/ FOR PRINCIPALS — INDEPENDENT REVIEW

The review your examiner will ask to see.

An arm’s-length test of your whole AML program — policies, filings, risk assessment, screening, training, and recordkeeping — sampled, documented, and delivered as a written report with ranked findings and tracked remediation. The one regulators expect every 12 to 18 months.

REVIEW REPORT · 2026
High severity1
Medium severity2
Low severity1
3 of 4 remediated
NEXT REVIEW
Q2 2027
on the 12–18 month clock
0
PROGRAM AREAS
tested end to end
0%
INDEPENDENT
arm’s-length review
0
FINDINGS
ranked by severity
0–18mo
CADENCE
as regulators expect

/ WHAT’S REVIEWED

The whole program, tested — not skimmed.

01

Policies & procedures

Is the written AML program current, adopted, and matched to your actual risk?

02

CTR & SAR filing

Are reports complete, accurate, and filed on time — sampled against the transactions?

03

Risk assessment

Is the agent and enterprise risk assessment sound and refreshed?

04

OFAC & screening

Is sanctions and PEP screening in place and working across the network?

05

Training

Is staff trained, certified, and current — with records to prove it?

06

Recordkeeping

Are records retained, organized, and exam-ready to the five-year standard?

/ THE PROCESS

Scope to signed-off.

01

Scope

Define coverage against your program and risk profile.

02

Test

Sample transactions, filings, and records; interview staff.

03

Findings

Document gaps, ranked by severity, with the evidence.

04

Report

Deliver a written report to the board or ownership.

05

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
FINDINGS · 2026 REVIEW3 / 4 CLOSED
HighSAR narrative depth
MediumRisk assessment refresh overdue
MediumTwo agents’ training lapsed
LowRetention filing gapsopen

Walk into the exam already reviewed.

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/ THE FILING DESK

Regulatory changes, before your examiner.

A short monthly brief on FinCEN guidance, enforcement actions, and AML practice for money services businesses.

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