How to prepare evidence for governing-body AML oversight

Oversight needs a usable evidence trail

Governing-body reporting should make it possible to understand the organisation’s AML/CTF risk-management position, compliance with policies, significant deficiencies and progress on agreed actions. The pack should be concise enough to use and detailed enough to support decisions.

Evidence to organise before reporting

• Current risk assessment and a record of material updates.
• Approved AML/CTF policies and relevant implementation evidence.
• AMLCO reports, decisions, escalations and action registers.
• Training and personnel-due-diligence completion evidence.
• Monitoring, review and quality-assurance results.
• Independent-evaluation findings and documented remediation responses where applicable.

Keep decisions visible

Record the information presented, questions raised, decisions made, owners assigned and due dates agreed. AUSTRAC guidance describes at least annual AMLCO reporting to the governing body and written notification of risk-assessment updates as soon as practicable after an update is made.