In today's WH Insights episode, Davinia Cutajar (Partner WH
Partners) talks about AML/CFT audits' best practices.
The first thing to identify when carrying out an AML/CFT audit
is who should carry out the audit.
The ideal candidate is a person who would not be auditing his
own work.
In other words, it should not be the Money Laundering Reporting
Officer or someone from the compliance team. Similarly, you want to
avoid the audit being carried out by someone who has a conflict of
interest, such as the head of sales.
Once the right person is identified, the scope and extent of the
audit should be clearly documented.
Most audits start with a review of the entity's policies and
procedures manual to ensure it is in line with the law and any
recent amendments.