Control effectiveness testing
Verifying that written procedures are genuinely applied, not merely present on paper.
AML Compliance
Independent AML Audit
An independent audit function that tests whether your framework works and reports to the board.
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Having written policies is one thing; demonstrating they work is another. That is why the framework rests on an independent audit function that periodically reviews the adequacy of a business's AML programme and surfaces its gaps.
An independent AML audit is not a paperwork review but a test of effectiveness: we sample customer files, trace specific transactions from the start, and measure whether the written procedure was actually applied or stayed in the manual.
The output is an independent report to senior management setting out what works, what does not, how serious each gap is, and a remediation plan with an owner and a timeline.
What the service includes
Due-diligence file sampling
Drawing a sample of customer files and testing whether verification is complete and documented.
Risk assessment review
Confirming the entity risk assessment is current and reflects the actual activity and client base.
Screening and reporting testing
Examining customer screening and the escalation and reporting path from detection to decision.
Training and records review
Checking training coverage and documentation, and retention of records for the prescribed period.
Independent report and remediation plan
A report to management grading each gap by severity, with a trackable correction plan.
Who is this service for?
- Businesses in scope required to review their programme periodically
- Businesses that built a framework and never tested it
- Boards wanting independent assurance
- Businesses after a material change in activity or systems
Frequently asked questions
How does this differ from a compliance health check?
A health check is rapid preparation ahead of an expected inspection. An independent audit is a periodic, methodical function that tests effectiveness and documents its findings to management as part of governance.
Can you act as both our compliance officer and our independent auditor?
No. Independence requires that the auditor is not part of day-to-day compliance operations. If we provide your outsourced compliance officer, we cannot audit our own work — we will refer you elsewhere rather than compromise independence.
How often should it be done?
Periodically, at a frequency proportionate to your size and risk. We set the appropriate cadence after an initial assessment.
Who sees the report?
It is an internal document addressed to senior management, and a supervisor may ask for it as evidence that the function exists.
What does an independent AML audit cost?
It depends on the size of the business, the number of customers in scope, and the state of existing documentation. A business that has documented its procedures pays less than one starting from nothing. You get a fixed figure after an initial scoping review.
Related services
Is your business ready for a regulatory inspection?
Message us on WhatsApp for a free initial assessment of your compliance position — no obligation.
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