How to Audit an Effective AML Governance Committee Structure and AML Issue Escalation Protocol

Jacob Johnston CAMS-Audit

Before understanding how to audit an effective and transparent AML issue escalation process between the AML compliance group from the U.S. Head Office, regions and LOBs, it is important to have a clear understanding of what a strong outlined and transparent global AML governance committee structure of a large financial institution with multiple LOBs and multiple jurisdictions/regions (in addition to the U.S.) could look like. Audit needs to validate that adequate AML oversight is captured from not just the compliance group of the U.S. Head Office, but also from each of the banks’ regions and LOBs, which also should have AML-designated individuals in a senior management role.

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