What type of questions should an independent audit consider for the AML compliance program?

• A. Is there a correct percentage of STRs/SARs filed?
• B. Are high-risk accounts reviewed regularly?
• C. Is the program publicly advertised?
• D. Are audits conducted by external stakeholders?

Answer: (B)

An independent audit of an AML compliance program should focus on whether high-risk accounts are reviewed regularly. This is crucial because the effectiveness of an AML program relies heavily on the identification and monitoring of suspicious activities, especially in high-risk areas that are more likely to be exploited for money laundering. Regular reviews ensure that risks are constantly assessed, and appropriate measures are taken to mitigate them, which is a key component of a robust compliance framework.

Monitoring high-risk accounts allows the institution to track transactional behavior that may suggest potential money laundering activities, ensuring timely reporting and compliance with regulatory requirements. This practice directly ties into the overall objective of an AML program – to prevent, detect, and report suspicious activities effectively.

In contrast, questions about the percentage of STRs/SARs filed may not capture the true functionality and efficiency of the compliance program, as filing rates can be influenced by factors other than the program’s effectiveness. The visibility of a compliance program (such as whether it is publicly advertised) does not indicate its thoroughness or efficiency in combating money laundering. Additionally, while audits conducted by external stakeholders are important for objectivity, they are not a direct indicator of the effectiveness of the ongoing compliance measures. Therefore, regular reviews of high-risk accounts stand as the most pertinent aspect