Independent AML file review
Twenty client files, read the way a regulator's reviewer reads them, by a named former MLCO who is independent of your compliance function. A gap matrix, a risk rating with the reasoning, and a remediation plan with owners and dates — in five to ten working days.
Why firms commission this
Regulation 21 expects an independent audit of your AML controls, proportionate to the practice, and the auditor must be independent of the function being reviewed. Most firms commission one after an adverse finding, a client questionnaire or an insurer renewal — which is the most expensive moment to discover a pattern.
- Independent of your compliance function, on paper and in practice
- A named specialist signs every finding — not a template
- Delivered as evidence you can file, not advice you have to summarise
Stated in advance, delivered as described.
Per-file findings
Seven control areas per file: CDD adequacy, ID and verification, source of funds and wealth, PEP screening, matter risk assessment, ongoing monitoring and retention. Each finding carries the rule applied, the page-level evidence, a confidence rating and a human decision.
Firm-level gap matrix
Where the weaknesses cluster — by control area, by matter type, by fee-earner or by office. This is the page most boards actually read, because it turns twenty files into a pattern.
Risk rating, with reasoning
An overall assurance rating stated plainly, with the reasoning a non-specialist can follow and challenge. No unexplainable scores.
Remediation plan
Named owners, target dates and effort estimates. Written so that the plan survives Monday morning rather than being admired and ignored.
Board summary
One page for the partnership, formatted to be filed as evidence of independent review — independence statement attached.
Methodology appendix
The ruleset version, sampling rationale and the limitations of the method, including the findings our tooling got wrong and the reviewer overruled.
Four steps, no surprises.
Free 3-file check
Send three files. We review them the way a reviewer would and send one page of findings in about 48 hours. No charge, no obligation.
Scope and fixed fee
A written proposal: sample basis, deliverables, turnaround, fee. 50% on booking, 50% on delivery, and the number does not move.
Secure intake and ruleset pass
Encrypted transfer, access limited to the named reviewer, structured extraction, then the MLR 2017 ruleset across the sample.
Human review and report
The associate confirms, rejects or escalates every finding, signs the report, and walks your team through it.
Fixed numbers. The invoice matches the proposal.
| Engagement | Cost | Turnaround | What it covers | |
|---|---|---|---|---|
| AML file review | $3,700 – $4,50020 files · fixed | 5–10 working days |
Independent review of a sampled file set against the Money Laundering Regulations 2017 — the check regulation 21 expects and your COLP answers for personally.
|
Contact us → Estimated range $3,700 – $4,500 · how quotes work |
| AML file review — founding client | $3,500 – $3,80020 files · first three clients | 5–10 working days |
The same review at the founding rate, traded for a named testimonial and permission to publish an anonymised case study.
|
Contact us → Estimated range $3,500 – $3,800 · how quotes work |
| Review + policy refresh + training | $7,000 – $8,500pack | 2–3 weeks |
Findings are half the job. This pairs the 20-file review with a firm-wide AML policy rewritten against what we found, plus a live session your fee-earners won't mute.
|
Contact us → Estimated range $7,000 – $8,500 · how quotes work |
Payment. 50% on booking, 50% on delivery unless the option says otherwise. Card payment through Stripe, or invoice with bank transfer. Card details never touch our servers. Larger deployments are billed to milestones agreed in writing before work starts.
- Firms of 5–50 fee earners with no independent review on file
- COLPs and MLROs answering a board, an insurer or a client questionnaire
- Firms whose last review was internal, or more than two years old
- Firms preparing for a supervisory visit who want the gaps found first