Independent Audit and Testing

Typically a higher-level, enterprise‐wide measure outside specific customer dealings.

Perform routine, unannounced audits focusing on transaction overrides, staff approvals, and AML record integrity to detect patterns consistent with insider bribery. Independent reviews highlight suspicious activities and deter collusion by ensuring staff decisions face objective scrutiny.

Perform routine, focused audits on trade finance documentation, sampling selected transactions to validate invoice valuations against recognized market references. Evaluate staff adherence to identification and mitigation procedures for misinvoicing, and test system capabilities in flagging trade anomalies.

Conduct periodic and specialized reviews of the institution’s digital documentation controls by simulating attempts to falsify or overwrite transaction data. These independent audits evaluate whether existing processes and systems reliably detect or prevent unauthorized record edits and ensure the timely escalation of irregularities.

Conduct periodic, independent reviews of all monitoring systems, data pipelines, and detection logic to verify effective coverage of automated transaction behaviours. Specifically test whether scripted micro-transactions, API-triggered batch payments, and uniform-interval fund movements are correctly ingested and flagged across all channels—including traditional banking, fintech platforms, and crypto services. Confirm that alert thresholds are not being suppressed, capped, or bypassed by structuring. Include scenario-based testing of velocity rules, API job patterns, and passive account usage to detect overlooked automation typologies. Ensure findings are escalated to governance bodies for remediation and model tuning.

Perform periodic internal or external evaluations of transaction monitoring thresholds using test transactions or simulated attacks. These exercises help identify blind spots, recalibrate rules, and prevent criminals from reverse-engineering the AML system through incremental probing of detection limits.

Conduct periodic, unannounced audits to compare ledger entries, accrual accounting records, and supporting documentation with actual cash flow data. Engage external audit specialists or separate internal teams to identify fabricated revenue, improper timing shifts, and backdated entries used to launder funds through fraudulent financial narratives.

Commission periodic audits specializing in forensic accounting to evaluate the validity and consistency of accrual entries within financial statements. Auditors should reconcile significant accrual adjustments with actual contractual obligations or transaction records, examining supporting documentation to detect manufactured revenue, disguised liabilities, or other suspicious distortions indicative of money laundering.

Conduct dedicated reviews of trade finance operations to evaluate the effectiveness of controls in detecting forged bills of exchange, inflated invoices, and phantom shipments. Test staff adherence to document verification procedures, enhanced due diligence (EDD) requirements for cross-border transactions, and the performance of transaction monitoring alerts. Address gaps to maintain robust oversight of Bill of Exchange Fraud risks.

Conduct periodic reviews of the entire syndicated loan process through neutral internal or external audits, focusing on verifying the accuracy of KYC data, the authenticity of trade documentation, and adherence to internal controls. This approach uncovers overlooked discrepancies or collusion among staff, ensuring that partial or flawed oversight is promptly corrected.

Schedule periodic audits to compare awarded contracts with market benchmarks. Check for repeated selection of the same bidder or last-minute bid withdrawals. Validate procurement logs and decision-making rationales to uncover rigged bidding patterns.

Require periodic external audits of the MSB’s AML controls and governance to verify effective suspicious activity identification and reporting. Independent reviewers should examine override logs, staff escalation processes, and agent oversight procedures to detect hidden or suppressed red flags, ensuring that criminals cannot mask illicit activities by subverting internal compliance.

Conduct targeted audits of insurance underwriting, reinsurance contracts, and claim settlement processes to identify overlooked anomalies or potential control failures. Examinations should focus on policy cancellations, excessive premium fluctuations, and opaque captive structures. Timely audits reinforce the effectiveness of AML controls and reveal manipulation buried within complex insurance deals.

Conduct periodic, unannounced audits that focus specifically on verifying the integrity of financial records and transaction logs. Employ auditors separate from day-to-day operations or external specialists to cross-check samples of entries against original documentation and third-party confirmations. Include penetration tests targeting critical systems to identify exploitable vulnerabilities that could enable record manipulation.

Require periodic, focused reviews of AML controls related to investment fund activities. Test the institution’s ability to identify fraudulently inflated valuations, inspect cross-border layering, and pinpoint undisclosed investor identities. By validating the effectiveness of these controls, institutions strengthen their defense against orchestrated manipulations of private equity or hedge fund transactions.

Require regular reviews of the bank’s AML controls by external audit firms or strictly independent internal teams. These reviews should examine transaction monitoring thresholds, suspicious transaction logs, and compliance overrides to detect any illicit tampering or manipulation by infiltrated leadership.

Conduct periodic examinations of client invoices, payment records, and creditor details to identify inflated or duplicated liabilities. Auditors compare invoice data against known business practices and market rates, recommending control enhancements to detect and prevent the creation of fraudulent payables.

Conduct specialized reviews of gambling operations to confirm that chip flow records and high-value bet monitoring are accurate. Test for unreported or forged receipts, and ensure front-line staff follow escalation protocols for suspicious redemption patterns.

Conduct regular, unannounced AML audits focused on verifying the completeness of wagering records, the correct application of ID thresholds, and the absence of unauthorized overrides. These reviews ensure betting shops accurately track cash flows, identify internal collusion, and comply with relevant AML reporting obligations.

Regularly audit principal-agent agreements and sub-agent onboarding files to confirm AML controls are applied at every layer. Include sample testing of aggregator-based transaction logs to detect unreported high-risk activities, ensuring reliable data sharing between principal and sub-agents.

Regularly audit sub-agent networks to ensure that principal-level AML requirements are enforced. Check sub-agent onboarding processes, transaction logs, the validity of business premises, and overall compliance with AML standards. Identify oversight gaps and recommend corrective actions to prevent sub-agents from circumventing established controls.

Conduct periodic reviews of patch management, system configurations, and AML rule settings by independent or external auditors. Promptly investigate discrepancies in system logs or unchecked changes, ensuring timely remediation of any weaknesses. This early detection mechanism helps expose insider collusion or infrastructure manipulation before criminals fully exploit internal control gaps.

Conduct periodic targeted audits of expense reporting systems and processes to identify patterns of fraudulent claims, repeated vendor anomalies, or inflated reimbursements. Focus on comparing expense records to actual business activities, verifying the authenticity of receipts, and reviewing any backdated or reclassified claims for potential abuse.