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AML 9.4.1 Guidance

1. The review and assessment undertaken for the purposes of Rule 9.4.1 may be undertaken:
a. internally by the Authorised Person's internal audit function; or
b. by a competent firm of independent auditors or compliance professionals.
2. The review and assessment undertaken for the purposes of Rule 9.4.1 should cover at least the following:
a. sample testing of compliance with the Authorised Person's CDD arrangements;
b. an analysis of all notifications made to the MLRO to highlight any area where procedures or training may need to be enhanced; and
c. a review of the nature and frequency of the dialogue between the senior management and the MLRO.
Derived from RM117/2013 [VER9/07-13]