What is a critical role of auditors when proposing an AML audit program?

The critical role of auditors when proposing an AML (Anti-Money Laundering) audit program is to present it to senior management with a focus on high-risk entities. This ensures that the audit program is aligned with the organization’s risk appetite and compliance requirements. By emphasizing high-risk entities, auditors help prioritize resources and attention where they are most needed, thereby enhancing the overall effectiveness of the anti-money laundering efforts. This approach facilitates strategic decision-making by senior management and fosters a culture of compliance throughout the organization.

In contrast, presenting audit findings to the media is not an appropriate role for auditors, as confidentiality and professionalism dictate that findings should be shared with relevant stakeholders within the organization first. Implementing the program without consultation would overlook the important collaborative aspect of effective audit processes, which typically require input and buy-in from management and stakeholders. Lastly, deferring responsibility to junior auditors undermines the accountability and expertise required at the senior level, which is crucial for comprehensive oversight of high-risk areas.