AML Audit: a Comprehensive Guide

March 08, 2024
Indepdendent AML audit

In today’s regulatory landscape, anti-money laundering (AML) audit is emerging as a key element of compliance. AMLYZE, a leading company in this field, underlines the importance of complying with the latest AML guidelines, which encourage companies to consider setting up an independent audit function.

AML audits are essential in assessing and improving a company’s internal control systems, policies and procedures. They all lead to ensuring compliance with AML regulations. That is why these audits assess are the procedures in place. Furthermore, it also evaluate how employees adhere to these procedures in practice through sample testing.

AMLYZE emphasizes the value of an independent audit function that provides an objective and unbiased assessment of a company’s AML/CFT compliance programme, thereby helping to identify and mitigate potential risks.

The AML audit can be carried out internally or outsourced to a third party. Especially in cases where the institution does not have the appropriate competence to carry out the AML audit, as it requires specific knowledge and understanding of the latest regulatory requirements.

The rationale behind stringent AML audit requirements

Ensuring the effectiveness of an AML audit programme is more than data collection. It involves establishing and continually updating and monitoring a robust audit programme. The process involves several key steps.

Anti money laundering audit process steps
Anti money laundering audit process steps

Let’s take a closer look at each step of the AML audit:

  1. Define audit objectives

    Audits should have clear objectives, whether they are routine or for specific purposes. Therefore selecting auditors with in-depth knowledge of AML laws and regulations is critical, as inexperienced auditors may overlook critical liabilities.

  2. Establishing an audit plan

    Establishing an audit plan is critical to achieving the audit objectives efficiently. The audit plan should be much more detailed than the audit objectives. And therefore include a description of the audit areas and methodology. When preparing the audit plan, it may also be beneficial to review previously conducted AML audits.

  3. Preparation for the audit

    Usually, an AML audit is a very extensive and comprehensive process that requires a lot of information, documents and data. In order for the process to run smoothly, it is useful not only for the auditors to prepare in advance, but also to help the department being audited to prepare, for example by explaining the process, schedules and deadlines, possible required documentation, etc.

  4. Execute the audit

    The audit should be executed in accordance with the audit plan to assess the AML compliance programme. In addition, if during the audit the auditors identify significant deficiencies in other AML areas not included in the original plan, consideration should be given to expanding the scope of the audit.

  5. Post-audit findings and recommendations

    After completion of the audit, it is important not only to describe what was found, but also to evaluate the findings based on their negative impact on the AML compliance programme and to make recommendations to improve the quality and effectiveness of the company’s AML compliance.

  6. Post-audit action plan and reporting to management

    Once the audit is complete, its findings and recommendations should be presented to senior management and an action plan drawn up to address any deficiencies and implement recommendations.

  7. Auditor’s follow-up after the action plan

    It is good practice for the auditor to follow up on actions completed by the auditee to check that recommendations have been properly implemented. It is also good practice to follow up not only on updated or newly adopted procedures but also on a small sample of client cases to assess whether deficiencies have been addressed not only on paper but also in practice.

The scope of an independent AML audit

An independent AML audit is an in-depth review of a company’s AML compliance programme.

This is distinct from a financial audit and may include a review of the firm’s AML programme and policies, enterprise-wide risk assessment, individual customer risk scoring, customer identification procedures, customer due diligence (CDD), enhanced customer due diligence (CDD), ongoing CDD and EDD, review of transaction monitoring systems and procedures, sanctions screening systems, periodic testing and back-testing of these systems, evaluation of other software used for AML purposes, procedures for internal investigations and submission of Suspicious activity reports (SARs), implementation of internal controls and quality assurance processes, AML training, record keeping, three lines of defense framework, reporting to senior management, management of conflicts of interest.

Previous audit reports are also reviewed to assess the effectiveness of the implementation of previous recommendations.

