The independent audit process helps the LEH assess the effectiveness and adequacy of its current processes, including by assessing the adequacy of the AML/CFT Program and checking for any inconsistencies between the policy and procedures and day-to-day operations in order to identify any weaknesses and deficiencies. Independent auditing must be undertaken regularly to review and assess the effectiveness of the AML/CFT compliance policies, procedures, systems and controls, and their compliance with the LEH’s obligations. As per Paragraph 16.31.1 of the Standards, the Compliance Officer’s function must undergo regular audit by the LEH’s internal audit department. In addition, under Paragraph 16.31.2 of the Standards, “agreed-upon procedures” for the review of the AML/CFT Compliance function must be performed by external auditors annually.

The independent audits, whether internal or external, should be undertaken by skilled and competent auditors. The internal audit department should be resourced with skilled and competent employees that understand the AML/CFT Program of the LEH. The audit should be commensurate to the level and sophistication of the LEH, and be updated to account for changes in risk assessments and the legal and regulatory framework in force in the UAE. The internal audit function should be accountable to the Board of Directors (or the Owner/Partners if there is no Board of Directors), independent of the audited activities and functions, and have sufficient authority, skills, expertise, and resources within the organization.