AML Remediation Support
“Can we deliver this remediation programme with confidence?”
Independent oversight, governance and quality assurance for AML remediation programmes.
Customer file remediation, KYC remediation and large-scale AML remediation programmes, supported by independent governance, risk prioritisation and management information that gives senior stakeholders confidence in delivery.
The question behind the engagement.
Remediation programmes are among the most operationally demanding pieces of work a regulated firm takes on. Large customer populations, evolving regulatory expectations and constant pressure to show measurable progress to supervisors, the Board and Internal Audit.
Most programmes start well and then drift. Quality varies between reviewers, decisions become inconsistent, governance weakens, and the management information stops reflecting what is actually happening on the ground.
An independent oversight layer, sitting outside the delivery teams and the second line, is what gives senior stakeholders confidence that the programme is achieving what it set out to achieve, and that the files being closed are genuinely defensible.
Judgement, not a checklist.
We agree the governance framework with the MLRO and the programme sponsor, set the decision rights and escalation routes, and chair the programme governance meeting through delivery.
We independently review completed customer files on a sampling basis, identify recurring quality issues, challenge file-closure decisions where the supporting evidence is thin, and feed the findings back into the reviewer guidance so the next batch of files lands at the right standard.
We act as the point of reference for complex implementation questions, approve the harder customer decisions where reviewers and team leads are uncertain, and work through the higher-risk cohorts directly with the delivery teams.
We rewrite the management information so it surfaces quality and risk, not just throughput, prepare the periodic update for the steering committee and the Board, and, where a regulatory undertaking is in play, prepare the supporting material for the supervisor.
A clear, staged process.
- 01
Plan
- 02
Govern
- 03
Execute
- 04
Assure
- 05
Report
- 01
Plan
- 02
Govern
- 03
Execute
- 04
Assure
- 05
Report
After the engagement.
- –Independent Oversight Reports
- –QA Framework
- –Governance Pack
- –Board MI Templates
- –Risk Prioritisation Schedule
- –Stakeholder Coordination Plan
- –Programme Health-Check Reviews
- –Closure Assurance Opinion
- Who it's for
- Payment Institutions
- Electronic Money Institutions
- Investment Firms
- Wealth Managers
- Asset Managers
- Crypto Asset Service Providers
- Corporate Service Providers
- Typical duration
- From four weeks to multi-month programme oversight.
- Delivery
- Remote, on-site or hybrid.
- Primary output
- Independent oversight that gives the Board, the MLRO and the regulator confidence in programme delivery.
- Ideal when
- Running a customer file or KYC remediation programme, responding to a regulatory undertaking, integrating an acquired book or clearing a periodic-review backlog.
- 01We agree the governance framework with the MLRO and the programme sponsor, set the decision rights and escalation routes, and chair the programme governance meeting through delivery.
- 02We independently review completed customer files on a sampling basis, identify recurring quality issues, challenge file-closure decisions where the supporting evidence is thin, and feed the findings back into the reviewer guidance so the next batch of files lands at the right standard.
- 03We act as the point of reference for complex implementation questions, approve the harder customer decisions where reviewers and team leads are uncertain, and work through the higher-risk cohorts directly with the delivery teams.
“A remediation programme is only as credible as the MI behind it. When the numbers drift, confidence drifts with them.”
A few considered answers.
We do not do the remediation. We oversee it, independently of delivery teams and the second line, to give senior management and the regulator confidence that the work is being completed to the right standard.
Yes. Most engagements sit alongside one or more delivery vendors. Our role is independent oversight, governance, quality assurance and Board-level reporting.
Yes. We regularly support programmes driven by regulatory undertakings, Internal Audit findings or post-acquisition customer-book integration.
Where appropriate, we prepare materials, brief senior management and attend regulator-facing meetings in support of the MLRO. We do not replace the MLRO or the firm's accountable officers.
Need independent oversight of a remediation programme?
Programmes succeed when governance, quality and reporting are right, not when throughput is the only measure.