Specialist advisory
Independent AML reviews for fintechs and MSBs
Clarify the review purpose, scope and independence before the work begins.
When an independent review is the appropriate conversation
You may need an objective evaluation of an existing program, a response to a review requirement or a clearer view of operating effectiveness. A general readiness assessment is not a substitute for a properly scoped independent review.
Agree the scope and the intended use
We discuss the business activities, applicable expectations, period covered and who will use the findings. Deliverables and limitations are agreed before work begins. The review can inform management priorities; it does not guarantee acceptance by a regulator or bank.
Independence must be assessed
Where Blue Aries Ventures has designed or operated the relevant program, we assess whether the independent-review engagement can appropriately be accepted. Independence is not assumed merely because the work is described as a separate project.
After the review
Management needs to understand the findings and decide how to respond. Any remediation support is separately scoped with appropriate consideration of independence. Timing and fees depend on the complexity and availability of information.
