The USA PATRIOT Act requires that all financial institutions maintain an anti-money laundering (AML) program that is tested by independent auditors. The independent test serves as the report card on how well a company's AML program is functioning. Therefore, it is very important that companies understand the scope of an independent test and are prepared to provide documentation to the auditors supporting their compliance efforts.
This audit checklist 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.