Which of the following might require adjustments to the AML audit program?

Mergers and acquisitions can significantly impact an organization’s risk profile and compliance obligations, thus necessitating adjustments to the Anti-Money Laundering (AML) audit program. When a merger or acquisition takes place, it often involves integrating operations, employees, and most importantly, compliance processes of the two entities. This merger can introduce new business lines, higher risks, different customer bases, and variations in regulatory environments.

Moreover, the AML compliance program must account for the newly combined entity's overall risk exposure, which could be very different from that of either organization on its own. Therefore, it becomes essential to reassess and possibly revise the AML audit program to ensure that it effectively addresses these new risks and complies with all relevant regulations.

While routine policy updates, staff performance reviews, and annual financial reports are important for maintaining an organization's operations and compliance, they do not typically create the same level of immediate complexity and risk that a merger or acquisition introduces. These more routine activities might necessitate adjustments, but they do not inherently require a comprehensive reevaluation of the AML audit program as mergers and acquisitions do.