Who is responsible for performing the AML audit risk assessment for each auditable entity?

The responsibility for performing the AML audit risk assessment for each auditable entity typically falls to audit managers. Audit managers are tasked with overseeing the audit process, including risk assessment, to ensure that the organization adheres to effective AML practices. They develop a comprehensive understanding of the operational risks and compliance environment of each entity being audited, which allows them to identify areas of potential risk and prioritize them accordingly.

In the context of an AML audit, audit managers analyze various factors such as transaction patterns, regulatory requirements, and historical compliance issues. Their higher-level perspective enables them to integrate input from various teams, including compliance officers and operational managers, to create a holistic view of the risks that need to be assessed.

While external auditors and compliance officers play crucial roles in the AML framework, they do not typically carry the primary responsibility for the AML audit risk assessment. External auditors usually focus on the accuracy and fairness of financial statements and compliance with accounting standards, while compliance officers ensure adherence to regulations and internal policies but do not lead the risk assessment process specifically for audits. Operational managers are more involved in day-to-day operations rather than the strategic risk assessment required in the context of AML audits. Thus, the role of audit managers is central in effectively conducting AML audit risk assessments.