AML/CFT Independent Review: Evidence Standards and Common Gaps
The evidence standards required for independent AML/CFT review and the most common gaps identified in review engagements.
Public summary
Public summary of an institutional briefing. Full document available to verified counterparties.
Independent AML/CFT review is increasingly required by counterparties, correspondent banks and institutional partners. The standard is no longer a policy file and a training log.
This briefing documents the evidence standards expected: documented risk assessment, customer due diligence record discipline, transaction monitoring rule rationale, alert investigation workpapers, suspicious activity reporting traceability and MLRO oversight evidence.
It also identifies the most common gaps observed in review engagements — and how those gaps are typically closed.
The full version of this publication is provided on request to verified institutional counterparties under standard confidentiality terms.
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