What is an Independent Audit?

Description of the bronID Process for conducting an Independent Audit (Independent Review) of your AML/CTF Program

An Independent Audit (Independent Review) is an impartial assessment of your AML/CTF Program. By conducting and Independent Audit, the Reviewer checks if you’re complying with your AML/CTF Program and that your AML/CTF Program:

  • properly addresses your money laundering and terrorism financing (ML/TF) risks
  • complies with your legal obligations
  • is working as it should.

The Independent Reviewer must be someone who:

  • understands your business or organisation
  • understands AML/CTF risks
  • was not involved in any part of developing the Program, including assessing your ML/TF risk, developing controls or implementing or maintaining the Program.

bronID has developed a proprietary methodology to conduct Independent Audits and evaluates the following aspects of your AML/CTF Program by assessing your technical compliance, the level of execution and the level of effectiveness:

  • assess the overall integrity and effectiveness of the AML/CTF Program, including policies, procedures and controls;
  • evaluate the adequacy of the AML/CTF risk assessment;
  • examine the adequacy of the Customer Due Diligence (CDD) policies, procedures and processes, and whether they comply with regulatory requirements;
  • determine the personnel adherence to your AML/CTF policies, procedures and controls;
  • perform transaction testing, with particular emphasis on high-risk operations (products, services, customers and geographic locations);
  • assess training adequacy, including its comprehensiveness, accuracy of materials, training schedule, attendance tracking and escalation procedures for lack of attendance;
  • assess compliance with applicable laws and regulations based on the jurisdictions in which you do business;
  • examine the integrity and accuracy of management information systems used in the AML/CTF Program;
  • evaluate the ability of transaction monitoring software application to identify unusual activity;
  • review case management and SMR/STR/SAR systems, including an evaluation of the research and referral of unusual transactions, and a review of policies, procedures and processes for referring unusual or suspicious activity to the personnel responsible for investigating unusual activity;
  • assess the effectiveness of your policy for reviewing accounts that generate multiple suspicious matter report filings, including account closure processes;
  • assess the adequacy of record-keeping and record retention processes;
  • track previously identified deficiencies and ensure management corrects them promptly;
  • considered whether the Board of Directors was responsive to earlier review findings;
  • determine the adequacy of your training program and materials;
  • review disciplinary actions taken for non-compliance with internal policies and regulatory requirements.
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