When is a look-back AML audit considered voluntary?

A look-back AML audit is deemed voluntary when it follows an internal audit indicating control failures. This scenario reflects a proactive stance taken by the organization to address concerns identified during the internal audit process. When control failures are discovered, management may choose to perform a look-back audit to ensure compliance and rectify any issues that could potentially expose the organization to risk. This indicates a commitment to improving the AML framework and addressing any deficiencies rather than responding to external compliance pressures, such as requests from regulatory bodies or management mandates unrelated to prior findings.

While management deciding to reassess AML strategies could lead to a voluntary audit, it is distinct from the context of responding to identified failures. The focus on past transactions in a look-back audit is not the primary reason for its voluntary status, as the evaluation typically stems from findings that prompt a deeper investigation into compliance effectiveness.