Innocloudapps

Engagement

AML programme audit

Independent examination of your end-to-end anti-money laundering programme, with sample testing and a board-ready findings report.

  • Format: On-site fieldwork with remote document review
  • Typical duration: 4–8 weeks depending on entity size
  • Delivery: Hong Kong offices; remote kickoff available
  • Fees: Fixed fee after scoping, from HK$85,000
Request this engagement
Auditor reviewing papers at a meeting table

Who this is for

Compliance officers, MLROs, and finance directors at licensed banks, securities firms, money service operators, and other Hong Kong regulated entities who need an independent view of their AML programme before a regulator visit, board presentation, or internal audit cycle.

Result you receive

A written audit opinion on the design and operating effectiveness of key AML controls, a graded findings list, and a remediation priority map tied to specific process steps — onboarding, periodic review, screening, monitoring, and STR escalation.

What is included

  • Kickoff workshop with your compliance and operations leads
  • Policy and procedure walkthrough against your current licence obligations
  • Sample testing of customer due diligence files and alert dispositions
  • Interviews with staff who perform day-to-day AML tasks
  • Draft findings discussion before the final report
  • Final report suitable for audit committee circulation

What is excluded

  • Legal opinions on whether a specific transaction is money laundering
  • Hands-on remediation project management (available as a separate engagement)
  • Continuous monitoring software licences or system configuration

Provider and working approach

Senior auditors from Innocloudapps lead fieldwork. We work in your premises when records cannot leave the building, and we schedule sampling windows around your month-end close so operations are not blocked for days at a time.

Process

  1. Scoping call — confirm entity type, prior findings, and systems.
  2. Document request — policies, risk assessment, sample population lists.
  3. Fieldwork — testing and interviews over agreed days.
  4. Draft review — factual accuracy check with your team.
  5. Final report — issued with management comments recorded.

Preparation

Please appoint a single engagement contact, reserve a quiet room for interview days, and prepare read-only access to CDD archives and alert queues. Incomplete sample populations delay testing more than anything else.

Constraints

We do not certify regulatory compliance as a guarantee against enforcement action. Our work is an independent audit opinion based on agreed scope and samples. Material changes to your programme mid-engagement may require a re-scope.

Fees

Quoted as a fixed fee after scoping. Starting point for a mid-sized money service operator is typically from HK$85,000. Larger licensed banks or multi-entity groups are priced on sample volume and number of business lines.

Next step

Request this engagement and mention “AML programme audit” in your message. We aim to return a draft scope within two business days.