Carrying out an independent assessment of your AML framework, other than satisfying legal obligations, will also provide you with peace of mind that it is adequately designed and effectively implemented to sufficiently mitigate risks faced by the entity.
In conducting ongoing monitoring of the measures, policies, controls, and procedures in place, the PMLFTR mandates subject person to consider, given the nature and size of its business, the implementation of an independent audit function to review the AML framework and the effectiveness of its implementation
This does not necessarily mandate the establishment of an internal audit function, as it can be outsourced to an external consultant or alternatively carried out internally by a competent person independent of the MLRO and the implementation and operation of the AML framework.
It will also give you the opportunity to identify and resolve issues before regulatory inspections. A health check will involve a review of the AML framework through the review of policies and procedures, interviews with employees, and testing of controls.
A report will be prepared to explain the gaps identified, as well as recommendations to close the gaps.