A key factor in the independence of an AML audit is that the auditor should:

While past involvement in AML/CFT departments may raise concerns about potential biases, it does not inherently compromise an auditor's independence if they possess the necessary skills and objectivity. Experience can actually enhance the auditor's understanding of the compliance framework, provided they can maintain impartiality.

Screening by the board, while a good practice for ensuring integrity, does not directly relate to the auditor's independence in performing an AML audit. This measure does not guarantee that the auditor possesses the essential technical knowledge and skills required for an effective and independent review of AML processes.

Complete separation from the AML/CFT compliance staff can lead to a lack of understanding of the organization's specific context and risks. An auditor should have relevant knowledge and training, which can sometimes be informed by interaction with compliance staff, as long as they maintain their independence and objectivity.