Laura H. Goldzung, CFE, CA


AML Audit Services AML Audit Services. Your trusted AML advisor
89 Headquarters Plaza North 14th Floor Morristown, NJ 07960
Phone: 800-870-8076
AML Audit Services
89 Headquarters Plaza North 14th Floor Morristown, NJ 07960
Phone: 800-870-8076
March 30, 2016 Laura H. Goldzung, CFE, CA

AML Independent Testing

Banks and nonbank institutions are required to undergo an independent review of their AML compliance program, commonly known as the “4th Pillar.” Small- to medium-sized companies may not have the dedicated personnel to focus solely on AML compliance, whereas compliance officers in larger organizations are often overwhelmed trying to keep up with the latest industry practices and compliance requirements.

An independent review from AML Audit Services helps to ensure that AML compliance controls are risk-ready. Each AMLAS client is assigned a certified AML industry specialist who serves as an advisor through the entire assessment process.

With an unbiased, objective view of the client’s business and operations, advisors apply their vast industry know-how and a proven three-step process to assess the program, identify gaps, and propose recommended enhancements.

Phase One

AML Audit Services professionals gain a deep understanding of the client’s business model and its underlying subtleties and nuances. They review documents, ask lots of questions, and run the necessary tests to identify any gaps, shortcomings, or deficiencies.

Phase one features a thorough review of program documents, including but not limited to:

  • Business model and infrastructure
  • AML policies and procedures documentation
  • AML risk assessment
  • Qualifications and biography of the designated compliance officer
  • Previous independent testing report and management responses
Phase Two

Phase Two consists of an onsite visit that includes:

  • Interviews with key personnel
  • Walk-through of compliance operations processes
  • Testing of transactions
  • A brief exit meeting with senior management to discuss preliminary conclusions

Once the gaps are identified, AML Audit Services advisors will identify needed enhancements. Recommendations are tailored to each client. Clients are educated on what standards need to be reached, and what regulators will expect to see.

Phase Three

AML Audit Services works with each client to identify realistic action steps for implementation.

Phase Three consists of:

  • Analysis of review and test items
  • Comprehensive report including:
    • Requirements
    • Observations
    • Testing
    • Recommendations
  • Comprehensive workpapers


Many institutions come to AML Audit Services after having worked with other AML service providers. What they find with AML Audit Services are trusted advisors with:

  • Considerable experience in bank and nonbank institutions and a deep understanding of the issues that each uniquely face.
  • A consultative approach, including a thorough discovery process that makes each client feel confident they are getting attention specific to their needs.
  • Extensive knowledge of regulatory expectations.
  • A reputation for being well-known, respected, and connected in the AML environment.
  • Superior quality deliverables.

Institutions hire AML Audit Services first so they don’t encounter issues later. Learn More.



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