Independent AML Assurance Review
“Can our Board rely on our financial crime controls?”
Independent assurance that gives Boards confidence.
An objective perspective on your financial crime framework, independent judgement on governance, controls and operational effectiveness, delivered through clear, considered reporting.
The question behind the engagement.
Senior management and Boards are increasingly expected to demonstrate effective oversight of financial crime risk. While first and second line functions manage day-to-day controls, there is often value in obtaining an independent opinion on whether the framework is operating as intended.
Whether preparing for Board reporting, regulatory engagement or governance improvements, an external perspective provides additional confidence and can identify weaknesses that internal teams may overlook.
Independent assurance is not about finding fault. It is about providing objective insight, constructive challenge and practical recommendations that support better governance and informed decision-making.
Judgement, not a checklist.
We read the Board and committee packs, the MLRO report, the BWRA and the supporting governance papers, and trace each conclusion back to the evidence the firm is relying on.
We sample customer files across the higher-risk cohorts, review transaction monitoring alert handling and SAR decisions, and meet the MLRO, the Senior Manager accountable for financial crime and the relevant operational leads. We test whether the controls described in the documentation are the controls operating on the ground.
We provide the Board and the Audit Committee with an independent written opinion that names where the framework is sound, where it is not, and what to prioritise. We brief the executive in person, attend the committee meeting where the report is discussed, and take the questions that follow.
After the engagement.
- –Executive Summary
- –Independent Assurance Opinion
- –Detailed Findings
- –Governance Perspective
- –Risk Prioritisation
- –Practical Recommendations
- –Board-ready Report
- –Executive Debrief
- Who it's for
- Boards
- Audit Committees
- Chief Executive Officers
- MLROs
- Heads of Compliance
- Payment Institutions
- Investment Firms
- Electronic Money Institutions
- Asset Managers
- Crypto Asset Service Providers
- Typical duration
- Two to four weeks.
- Delivery
- Remote, on-site or hybrid.
- Primary output
- Independent assurance report suitable for Board discussion.
- Ideal when
- Seeking independent oversight, strengthening governance or providing additional assurance to senior management.
- 01We read the Board and committee packs, the MLRO report, the BWRA and the supporting governance papers, and trace each conclusion back to the evidence the firm is relying on.
- 02We sample customer files across the higher-risk cohorts, review transaction monitoring alert handling and SAR decisions, and meet the MLRO, the Senior Manager accountable for financial crime and the relevant operational leads.
- 03We provide the Board and the Audit Committee with an independent written opinion that names where the framework is sound, where it is not, and what to prioritise.
A few considered answers.
An objective opinion on your financial crime framework, considering governance, operational controls and overall effectiveness. The work offers senior management and the Board an independent perspective supported by practical recommendations.
No. Internal Audit provides independent assurance over the effectiveness of governance, risk management and controls within an established audit framework. Claritas Risk provides specialist financial crime expertise, practical, advisory-focused assurance designed to complement, not replace, Internal Audit.
Boards, Audit Committees, senior management and MLROs, in clear language that supports informed governance decisions.
Yes. Many firms commission independent assurance before regulatory inspections or as part of wider governance enhancement programmes to demonstrate proactive oversight.
Yes. We can undertake follow-up assurance work to independently consider whether agreed improvements have been implemented and are operating effectively.
Ready for an independent perspective?
Independent assurance provides confidence not only to regulators, but to your Board, your senior management and your organisation.