1. Anti-Money Laundering
  2. Process
  3. Test controls and review the results
Process · Test controls and review the results

Test controls and review the results

The review package should let another person follow the test from control to evidence. The Control Tester records what was examined, while the AML Program Manager decides when the assessment is ready to submit. The Independent Reviewer evaluates that package and records the business decision.

Step by step

  1. Start testing AML Program Manager and Control Tester

    AML Program Manager moves the Planned assessment into Testing under the agreed plan. Control Tester links each sample to its assessment and control. Record the sample revision and test date so later corrections can be distinguished from the original work.

    • AML Program Manager starts Testing; Control Tester prepares samples
    • Updates Assessments, Assessment tests, Controls
  2. Record evidence Control Tester

    Control Tester records sample size, exception count, result and evidence reference. The exception count cannot exceed the sample. Review requires an inspectable evidence reference for every performed sample, including Fail and Inconclusive outcomes. Keep unperformed work Pending, and attach supporting material with the agreed visibility.

    • Record sample outcomes and supporting material
    • Updates Assessment tests, Record attachments
  3. Submit the assessment AML Program Manager

    AML Program Manager checks the testing against scope and moves the assessment from Testing to Review. Identify any findings that need attention. Confirm that the revision presented to the reviewer matches the evidence package being discussed.

    • Present the current revision for Review
    • Updates Assessments, Findings
  4. Review results Independent Reviewer

    Independent Reviewer records Approve, Reject or Return with a reason against the source revision. Approval moves the assessment from Review to Approved. Where findings require corrective work, move the approved assessment into Remediation. Rejected or returned work stays in Review until corrected evidence is resubmitted.

    • Record the decision and approval outcome
    • Updates Assessments, Review decisions, Operation receipts
    ApprovalA person approves before the work moves on.

Where it usually breaks

And how to keep it from happening.

  • A passing label is entered before supporting evidence is available.
  • The exception count includes cases outside the recorded sample.
  • A reviewer approves an old revision while new evidence is being added.
Control Tester
, AML Program Manager, Independent Reviewer.

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