Client Stories
Comments below come from compliance and finance leads who hired us for defined AML audit engagements.
The programme audit ran longer than our internal plan because our alert archive was messy — that delay was on us. Once sampling started, their notes on disposition quality were the first time an external reviewer mirrored how our analysts actually write cases.
— Head of Compliance, securities firm, Admiralty
We only booked CDD file testing. Forty files, risk-weighted. They flagged a habit of copying risk rationales across related companies that our own spot checks had missed for two years.
— MLRO, money service operator
Sanctions review week was intense. I would have preferred more notice before they sat with the junior analysts, but the escalation timing gaps they found were real and we fixed the queue rules the following month.
— Operations manager, licensed lender
Before our board paper on closed AML items, the remediation readiness pass stopped us from claiming three findings were done. The evidence packs looked complete until someone asked for the re-test sample list.
— Finance director, family office group
Extended story: multi-branch money service operator
A Central-headquartered operator with counters in Kowloon asked for a full AML programme audit ahead of a licence condition review. Records for walk-in customers lived in three formats. Week one was spent building a single population list; weeks two and three covered sampling and interviews.
The material finding was not a missing policy. Periodic reviews for higher-risk remittance corridors were logged as complete when only identity documents had been refreshed, not source-of-funds narratives. Management accepted the finding, rebuilt the checklist, and asked us back six months later for a remediation readiness review on that item alone.
Extended story: broker preparing for internal audit
A brokerage compliance team wanted CDD file testing only, with results shared with their internal auditors. We sampled sixty files across margin and cash accounts. Rating drift between onboarding and the latest review appeared in nearly a fifth of the high-risk segment. The client used the scorecards in their internal audit kickoff rather than commissioning another full external programme audit that year.