Hiring an external advisor to conduct an independent review
Greengage Pty Ltd is a small grocery business that also offers designated remittance services. There are three full-time employees and several casual and part-time workers. The manager of Greengage, who is one of the full-time employees, is the compliance officer and developed and maintains the business’s AML/CTF program. This means the manager is not suitable to conduct an independent review. None of the other employees have the knowledge or understanding of AML/CTF obligations to conduct a review either.
Greengage therefore hires an accounting firm, Plum Accountancy, as an external advisor. Plum Accountancy conducts an independent review every two years. Plum is an appropriate independent reviewer because they provide accounting and tax services to Greengage, and have expertise in reviewing AML/CTF programs.
Engaging an internal advisor to conduct an independent review
Maple Wealth Creation Ltd provides financial services to its customers. Maple is part of a corporate group that has three separate entities – Willow Ltd, Oak Ltd, and Ash Ltd.
Maple has separate compliance and internal audit functions. Ms Black is responsible for AML/CTF compliance and she developed and maintains Maple’s AML/CTF program. Mr Grey is the internal auditor who usually conducts the independent reviews, however he is on long-service leave. The acting auditor has previously worked in Maple’s compliance team and helped to implement the AML/CTF program so can’t do the independent review.
Maple knows there is AML/CTF expertise in the corporate group it belongs to. It therefore appoints the General Counsel of Oak Ltd to do the independent review.