1. An AML/CTF Program is a document maintained by a reporting entity specifying how they comply with AML/CTF legislation to identify and manage the risk of its products or services being used for money laundering (ML) or terrorism financing (TF).
2. There is no ‘one-size fits all’ approach in choosing the components of AML/CTF Program for each independent review. A combination of the organisation’s current high-risk areas and overall regulatory environment should be considered.
3. The overarching objective should be to gather meaningful information as part of the engagement risk assessment so that it helps to effectively perform the AML/CTF internal audit engagement.