Engagement
AML and KYC control testing
Sample-based testing of customer due diligence, screening evidence, and SAR escalation trails for fintech compliance teams.
Focus of the testing
We select samples from onboarding cohorts, refresh cycles, and alert queues. Each sample is traced from application or alert through screening evidence to case closure or SAR decision. Gaps in ownership, stale refresh dates, and broken escalation paths are recorded as exceptions.
Who typically commissions this
MLROs preparing for correspondent bank questionnaires, payment institutions refreshing their annual AML programme review, and lending platforms that have changed onboarding vendors mid-year.
Output
A control matrix (pass / exception / not tested) plus narrative for each exception. We stay in audit language; remediation workshops can be scoped separately if you want coaching tone for internal training.