The purpose of an independent review is to allow an independent third party to assess both the adequacy of the policies and procedures your business uses to mitigate financial crimes and the efficiency of the implementation of the policies and procedures.
When the independent review is thoroughly and accurately performed, the result of the review can alert organization’s management of deficiencies in their compliance program so it can be fixed before it is flagged by external auditors and/or regulators. Regulators and your banking partners often use the review to gain insight into the quality of your compliance program.
NOTE: Bank Secrecy Act regulation forbids independent review of MSB compliance programs be performed by the organization’s Compliance Officer or anyone subordinated to the Compliance Officer. Anyone with sufficient knowledge of the organization’s compliance obligations may perform the review.
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