Responsibility and frequency 

Staff not involved in money laundering risk areas can internally conduct anti-money laundering audits. For example, it can be a separate independent line of defence, or a third party.

Recognizing the limitations of smaller companies in terms of resources and expertise, experts often recommend employing competent, independent third parties for this purpose. Even if an independent third party conducts the audit, the financial institution remains responsible for its quality and must therefore carefully select external auditors with sufficient competence.

Although requirements vary from jurisdiction to jurisdiction, there’s a general consensus that conducting audits regularly is essential. For instance, in the United States, the Financial Crimes Enforcement Network (FinCEN) has stated that testing scope and frequency should match the risks posed by the company’s products and services.

Also, the depth of audits should match the risks posed by the firm’s products and services in terms of depth and frequency. Larger financial institutions commonly practice auditing different AML areas each year. But the scope and depth of the audit will be much greater than if all AML areas were audited in the same year.

AML and financial audits

Typically, a certified public accounting firm do a financial audit and, which involves a review of the financial statements. While an AML audit focuses on verifying the adequacy and effectiveness of a company’s anti-money laundering programme.

A comprehensive and informative database is essential to any audit, whether it’s a financial audit or an AML audit. Because a robust database easily retrieves information at multiple levels, providing valuable insight into the complexity of auditing processes and transactions.

It also enables auditors to gain deeper insights into context, underlying risks and potential anomalies. Maintaining a high quality database is therefore critical to ensuring thorough and reliable audit procedures, ultimately enhancing the effectiveness and trustworthiness of audit findings and recommendations.

AMLYZE emphasizes the importance of maintaining a robust database for client risk assessment and transaction monitoring processes. This ensures easy retrieval of valuable information essential for AML audits.


AML audits are a critical component in ensuring compliance with AML regulations. And AMLYZE promotes the need for independent, thorough and effective audits and recognises their role in protecting against financial crime. By rigorously adhering to these audit standards, organizations not only comply with regulatory requirements, but also strengthen their reputation and operational integrity in the face of evolving financial risks.


1. What is an anti money laudering (AML) audit?

An anti-money laundering (AML) audit is a thorough review of a company’s AML policies, procedures and compliance practices. It assesses the effectiveness of a company’s measures to prevent and detect money laundering activities.

2. Who needs an AML audit?

Any business subject to AML regulations. Such as financial institutions, law firms and other entities involved in financial transactions. All requires an AML audit to ensure compliance with applicable laws and regulations.

3. How often do you need to conduct an AML audit?

The frequency varies depending on the size of the organization, the nature of the business and regulatory requirements. Typically, financial institutions and businesses with a higher risk profile should conduct it annually.

4. Who can perform an AML audit?

Internal staff not directly involved in the AML compliance process. And also independent third party auditors with expertise in AML audits, regulations and practices.

5. What does an AML audit include?

It includes a review of the AML compliance programme, policies and procedures. From customer risk identification, customer due diligence, transaction monitoring and suspicious activity reporting to the internal control framework.

6. Why is an AML audit important?

They are critical for identifying AML weaknesses and ensuring regulatory compliance. They are also essential for protecting against financial crime and maintaining the integrity of financial systems.

7. What are the consequences of failing an AML audit?

Failure can result in regulatory sanctions, fines and reputational damage. Consequently, it can lead to the omission of money laundering or terrorist financing transactions due to weak AML controls. And, in severe cases, criminal charges against the company or its officers.

8. How can a business prepare for an AML audit?

Companies can prepare by ensuring that their AML policies are up to date. They can also conduct internal reviews, train staff and maintain proper records of all AML-related activities.

9. What is the difference between an AML audit and a financial audit?

A financial audit focuses on the accuracy and integrity of financial statements. And an AML audit specifically examines the effectiveness of a company’s measures to prevent and detect money laundering activities.

About the author

AMLYZE is a fully automated service created for the financial sector and businesses that are obliged to comply with AML/CFT regulations.


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