Independent Review

An AML Inspection is a formal supervisory activity carried out by the IAB as part of its regulatory role. It is not optional and forms part of your ongoing compliance obligations.

An Independent Review, by contrast, is an activity undertaken by the practice to assess its own AML policies, procedures, and controls. It is not mandated in the same way as an inspection, but it is strongly encouraged as good professional practice and aligns with regulatory expectations around ongoing monitoring and effectiveness.

In terms of who can carry out an independent review, this should be someone experienced and sufficiently objective. In practice, this would typically be another practitioner who understands AML requirements and how they apply in a bookkeeping or accountancy setting. As a guide, an individual holding at least MIAB level (or equivalent experience) and operating their own practice would be appropriate. The IAB Ambassador network is a suitable place to identify individuals with the relevant experience.

As evidence, the IAB would expect a clear written record of the review. This should be dated and set out what areas were covered, the findings, and any actions identified. The documentation should demonstrate that the review was a genuine and structured assessment of your AML framework.