Managing an AML Remediation Programme
A practitioner's account of how a remediation programme is planned, governed and delivered.
For MLROs, programme sponsors, Steering Committee members and remediation leads.
Guide 004 sets out, step by step, how an AML remediation programme is planned, governed and delivered in practice. It covers scoping, volume estimation, governance design, ownership, risk-based prioritisation, escalated cases, quality assurance, management information, Board reporting, programme risks, dependencies, completion criteria and close-out. It closes with a working speaker brief for MLROs presenting the programme to their Board.
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- Scoping, volume estimation and the first ninety minutes
- Governance architecture: Steering, Programme Office, workstreams
- Risk-based prioritisation and escalation handling
- Quality assurance, management information and Board reporting
- Programme risks, dependencies and completion criteria
- Close-out, handover and a working speaker brief
This is the guide I would hand to an MLRO on the morning their Board signs off a remediation programme. It is not an overview of why remediation matters. It describes the work: the decisions taken in the first week, the documents that need to exist by the end of the first month, and the reporting that needs to sit in front of the Steering Committee from the first meeting onward.
The fourteen sections follow the order a programme is actually built. Read it through once, then keep it open in the second screen during your scoping workshops. The patterns inside are drawn from programmes ranging from a few thousand files in a single jurisdiction to multi-entity remediations across several supervisors. The mechanics travel.
Estructurado para ser útil, no para impresionar.
Scoping, volume estimation and the first ninety minutes
Governance architecture: Steering, Programme Office, workstreams
Risk-based prioritisation and escalation handling
Quality assurance, management information and Board reporting
Programme risks, dependencies and completion criteria
Close-out, handover and a working speaker brief
10 Questions Every Board Should Ask Before the Regulator Does
Ten Board-level governance questions, with a structured self-assessment and score guide.
Ver guíaIs Your AML Remediation Programme Set Up to Succeed?
Nine sections covering governance, quality assurance, MI, Board reporting and root cause analysis.
Ver guíaPreparing for an AML Inspection
Eight focus areas from governance and CDD through to evidence preparation, with a readiness score.
Ver guíaBoard Oversight of Financial Crime
Fourteen working sections on what the Board owns, the papers it reads, the questions it asks and the decisions it cannot delegate.
Ver guíaPreparing for an AML Inspection
Fourteen working sections covering the notice letter, the document request, the data room, the interviews, the exit meeting and how to respond to draft findings without negotiating away the truth.
Ver guíaQuality Assurance During KYC Remediation
Fourteen working sections covering sample design, defect taxonomy, calibration meetings, trend reporting, re-review triggers, acceptance criteria and how QA supports governance rather than only measuring it.
Ver guíaBuilding Meaningful AML Management Information
Fourteen working sections covering the three lenses of activity, quality and residual risk, the five-question rebuild, KRIs and thresholds, the commentary discipline, escalation, the annual rebuild and how MI fails quietly.
Ver guíaScoping an AML Remediation Programme
Fourteen working sections covering population definition, segmentation, the file standard, productivity pilots, capacity in layers, governance, mobilisation, dependencies, budget, contingency and the assumptions register that holds the plan together.
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Si no creemos que Claritas sea la opción adecuada para su organización, se lo diremos con franqueza.