Which of the following can trigger the need for an AML audit?

The need for an AML (Anti-Money Laundering) audit can be significantly triggered by previous internal or external audit findings. This is because such findings can reveal vulnerabilities or deficiencies in an organization’s compliance framework, risk assessment procedures, or transaction monitoring systems. If auditors identify issues related to AML processes, it signals that there may be deeper systemic problems that need to be addressed to ensure compliance with regulatory requirements.

When previous audits have highlighted concerns, it often mandates a reassessment of the entire AML program to rectify those issues and strengthen the controls in place. This proactive approach helps in minimizing risk and protecting the organization from potential legal penalties or reputational damage stemming from non-compliance.

In contrast, while increased business revenue, hiring new staff, and changes in leadership can suggest a need for reassessment or evaluation of an organization’s AML framework, they do not have the same compelling urgency as findings from past audits. Increased revenue could warrant monitoring for potential money laundering activities, and while new staff and leadership changes may call for training or policy review, they do not inherently indicate a need for an audit like previous audit shortcomings do.