Independent Review

An assessment can change while people discuss its findings. Independent review needs to identify the submitted revision so that approval has a clear meaning. The Independent Reviewer checks the scope, testing and supporting material, then records an approval, rejection or return with a reason. The decision belongs to the version reviewed.

The AML Program Manager uses that decision to move work forward or arrange corrections. A returned assessment remains visible for follow-up. A later approval should explain which corrected evidence satisfied the reviewer rather than making the earlier concern disappear. This is particularly useful when the assessment moves into remediation and a different person takes responsibility for the action.

• Review package. Bring the assessment period, planned testing and recorded sample results together. The reviewer checks the current revision before deciding. An unresolved evidence question remains part of the review until the team can give a supported answer.
• Decision record. Record the reviewer, decision time and reason with the source revision. Approve, Reject and Return are distinct decisions. A request for more work should explain what must change before the AML Program Manager resubmits the assessment.
• Operation outcome. Keep the action’s operation key and expected revision with its receipt. Pending, Completed, Failed and Needs review describe the recorded action outcome. Read that outcome alongside the business decision when resolving a repeated or interrupted request.

Select the Independent Reviewer and define how independence will be checked against the person preparing the work. Agree which changes require a fresh review and how to retain the earlier decision. An approval of a previous revision must not be presented as approval of newly changed evidence.

Decide who investigates an operation that remains Pending or Needs review. Admin can help resolve a technical exception, while the Independent Reviewer retains authority over the business decision. Agree where any external reference will lead and how authorized staff can inspect the related evidence.

Submit an assessment whose sample evidence is ready for review. Before the reviewer approves it, have the AML Program Manager correct the scope and increase the revision. The reviewer should return to the current package and make a decision on that information. The earlier review request must not quietly approve the changed assessment.

Repeat an accepted request using the same operation identity. Reconcile the existing receipt and decision before attempting another action. The rehearsal succeeds when the manager can explain both the business outcome and the action outcome, including any unresolved failure. Moving an assessment into remediation then carries its reviewed approval and complete period into the next handoff.

• Assessment Review Queue — Inspect assessment revisions waiting for an independent decision.
• Review Decision History — Read the recorded decision and reason against the revision reviewed.
• Operation Exceptions — Investigate guarded actions with pending or unresolved outcomes.

Review scope approval and testing decisions before remediation.