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COPYRIGHT NOTICE – USE OF WEBEX LOGIN/PASSWORD FOR ACAMS WEB SEMINARS
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Demystifying the AML Audit Discovery Phase—Preparing for the Pre‐Visit
www2.acams.org/webinars
Welcome to the ACAMS Web Seminar
AML Audit (Part I): Demystifying the AML Audit Discovery Phase—Preparing for the
Pre‐VisitApril 18, 2012
12:00 Noon– 2:00 PM EDT
A sound check will be performed 5 minutes before the start time.
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Technical Assistance
Send a message via the Q & A boxOr Call WebEx Technical Support:
(US & Canada) 866‐229‐3239 (International) 916‐229‐3239
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If you are not able to listen to the audio on your computer speakers, press the stop button, wait 5 seconds then press play. Make sure to adjust the volume button on your computer speakers and also adjust the volume on your sound card. To do this, go to the Start Menu, click Control Panel, then click Sound & Audio Devices and adjust accordingly.If you do not have speakers, please refer to your login instructions for the Teleconference Domestic and International Numbers and Access Code.You may request the Teleconference Number by clicking “Request” under the attendee box on your left hand side.
Demystifying the AML Audit Discovery Phase—Preparing for the Pre‐Visit
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• Can you hear the sound check?
• It has begun
Demystifying the AML Audit Discovery Phase—Preparing for the Pre‐Visit
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Q&ATo send a question:Locate the Q & A box on the bottom right hand corner of the WebEx platform.
Type in your question and click send!
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Welcome to the ACAMS Web Seminar
AML Audit (Part I): Demystifying the AML Audit Discovery Phase—Preparing
for the Pre‐Visit
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Speakers:Bill Badinelli, CAMS, CIAAudit Partner, Senior Vice President, AML/Regulatory Risk
RBS Americas‐ GIA
Laura Goldzung, CAMS, CFEPresident & Principal Examiner
AML Audit Services, LLC
Demystifying the AML Audit Discovery Phase—Preparing for the Pre‐Visit
www2.acams.org/webinars
Effective Audit Program
• Appropriate for the organization’s risk profile• Covers all applicable regulations and guidance• Effective discovery, scoping and planning• Proper testing and sample size• Program covers all appropriate areas• Work is properly documented• Conclusions are well supported
Demystifying the AML Audit Discovery Phase—Preparing for the Pre‐Visit
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Effective Audit Program, cont.
• Issues are communicated effectively
• Violations are identified and risks explained
• Includes appropriate corrective actions
• Findings and actions are tracked
• Results are communicated to board/senior management
• Document resolution of exceptions not in report Demystifying the AML Audit Discovery Phase—Preparing for the Pre‐Visit
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Audit Discovery External vs. Internal
• Internal Audit Team – Understands the organization
• External Audit Team – Self‐educates and performs discovery to understand the organization
Demystifying the AML Audit Discovery Phase—Preparing for the Pre‐Visit
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Discovery Phase for External AuditUnderstanding the Business of the FI
Performing discovery sets the stage for understanding the business and to develop the scope of the review
Demystifying the AML Audit Discovery Phase—Preparing for the Pre‐Visit
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Audit Discovery – External AuditReview and Analyze
• AML Compliance Program document approved by Senior Management
• Risk Assessment – BSA/AML & OFAC• Regulatory exam reports, exceptions, responses• Previous independent reviews, exceptions, responses• AMLCO Bio & Experience• Comprehensiveness of AML Training Program• Understanding of supervisory structure, business lines
Demystifying the AML Audit Discovery Phase—Preparing for the Pre‐Visit
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Audit Discovery – External AuditReview and Analyze
• Clearing relationships, affiliates, where applicable• Customer base − Domestic / International• Changes in business focus and infrastructure (controls)• AML system controls and data integrity• Suspicious Activity Program• AML issues brought before Board/audit committee• Strategy, business plans, i.e. new customer segments • Flow of AML controls in FI – departments, people,
systemsDemystifying the AML Audit Discovery Phase—Preparing for the Pre‐Visit
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Audit Discovery
• Amount of information needed to plan the audit may vary
• Document understanding of the BSA risk profile
• Identify high risk products, services, clients and geographies
• Consider new products since prior audit
Demystifying the AML Audit Discovery Phase—Preparing for the Pre‐Visit
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Audit Discovery, cont.
