Quality Assurance During KYC Remediation
A practitioner's account of what quality assurance actually looks like across the life of a live remediation.
For Programme Directors, QA Leads, MLROs, Heads of Compliance, second-line assurance leads and Steering Committee members responsible for a live KYC remediation.
Guide 007 sets out, week by week, what good quality assurance looks like during a live KYC remediation. It covers what QA is for and what it is not, how to design and select a sample that reflects risk rather than population, what reviewers look for in a file, what constitutes a defect, how to categorise defects so the data is usable, when and to whom to escalate, how to give feedback that changes the next file, how to run a weekly calibration meeting that decides consistency across reviewers, how to read the trends, when to re-review a cohort, what acceptance criteria should require before sign-off, how QA reports to the Steering Committee, the second line and the Board, and how the QA function closes out at the end of the programme so the lessons survive into business-as-usual. It closes with a working defect taxonomy and a brief for chairing the weekly calibration meeting.
Inside you will find
- What QA is for on a remediation, and what it is not
- Designing and selecting the sample so it reflects risk, not population
- What reviewers look for, what constitutes a defect and how defects are categorised
- Escalation thresholds, feedback that changes the next file and the weekly calibration meeting
- Reading the trends, when to re-review a cohort and what acceptance criteria should require
- How QA reports to governance and how the function closes out at the end of the programme
- Appendix: a working defect taxonomy and a brief for the weekly calibration meeting
This is the guide I would hand to the QA Lead on a remediation programme the week they take up the role, and to the Programme Director who has just signed off the QA charter. It does not describe quality in the abstract. It describes the work: the samples drawn, the files opened, the defects logged, the calibration meetings held, the trends read, the cases re-reviewed and the conversations that turn QA from a measurement into an instrument of change.
Fourteen sections, in the working order of a live programme. The first four cover the design of the QA function. The middle six cover the work itself, week to week. The last four cover how QA matures, reports and ultimately supports the governance that stands behind the programme.
Structured to be useful, not to impress.
What QA is for on a remediation, and what it is not
Designing and selecting the sample so it reflects risk, not population
What reviewers look for, what constitutes a defect and how defects are categorised
Escalation thresholds, feedback that changes the next file and the weekly calibration meeting
Reading the trends, when to re-review a cohort and what acceptance criteria should require
How QA reports to governance and how the function closes out at the end of the programme
Appendix: a working defect taxonomy and a brief for the weekly calibration meeting
10 Questions Every Board Should Ask Before the Regulator Does
Ten Board-level governance questions, with a structured self-assessment and score guide.
View guideIs Your AML Remediation Programme Set Up to Succeed?
Nine sections covering governance, quality assurance, MI, Board reporting and root cause analysis.
View guidePreparing for an AML Inspection
Eight focus areas from governance and CDD through to evidence preparation, with a readiness score.
View guideManaging an AML Remediation Programme
Fourteen working sections covering scope, governance, prioritisation, QA, MI, Board reporting and close-out.
View guideBoard 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.
View guidePreparing 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.
View guideBuilding 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.
View guideScoping 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.
View guideIf you're unsure whether your organisation would benefit from external support, let's have a conversation.
If we don't believe Claritas is the right fit for your organisation, we'll tell you honestly.