Source Document
Manual of Regulations for Banks
BSP.MORB.2023.Sec911.p13.OBL6
Manual of Regulations for Banks > 911 RISK MANAGEMENT > Manual monitoring > 911
Obligation Summary
The AML/TF internal audit must be performed by qualified personnel who are independent of the audited office.
The internal audit function associated with money laundering and terrorist financing should be conducted by qualified personnel who are independent of the office being audited.
MORB, Sec. 911, p. 13 (2023 ed.) · Manual of Regulations for Banks · p. 13
b. Manual monitoring. Covered persons not required to adopt an AML/CFT electronic system must ensure that they have the means of complying with this Section.
Internal audit. The internal audit function associated with money laundering and terrorist financing should be conducted by qualified personnel who are independent of the office being audited. It must have the support of the board of directors and senior management and have a direct reporting line to the board or a board-level audit committee.
The internal audit shall, in addition to those specified by this Part, be responsible for the periodic and independent evaluation of the risk management, degree of adherence to internal control mechanisms related to the customer identification process, such as the determination of the existence of customers and the completeness of the minimum information and/or documents establishing the true and full identity of, and the extent and standard of due diligence applied to, customers, CT and ST reporting and record keeping and retention, as well as the adequacy and
What This Requires.
ProfytAI Regulatory Intelligence
Type: requirementRequires that the internal audit function covering money laundering and terrorist financing be performed by qualified personnel who are independent of the office being audited.
Relationship
Standalone opening statement of the 'Internal audit' topic, positioned after the 'Manual monitoring' item in the monitoring-and-reporting-tools list. It is followed immediately by the reporting-line requirement and the scope-of-responsibility requirement, together forming the internal-audit subtopic.
Why This Exists
Independence and qualification of the AML/TF internal audit function are what make its findings credible: an auditor reviewing their own office's controls, or one lacking relevant expertise, cannot reliably assess whether AML/CFT controls are actually working.
Implementation Considerations
Typically involves assigning AML/TF-related internal audit work to staff who have relevant AML/CFT competence and who sit organizationally apart from, and have no operational role in, the office or function they are auditing.
Interpretation Note · Two distinct qualifying conditions are stated conjunctively: personnel must be both 'qualified' and 'independent of the office being audited'; satisfying only one is not sufficient. As with the neighboring reporting-system sentence, the source uses 'should' rather than 'shall.'
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