• Identify new regulations and guidance
• Review most recent audits and regulatory exams,
• Consider results of assurance reviews and/or business line self testing
• Identify open issues and resolutions of past issues and recommendations
Demystifying the AML Audit Discovery Phase—Preparing for the Pre‐Visit
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Audit Discovery, cont.
• Consider changes since prior audit, including • Institution’s risk profile• Compliance function• IT programs• Monitoring systems and/or thresholds• Key compliance staff• Key operations and support staff• Outsourcing
Demystifying the AML Audit Discovery Phase—Preparing for the Pre‐Visit
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Key Steps in Audit Planning• Understand the objective, timing and
planned approach for the audit• Notify the Audit Sponsor of the audit’s high
level scope and approximate timeline• Hold preliminary business meetings• Create exceptions for all concerns resulting
from planning activity
Demystifying the AML Audit Discovery Phase—Preparing for the Pre‐Visit
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Key Steps in Audit Planning, cont.• Hold planning session involving all key
members of the audit and CAATs teams and relevant SMEs to discuss and agree key information
• Discuss and agree milestones• Begin to populate the audit scoping
document and high level process maps
Demystifying the AML Audit Discovery Phase—Preparing for the Pre‐Visit
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Key Steps in Audit Planning, cont.• Identify key risks and key controls to the high
level process maps• Populate the audit file with specific risks and
associated key controls discussed during the planning meeting
• Organize team, provide background information on audit
• Finalize scope and record evidence of Audit Sponsor’s acknowledgement
Demystifying the AML Audit Discovery Phase—Preparing for the Pre‐Visit
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Developing the Scope• The Audit Sponsor and business contacts are
crucial sources of information• Clearly explain what is both in scope and out
of scope• Must be clear link between information
obtained and the final scope• All relevant information should be available• Consider mapping to FFIEC Manual
Demystifying the AML Audit Discovery Phase—Preparing for the Pre‐Visit
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Developing the Scope, cont.• Scope must take account of any concerns
raised by the planning work to date• Consider the likelihood of a specific risk
materializing and the impact if it does• Risk analysis must include those risks which
feature in the business high level risk profile• Rank each specific inherent risk as high,
medium or lowDemystifying the AML Audit Discovery Phase—Preparing for the Pre‐Visit
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Scoping and Resourcing• Ensure that adequate resources and skills are available
to complete the audit based on the planned scope and deliverables
• When the work is expected to complete• Right skills available at the right time• Are there any skills without which the audit could not
be performed• Team member roles, responsibilities, objectives and
reporting lines need to be agreed and communicated to the team
Demystifying the AML Audit Discovery Phase—Preparing for the Pre‐Visit
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Raising Exceptions• Any concern or control gap that is identified
during planning should be raised as soon as it is identified
• This may not be a formal issue, raising it now will save time later in the audit if it does become an issue
• The concern or gap should be discussed with the business to confirm that the auditor’s understanding is factually accurate
Demystifying the AML Audit Discovery Phase—Preparing for the Pre‐Visit
www2.acams.org/webinars
Demystifying the AML Audit Discovery Phase—Preparing for the Pre‐Visit
www2.acams.org/webinars
If you have suggestions for future web seminarsor
additional questions for today’s experts, please send them to:
Thank you for joining us today!
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Web Seminar Certificate of AttendanceTo request a certificate of attendance, please fill out the request form, found in your reference materials, and email the form to [email protected] along with your payment information. First certificate is included in cost of seminars. There is a $40 administrative fee for each additional certificate.
You may also call +1 305.373.0020 to process payment over the phone.
Demystifying the AML Audit Discovery Phase—Preparing for the Pre‐Visit
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Next Web Seminar:
Customer Due Diligence (CDD) Changes: Are You Answering or Asking The Right Questions?
April 25, 2012 – Noon to 1:00 PM EDT
www2.acams.org/webinars
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