Engagement

CDD file testing

Targeted sampling of customer due diligence files to test completeness, risk rating consistency, and refresh timing.

  • Format: Remote or on-site sampling
  • Typical duration: 2–4 weeks
  • Delivery: Hong Kong
  • Fees: From HK$38,000 depending on sample size
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Overview

When your last full AML audit is recent, but onboarding quality still worries the MLRO, CDD file testing isolates the customer file itself. We pull a risk-weighted sample across high-risk, medium-risk, and low-risk segments and score each file against your own checklist plus Hong Kong market practice.

Included

  • Agreed sample size and selection method
  • File-by-file scorecard
  • Themes across missing documents, stale refreshes, and rating drift
  • Short briefing for the compliance team

Not included

Full programme design assessment or sanctions screening logic review.

Fees and next step

Fees start from HK$38,000 for a 40-file sample. Ask about CDD file testing.