The independent review report must include a summary of the review and the assessment of the overall AML/CFT framework of the regulated entity. A detailed and overall rating of AML/CFT controls must be provided using the scale of: Good, Acceptable, Needs Improvement, or Deficient. We have conducted lots of independent reviews. In this article we explain who the review obligations apply to, who can undertake them, where they come from, and what to expect. Janus Henderson Group plc (“JHG,” the “Company,” “we,” “us,” “our” and similar terms), a company incorporated and registered in Jersey, Channel Islands, is an independent global asset manager, specializing in investment management across all major asset classes. Independent reviewers must include in their testing all relevant AML/CFT reports provided to the Regulatory Authority, such as the Form Q27, the Annual MLRO Report, questionnaires, and any other form, report or information provided under a Regulatory Authority requirement. Introduction 1.1 The UK has a comprehensive anti-money laundering and counter-terrorist financing (AML/CTF) supervision regime, responsible for ensuring that a range of firms engaging in. Your AML/CTF policies must set out how your business will respond to an independent evaluation. This includes how you’ll review and, if required, update your ML/TF risk assessment and AML/CTF policies in response to adverse findings. We suggest businesses have an independent review after the first year of operations to ensure you are on the right track with your AML/CTF compliance and make sure that any breaches or systemic issues are rectified early on in the operations. We are issuing this guidance to assist money services businesses in understanding the regulatory requirements regarding conducting independent reviews of their anti-money laundering programs. The audit department performs independent review on the basis of a risk-based sample of material and high-risk activities, to assess the cases or areas where non-compliance may have serious financial and compliance implications resulting in reputation, financial and operational losses. Janus Henderson Investors Europe S.A. (“JHIESA”), previously known as Henderson Management S.A. (“HMSA”), formed on 31 May 1985, is a wholly owned direct subsidiary of Janus Henderson Group plc (“JHG” or “JHG Group”).