivity and competence - an auditor who lacks sufficient AML knowledge cannot meaningfully evaluate the program's adequacy or identify deficiencies, making technical proficiency a foundational requirement for an independent review. Without the ability to assess whether controls are appropriate and effective, the auditor's independence is functionally meaningless regardless of their organizational separation.