Trainee auditors, like all entities subject to the AML Law, must, pursuant to Article 8 of that Law, develop and apply effective AML/CFT rules of conduct, procedures and internal control measures (hereafter “AML/CFT procedures”) that are proportionate to their nature and size.
The Belgian Audit Oversight Board draws attention to its Recommendation dated 7 September 2023, in which it recommends that a clause be included in trainee auditors’ service agreements to address this point, in order to stipulate explicitly that the AML/CFT procedures of the trainee’s audit firm must be applied by all trainees at that firm.