Engagement overview
Fintech AML program audit
A growing fintech’s review of program controls, customer files and remediation priorities.
The situation
The engagement concerned a growing fintech preparing for a regulatory examination. Concerns included monitoring settings, incomplete customer documentation, escalation procedures and training records.
The engagement scope
The scope covered policy and procedure review, governance, transaction testing, alert decisions and customer-file review. The focus was on understanding whether documented controls matched day-to-day practices.
The remediation priorities
The review focused on monitoring calibration, customer due diligence, escalation ownership and training documentation. These workstreams connect program design to the people and systems carrying it out.
What startup teams can take from this
Do not wait for scale to expose an unclear decision process. Maintain traceable control evidence, named owners and an open-issues log. A readiness review and an independent audit are distinct scopes; establish the purpose, coverage and independence before the work begins.