[转帖]AML Audit Checklist

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AML Audit Checklist

The USA PATRIOT requires that all financial institutions maintain an anti-money laundering (AML) program which, at a minimum, includes:

• Written policies, procedures and controls
• Designation of a compliance officer
• Employee training
• Independent testing of the program.

Like any audit, the independent test serves as the report card on how well a company's AML program is functioning. Therefore, it is very important, particularly in the current environment, that companies understand the scope of an independent test and that they are fully prepared to provide documentation to the auditors that support their compliance efforts.

The Audit Checklist below is intended to assist financial institutions in preparing for the independent tests of their AML programs. It identifies areas that are generally within the audit scope, and lists the types of information that the auditors will likely request.

Information
Resolution of Prior Audit & Examination Issues
Evidence of How Prior Issues/Exceptions Were Addressed	ü
AML Compliance Officer
Evidence of Board of Director/Senior Management Appointment	ü
Job Description	ü
Resume	ü
Training Attended Since Last Audit	ü
AML Organizational Structure/Reporting Line	ü
AML Risk Assessment
Risk Assessment Methodology	ü
Risk Assessment Results	ü
Policies and Procedures
Written AML Policies and Procedures (including CIP)	ü
OFAC Policy and Procedures	ü
Evidence of Board of Director/Senior Management Approval	ü
Evidence of Distribution of Policies	ü
Training
Training Materials	ü
Training Attendance Lists	ü
Reliance on Third Parties
Contractual Agreements	ü
Due Diligence/Audit Reports	ü
Annual Certification	ü
Foreign Correspondent Certifications
Certification Procedures	ü
Current Certifications	ü
Listing of Correspondent Accounts Closed Since the Last Audit	ü
Information Sharing
314a Procedures	ü
314b Designation and Procedures	ü
Requests from Law Enforcement & Evidence of Compliance	ü
Monitoring & Investigation
Systems Users’ Manuals	ü
Documentation Supporting Systems Changes	ü
Monitoring Procedures (AML, OFAC, Special Measures)	ü
Investigation Files	ü
Open “Alerts”	ü
SAR Filings	ü
Other Record Keeping & Reporting
Exempt List	ü
CTR Filings	ü
Monetary Instruments	ü
Wire Transfers	ü
Evidence of Compliance with Record Retention and Retrieval Requirements	ü
Management & Board Involvement
Standard Management & Board Reports	ü
Special Management/Board Presentations	ü
AML Compliance Committee minutes	ü

* This checklist is intended as a general guide for preparing for an anti-money laundering audit, but must be customized for each financial institution’s businesses and customers. Some of the information included may not be applicable to all financial institutions, while other financial institutions, because of the services they provide or their customers, might be expected to produce additional information.

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