What must a testing plan for AML controls include?

A testing plan for AML (Anti-Money Laundering) controls is crucial for identifying and mitigating potential weaknesses in the program. Including details that help discover deficiencies and risks is essential because it allows auditors to pinpoint specific areas where the AML controls may not be effectively preventing or detecting money laundering activities. This involves a thorough assessment of existing controls, evaluating their effectiveness, and understanding the risks associated with different scenarios that could expose the organization to vulnerabilities.

Focusing on identifying deficiencies ensures that the audit process can lead to actionable insights and improvements, which is vital for maintaining compliance and safeguarding the institution against financial crimes. A well-developed testing plan that emphasizes this aspect equips auditors to provide valuable recommendations for enhancing AML controls based on the findings.

The other options, while relevant to the broader context of AML program management and auditing, do not directly address the critical function of a testing plan. A general overview of the AML program does not provide the necessary depth needed for effective testing. A summary of previous audit results may inform the current audit but does not constitute a fundamental element of the testing plan itself. Lastly, proposed changes to the audit schedule are more about logistical planning rather than the core content of the testing plan aimed at discovering deficiencies and risks.