AML Governance Review
“Is our governance effective?”
Strong governance is the foundation of an effective financial crime framework.
Independent judgement on Board oversight, accountability, decision-making and the effectiveness of your AML governance arrangements.
The question behind the engagement.
Financial crime governance is about more than policies and procedures. Regulators expect Boards and senior management to evidence effective oversight of financial crime risk, supported by clear accountability, accurate management information and well-defined governance structures.
Many firms have invested heavily in operational controls without ever asking, independently, whether governance arrangements support effective decision-making or whether responsibilities are clearly understood across the organisation.
Weak governance rarely surfaces until regulatory scrutiny, internal audit findings or significant business change expose the underlying weaknesses.
An independent perspective gives senior management an objective view of how financial crime governance operates in practice, and whether it sits sensibly against the organisation's risk profile and regulatory obligations.
Judgement, not a checklist.
We start with the Board pack. The terms of reference. The minutes. The MLRO report. The reporting lines on paper, and the ones that operate in practice.
We meet the Chair, the MLRO, the Senior Manager accountable for financial crime and, where it matters, the second and third lines. We ask the questions a supervisor would ask. We listen to what the answers reveal about how decisions actually get made.
You get a clear read on where accountability is sound, where it is ambiguous, and where the management information is reporting activity instead of risk. The recommendations are written so the Board can act on them at its next meeting.
From baseline to Board-ready confidence.
An independent governance review follows a clear arc. We map current state, test it against supervisory expectations, and leave the Board with a prioritised, proportionate plan.
A clear, staged process.
- 01
Scope
- 02
Review
- 03
Assess
- 04
Report
- 05
Action Plan
- 01
Scope
- 02
Review
- 03
Assess
- 04
Report
- 05
Action Plan
After the engagement.
- –Executive Summary
- –Governance Assessment Report
- –Governance Maturity View
- –Board Oversight Review
- –Accountability Assessment
- –Prioritised Recommendations
- –Governance Improvement Roadmap
- –Executive Debrief
- Who it's for
- Payment Institutions
- Electronic Money Institutions
- Investment Firms
- Asset Managers
- Wealth Managers
- Crypto Asset Service Providers
- Corporate Service Providers
- Typical duration
- Two to four weeks.
- Delivery
- Remote, on-site or hybrid.
- Primary output
- Independent governance perspective with practical recommendations.
- Ideal when
- Preparing for regulatory growth, Board effectiveness reviews, AMLR implementation or governance transformation.
- 01We start with the Board pack.
- 02We meet the Chair, the MLRO, the Senior Manager accountable for financial crime and, where it matters, the second and third lines.
- 03You get a clear read on where accountability is sound, where it is ambiguous, and where the management information is reporting activity instead of risk.
“The hardest part of a governance review is rarely finding the weakness. It is helping the Board see it clearly enough to act before a supervisor does.”
A few considered answers.
An AML Governance Review is an independent assessment of your firm's anti-money laundering framework, governance arrangements, policies and operational controls. We assess how your framework operates in practice, identify gaps against current regulatory expectations and provide practical recommendations to strengthen your controls before they become regulatory findings.
Internal reviews are valuable, but they are naturally influenced by existing processes and resource constraints. Claritas Risk provides an independent assessment led by a senior AML practitioner with experience gained inside leading international financial institutions. Our focus is on what regulators are likely to examine and how your framework performs in practice, not simply whether policies exist.
We support smaller regulated financial institutions including Payment Institutions, Electronic Money Institutions, Investment Firms, Wealth Managers, Asset Managers, FinTechs, Crypto Asset Service Providers, Family Offices and Corporate Service Providers.
Compliance is rarely a simple yes or no. We assess how well your controls align with current regulatory expectations, identify strengths and weaknesses, prioritise risks and recommend practical improvements that are proportionate to your business.
You receive a detailed report explaining our findings, the associated risks and clear recommendations. Where required, we also support remediation planning, implementation guidance and follow-up independent assurance.
Ready to strengthen your governance framework?
Effective governance provides the quiet foundation of every successful financial crime programme.