Who meets the standard to perform for the AML audit? (Choose two.)
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A. B. C. D. E.BE
The correct answers are A and B.
AML audits are conducted to evaluate an institution's compliance with AML regulations and determine whether the internal controls implemented by the institution are adequate to manage the risks of money laundering and terrorist financing. It is essential that the individuals who conduct the AML audit have the necessary knowledge, expertise, and independence to provide an objective assessment of the institution's AML program.
Option A suggests that qualified bank staff can perform the AML audit if they are not involved in the AML function being tested. This approach is beneficial because internal staff has a better understanding of the institution's operations and may have more significant access to relevant information. Additionally, they can identify issues in real-time and take corrective action promptly. However, they should not be involved in the AML function being tested to ensure independence and objectivity.
Option B suggests that an internal auditor with the requisite knowledge and expertise of AML meets the standard to perform the AML audit. It is essential that the internal auditor understands the AML laws and regulations, internal policies, and procedures, and the inherent risks of the institution's products, services, and customers. The internal auditor should also have knowledge of AML audit methodologies and techniques to ensure a thorough and objective review.
Option C suggests that an internal auditor with a family member employed in the AML department is not suitable for performing the AML audit. This is because the family member's employment can create a conflict of interest or the perception of bias in the audit, and the independence and objectivity of the audit may be compromised.
Option D suggests that a consultant with limited knowledge and experience in AML but many years of internal audit experience is not suitable for performing the AML audit. AML audit requires specialized knowledge and expertise of AML laws, regulations, and risks. Therefore, a consultant with limited knowledge of AML may not be able to provide a thorough and objective assessment of the institution's AML program.
Option E suggests that a consultant previously employed in the AML department within the past two years is not suitable for performing the AML audit. The previous employment in the AML department can create a conflict of interest or the perception of bias in the audit, and the independence and objectivity of the audit may be compromised.
In summary, A and B meet the standard to perform the AML audit because they have the necessary knowledge, expertise, and independence to provide an objective assessment of the institution's AML program.