TAG Consultancy AML Audit

Ask yourself?

Are you aware of the new independent AML audit requirements imposed on most financial services firms, with very few exemptions, in Gibraltar?

TAG Consultancy Can Help!


Section 26 (1A) of POCA, covered under section 5.5 of the GFSC’s AML/CTF Guidance Note v.7.0, introduced the requirement for a relevant financial business, having regard to the size and nature of the business, to undertake an independent audit function for the purposes of testing the following:

  • Customer due diligence measures and ongoing monitoring,
  • Reporting,
  • Record-keeping,
  • Internal control,
  • Risk assessment and management,
  • Compliance management and
  • Employee screening.

All Financial Institutions, as defined by POCA and other regulated financial businesses are subject to these requirements and must therefore undertake the independent AML audit function.


The GFSC’s criteria in respect of relevant financial businesses, as defined by the POCA, to assess whether these requirements apply to them are as follows:

A relevant financial business, which is not captured above as a financial institution and, with the exception of Trust and Company Service Providers, must undertake an independent AML audit function if it meets one or more of the following criteria:

1. Has 5 or more full time employees; or

2. Has a turnover of £1,000,000 or over.

With respect to Trust and Company Service Providers, firms must undertake an independent AML audit function if it meets one or more of the following criteria;

1. Has 50 or more trusts under management, or

2. Has 100 or more companies under management.

Frequency & Scope

Individual firms, applying a risk-based approach, will need to determine the frequency and scope of the independent AML audit but it is expected that it be conducted at least annually.

The function should be performed by individuals who are not involved in the firm’s compliance function, these may be from within the firm or external, ensuring the independence of the role.

The firm’s Senior Management should monitor and review the effectiveness of the process.

How can TAG help?

TAG Consultancy has the in-house expertise to conduct independent AML audits and can offer a tailored solution to compliance with the above with fee quotes that will be adapted to your needs in respect of the frequency and scope of the function.  If you want further information, please do not hesitate to contact us.

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