Our independence standard
Independence is what makes an AML audit worth filing. Here is how we protect it and how we document it, as CIMA's AML Rule requires.
What the Rule requires
AML Rule 12.2(b) requires the audit to be carried out by suitably qualified persons who are independent and separate from those involved in the design, implementation or operation of the policies, procedures, systems and controls under audit, and who are free from any conflict of interest that could impair their objective judgment. Under 12.2(c), the regulated entity must be able to give CIMA, on request, documentation of the auditor's independence and the basis on which it was determined.
CIMA's FAQs explain that independence means being free from actual or perceived conflicts and not responsible for the design, operation, management or oversight of the programme (FAQ 41). The AMLCO, MLRO and DMLRO cannot audit activities they are responsible for, whether employed or outsourced (FAQ 39).
Engagements we decline
We do not accept an independent AML audit engagement for an entity where:
- we, or any member of our team, act as its AMLCO, MLRO or DMLRO;
- we, or any member of our team, act as one of its directors; or
- we designed, drafted or wrote its AML/CFT/CPF or sanctions compliance programme.
The same applies where we have been involved in operating, managing or overseeing the programme in any other way.
How we check and document independence
- Conflict question at enquiry. Our quote form asks whether we have any of these roles or involvement.
- Internal conflict check against our current and past appointments and engagements before we send a proposal.
- Written independence confirmation in the engagement letter, identifying any relationship considered and why it does not impair independence.
- Independence statement in the final report setting out the basis on which independence was determined, ready for you to provide to CIMA on request (12.2(c)).
- Ongoing monitoring during the engagement. If a new conflict arises, we tell you straight away.
Our other services and independence
We also provide AML officer services, training and gap analyses. Where we provide AML officers or design a programme for a client, another independent party must audit that programme, and we will say so at the outset. General training does not, on its own, make us responsible for the design or operation of your programme. We still consider it in every conflict check.
Our AML audits are independent AML compliance programme audits under Rule 12 of the CIMA AML Rule. They are not audits of financial statements.
Ready to scope your independent AML audit?
Tell us about your entity. We will come back with a proposed scope, timetable and quote. No obligation.