I'm sure that about 5 years ago there was someone on here talking about this issue , G had told them that "next" and "prev" arrows next to ( above or below adsense was not allowed )..My copy of the thread is on an HD which is archived and it would be major disruption to hook it up and find the thread though..

Was about the same time as someone was here who had coded "bugs" to be crawling up and down the edges of his pages,, right next to the ads..real "click me" stuff..( I already knew their site, but they were posting as if they were "clean" )..They remade the site,( I noticed ) to remove what would have got them banned, during that thread..

I don't know if anyone has ever gotten a warning about it, but I know that a couple times people have asked me to look at their layouts and I have always advised to move the AdSense away from the gallery arrows, because it seems a pretty obvious TOS violation to me.

(And just because you see them out there doesn't mean they're okay - sometimes it takes AdSense a while to get around to banning something. And after all... why wouldn't it?)

I have an adsense ad top of galleries on a busy site. But the navigation is below the picture with no ad, also I don't specify the ad is text only. Not had any problems with Google and they've looked at the site manually a few times as used to be premium pub. But when in doubt leave it out i guess.