/ WHAT’S REVIEWED
The whole program, tested — not skimmed.
Policies & procedures
Is the written AML program current, adopted, and matched to your actual risk?
CTR & SAR filing
Are reports complete, accurate, and filed on time — sampled against the transactions?
Risk assessment
Is the agent and enterprise risk assessment sound and refreshed?
OFAC & screening
Is sanctions and PEP screening in place and working across the network?
Training
Is staff trained, certified, and current — with records to prove it?
Recordkeeping
Are records retained, organized, and exam-ready to the five-year standard?
/ THE PROCESS
Scope to signed-off.
Scope
Define coverage against your program and risk profile.
Test
Sample transactions, filings, and records; interview staff.
Findings
Document gaps, ranked by severity, with the evidence.
Report
Deliver a written report to the board or ownership.
Remediate
Track each finding to closed — ready for the next exam.
/ FINDINGS TO CLOSED
A report you can act on and show.
Findings come ranked by severity, each with the evidence behind it and a recommended fix. Remediation is tracked to closed — so the next review, and the next exam, start from a clean, documented baseline.
- Severity-ranked, evidence-backed findings
- Written report for the board or ownership
- Remediation tracked to closed