As emphasized in the Basel Committee guidance for "Sound management of risks related to money laundering and financing of terrorism", the third line of defense, or audit function, should:
A.
Conduct AML audits no less often than every 12 months for consistency in annual reporting.
B.
Remain independent from expressing opinions on the sufficiency of remediation or action plans to address findings and recommendations.
C.
Be involved in the day-to-day operations of the AML program to immediately prevent control failures.
D.
Report to the audit committee of the board of directors to maintain independence.
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