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Run: BSA/AML Independent Audit Preparation Checklist

Use this BSA/AML Independent Audit Preparation Checklist to gather the documents, logs, and evidence an independent tester will ask for before fieldwork begins.

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Audit Scope and Readiness

Verify the review period, legal entity, branch coverage, and business lines included in the independent audit are clearly defined.
Confirm the independent testing engagement, scope, and reporting line are documented and available for review.
Check that prior BSA/AML audit findings, management responses, and remediation status are compiled.
Ensure the most recent enterprise-wide BSA/AML risk assessment is available, approved, and dated.

Policies, Procedures, and Governance

Confirm the written BSA/AML policy is current, approved by management or the board as applicable, and accessible.
Verify procedures address customer identification, beneficial ownership, CDD, and EDD where required.
Confirm recent board, committee, or senior management reporting on BSA/AML metrics, issues, and escalations is compiled.
Verify the testing methodology, sampling approach, and workpapers supporting prior independent reviews are retained.

Transaction Monitoring and Regulatory Reporting Logs

Confirm the Suspicious Activity Report log includes filing dates, case references, disposition, and status for the audit period.
Verify the Currency Transaction Report log includes reportable transactions, filing status, and exception handling.
Ensure sanctions screening alerts, true hits, false positives, dispositions, and escalation evidence are compiled.
Check that alert review records show investigation steps, rationale, and closure decisions for sampled cases.

Training, Staffing, and Competency

Confirm annual training completion records are available for applicable employees, officers, and directors.
Verify enhanced training exists for roles such as operations, onboarding, investigations, and sanctions screening.
Enter the percentage of required personnel who completed assigned BSA/AML training on time.
Confirm course materials, rosters, completion certificates, and make-up training evidence are retained.

Records, Retention, and Evidence Package

Verify documents are organized by request number, topic, or control area for efficient auditor access.
Confirm BSA/AML records are retained according to policy and applicable regulatory retention requirements.
Ensure supporting documents exist for sampled accounts, alerts, filings, investigations, and approvals.
Document any known deficiencies, root cause analysis, remediation owner, and target completion dates.

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